planning report D&P/3763/01 21 April 2016 2-3 Avenue, in the

planning application no. 16/00149/FULEIA

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

The proposal Demolition of existing buildings and construction of a building arranged over 3 basement floors, ground and 32 upper floors plus mezzanine and 3 rooftop plant levels (168.4m AOD) to provide office accommodation (Class B1); flexible retail uses (Class A1-A3); cafe/restaurant uses (Class A3); flexible retail uses (Class A1/A3); a flexible space for office, conferencing, events and/or leisure use (Class B1, D1, D2 and/or sui generis) and a publicly accessible roof terrace and associated facilities; hard and soft landscaping works; servicing facilities; and other works incidental to the development (total floor area 92,123sq.m GEA). This application is accompanied by an Environmental Statement.

The applicant The applicant is Bluebutton Properties Ltd and the architect is Arup Associates.

Strategic issues The proposal is supported in strategic planning terms. This is an appropriate location for a tall building of high design quality, and the proposed office development would support the function of the Central Activities Zone. Various outstanding matters with respect to urban design, safeguarding future development, sustainable development and transport should, nevertheless, be addressed prior to the Mayor’s decision making stage.

Recommendation That the City of London Corporation be advised that whilst the application is broadly supported in strategic planning terms, the application does not fully comply with the London Plan for the reasons set out in paragraph 82 of this report. The resolution of those issues could, nevertheless, lead to the application becoming compliant with the London Plan.

page 1 Context

1 On 11 March 2016 the Mayor of London received documents from the City of London Corporation notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 21 April 2016 to provide the City Corporation with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under the following categories of the Schedule to the Order 2008:

 1B 1.(a) “Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings - in the City of London and with a total floorspace of more than 100,000 square metres”; and,

 1C 1.(b) “Development which comprises or includes the erection of a building of… more than 150 metres high and is in the City of London”.

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

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

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

6 The existing 0.49 hectare site comprises two 1980’s commercial office buildings located at 2-3 Finsbury Avenue at the northern end of Finsbury Avenue Square within the Estate. The site is situated at the north-eastern extent of the City of London and is immediately adjacent to the administrative boundaries of the London Boroughs of Hackney and . It is within the Central Activities Zone as identified by the London Plan. The City Fringe Opportunity Area lies immediately to the north of the site.

7 The application site is bounded by Finsbury Avenue Square and the Grade II listed 1 Finsbury Avenue building to the south, Sun Street to the north and Wilson Street to the west. is the closest part of the Strategic Road Network, and Bishopsgate (A10) lies approximately 400 metres to the east.

8 The site is highly accessible by public transport, being 300 metres from where national rail and underground services on the Central, Metropolitan, Circle and Hammersmith & City lines can be accessed, as well as 17 bus routes. services and additional national rail services and bus routes are available 400 metres away at station and Docklands Light Railway and Waterloo & City line services are within walking distance at Bank station. From 2018, Crossrail services will also stop at Liverpool Street, with an entrance from Moorgate. As such, the site records the highest possible Public Transport Accessibility Level (PTAL) of 6b. There is a cycle hire docking station opposite the site on Sun Street, and Cycle

page 2 Superhighway Route 1 will also start close to the site at the junction of Wilson Street and Sun Street.

Details of the proposal

9 The proposals seek the demolition of the existing commercial buildings and their replacement with a mixed-use, office-led redevelopment. The mix of uses will be predominantly B1 office floorspace, with A1-A3 retail/commercial uses on the ground floor within a new arcade that will link Finsbury Avenue Square with Sun Street to the north and publicly accessible A3 restaurant/cafe uses at 13th floor level. A conference/events space (Class D1/D2/sui generis) would be provided on the top floors of the secondary (levels 14-18). The building will provide a total of 92,123 sq.m. (GEA) of floorspace (84,226 sqm GIA).

10 It is proposed that the building will be formed of four distinct masses of varying heights, with the tallest standing at 168.4 metres AOD. The existing Broadgate Tower (approximately 325 metres to the north east of the site) stands at 178.2 metres AOD. Case history

11 On 30 September 2015 GLA planning officers met with the applicant team and planning officers from the City of London to discuss the proposals for the site. GLA officers advised that the scheme was broadly supported in strategic planning terms subject to an appropriate contribution to off-site housing provision, but that the future application would need to address London Plan policy with respect to urban design, inclusive access, sustainable development and transport. Strategic planning issues and relevant policies and guidance

12 The relevant strategic issues and corresponding policies are as follows:

 Principle of Development London Plan; Central Activities Zone SPG;  Offices London Plan; Central Activities Zone SPG;  Mix of uses London Plan; Central Activities Zone SPG;  Urban design London Plan; Shaping Neighbourhoods: Character and Context SPG;  Strategic views London Plan, London View Management Framework SPG;  Historic environment London Plan; World Heritage Sites SPG;  Inclusive access London Plan; Accessible London: achieving an inclusive environment SPG;  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy;  Transport London Plan; the Mayor’s Transport Strategy;  Crossrail London Plan; Mayoral Community Infrastructure Levy

13 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the City of London Local Plan 2015 and the 2015 London Plan (Consolidated with Alterations since 2011).

14 The following are also relevant material considerations:

page 3  The National Planning Policy Framework, Technical Guide to the National Planning Policy Framework and National Planning Practice Guidance;  City of London Corporation Planning Obligations SPD (2014).  Central Activities Zone SPG (2016)

Principle of development

Mix of uses in Central Activities Zone (CAZ)

15 London Plan policies 2.10 and 4.2 encourage the renewal and modernisation of existing office stock in viable locations to improve its quality and flexibility, seeking increases in current stock where there is evidence of sustained demand for office based activities, in order to sustain and enhance the City of London’s role as a strategically important, globally oriented financial and business services centre. The proposal to provide an uplift in office floorspace of approximately 39,000 sq.m. (GIA) in this location is therefore welcomed and supported in strategic policy terms.

16 The proposal would provide approximately 60,800 sq.m. (GIA) of high quality B1 office floorspace in what is envisaged to be a flexible and multi-tenanted building. The applicant has stated the intention to diversify the type of B1 offer through the provision of flexible office space. The main floor levels can be divided into two tenancies per floor. The floorspace thus has the potential to accommodate small and medium enterprises (SMEs) as well as more typical financial, legal and business services, and it is also intended that some of the floorspace would attract tech/digital-creative companies such as those common to the City Fringe area, which is welcomed. The opportunity to rent space on more flexible leases which are considered more amenable to smaller companies would also be encouraged in accordance with London Plan Policy 4.2. The applicant should provide further information on how SMEs would be accommodated within the building, and how leases could be offered flexibly and affordably. The City Corporation should consider securing a proportion of flexible, affordable workspace in the s106 agreement for the scheme, and this information should be provided before the Mayor considers this application again.

17 London Plan Policy 2.11 states that development within the CAZ should increase office floorspace and include a mix of uses that includes housing. Similarly London Plan policy 4.3 states that development resulting in an increase in office floorspace should provide for a mix of uses including housing. Both policies, however, state that the proposed land-use mix should not conflict with other London Plan policies. Furthermore, paragraph 4.17 of the London Plan states that exceptions (to providing housing) can be permitted where the mix of uses might compromise broader objectives.

18 The site sits within the City of London and is immediately adjacent to the core growth area of the City Fringe Opportunity Area. As such, the site is within a business location of national importance, where demand for office floorspace is high and expected to remain so. There is a strategic concern that low vacancy rates and insufficient future levels of office floorspace provision could have a negative impact on the competitiveness of the City and the growing Tech City business cluster, and jeopardise future economic growth. Furthermore, the introduction of residential uses at this site could potentially undermine employment uses here and nearby, for example by impacting late night operation and servicing.

19 A land-use mix that does not include residential development in this location is supported in this case, as the development could strongly contribute towards supporting both the City and the City Fringe as business locations of national significance. As such, the inclusion of on-site housing is not required and contributions to off-site affordable housing should be calculated in line

page 4 with the City of London Corporation Planning Obligations SPD and secured by s106 legal agreement.

Retail and public terrace

20 The proposal includes retail/café/Class A2 uses at ground floor and mezzanine levels [total floorspace 1,665 sq.m. NIA]. The provision of retail units at ground floor will help animate the public realm and provide facilities for workers and visitors and is therefore supported in accordance with London Plan policies 2.11 and 4.3. The applicant has submitted a retail statement in view of the significant amount of new retail floorspace in an edge of centre location (being some 200m from the Liverpool Street and Moorgate Principle Shopping Centres as defined in the City of London Local Plan). The retail statement concludes that the proposed development complies with the NPPF sequential test and impact test in that it would not result in significant adverse impact on existing retail centres. The report states that the proposed retail floorspace would be flexible, providing space for small to medium size occupiers which would primarily serve the increase in office floorspace on the site and would not compete with or prejudice the existing offer in the Principle Shopping Centres. Given the layout of the proposed retail floorspace, which is physically divided into relatively small individual units by the floorplate of the building, GLA officers consider that the proposed retail uses would complement the existing retail offer in the established centres, rather than prejudicing their viability, and thus concur with the conclusions of the applicant’s statement.

21 The proposed development would also provide a publicly accessible terrace/viewing gallery with supporting café and restaurant uses at 13th floor level that would be accessed off Finsbury Avenue Square via scenic lifts. This is strongly welcomed in accordance with London Plan Policy 7.7 on tall buildings and public access. Public access to this area should be secured in the s106 legal agreement together with the specification of the spaces and details of how access will be managed (including any booking system and entry charges. Free of charge access should be secured wherever possible). Details of the proposed heads of terms should be provided before the application is referred back to the Mayor at Stage 2. Urban design

Tall building

22 The site is located within an emerging cluster of tall buildings around Bishopsgate and is considered to be a location where a tall building is acceptable in principle, subject to the highest standards of architecture and urban design, as prescribed by London Plan Policy 7.7. The form and massing strategy is broadly supported and responds successfully to the historic urban grain along Sun Street through a series of defined massing elements of vertical proportions and varying heights. The taller elements are broadly aligned with the scale of emerging development to the north of the site, including Crown Place, Principal Place and Bavaria House. The positioning of the tallest element alongside Finsbury Avenue Square helps to denote this portion of the Broadgate Estate and has potential to contribute towards local way-finding.

23 Having considered the submitted townscape, built heritage and visual impact assessment (see also below), and notwithstanding comments below regarding the relationship with emerging proposals in terms of impact on amenity, GLA officers are of the opinion that the height and form of the proposed building relates well to the emerging cluster of tall buildings and the surrounding area.

24 As mentioned above, the proposed provision of a publicly accessible terrace at the building is strongly supported. Noting the considerations associated with architectural quality, strategic views and the historic environment (refer to paragraphs below), GLA officers are

page 5 satisfied that the application accords with London Plan Policy 7.7. However, as detailed in paragraphs 43 to 47, the applicant should also have regard to the impact of the towers on neighbouring consented schemes.

Layout

25 The layout principles underpinning the scheme are broadly supported and include the reinstating of the historic Sun Street building line alongside the introduction of active frontages to the majority of public facing edges, which is welcomed. The inclusion of a diagonal link to respond to an established desire line towards and Old Street beyond is recognised as a positive element of the scheme and will contribute towards improved local permeability while assisting in optimising the level of street-base activity. It was raised at the pre-application stage that the design and proportions of the openings to the link are crucial in achieving a welcoming and fully public route and the applicant should work towards increasing the height of the link to optimise the route’s potential. This has been achieved by allowing the corner element to cantilever above the triple-height entrance to the public route, which would provide a strong and legible marker for the entrance. The route itself would be a generously proportioned double-height space.

26 The design has sought to maximise the amount of active frontages on the buildings, including on either side of the new arcaded diagonal route, and along Whitecross Place, which will help support welcoming and active pedestrian thoroughfares. It is acknowledged that the service access point would be positioned along the prominent Wilson Street frontage (relocating the existing service entrance from Sun Street). This is unfortunate, although it is noted that new commercial frontages along Wilson Street and Sun Street have the potential to provide more activation to these streets than the existing ground floor office development. The applicant should thus seek to maximise the amount of commercial and active frontage along Sun Street in compensation. The current floorplans show that a long stretch of this frontage at ground floor level is occupied by voids, circulation spaces and a post room which could be located internally within the building and opportunities to introduce an additional commercial unit here, or a more active edge to this frontage, should be explored.

27 Similarly, on Whitecross Place the transparent lifts would provide some animation, but the applicant should make use of all opportunities to maximise the amount of commercial frontage, to encourage activity along this link. In this regard, the commercial unit to the west of the lifts could be extended to wrap around the corner into Wilson Street and the applicant should explore this possibility.

Architecture

28 The façade treatment would reinforce the vertical emphasis of the buildings, providing an effective counterpoint to nos. 1 and 5 Finsbury Avenue Square which have a horizontal emphasis. The façade treatment is conceived as vertical glass panes cleaved to follow the diagonal geometry of the building’s form. Each typical office floor level would be clad in clear glass panels with a translucent interlayer at floor height and a rolled glass panel at spandrel level. Each panel would be separated with vertical glass fins extending for the full height of each element of the building. In vertical bands and at every fourth level a break in the façade treatment would be created with insulated rolled glass panels. These panels will have a textured surface and reflective back face, capturing reflections from the sky. At ground to fourth floor levels, the facades would take on a less geometric form with rounded corners, and the cladding would wrap around these elements fluidly up to the various soffit levels of the building above. This would help define a more informal and human scale to the pedestrian realm, creating welcoming and legible public spaces.

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29 The minor tower would be clad in the same type of system, but would be differentiated from the main tower by translucent areas created by a white PVB interlayer. This would reduce solar glare and would create a diffuse light when the events space is illuminated in the evenings.

30 The architectural treatment results in an elegant building which demonstrates a high standard of architecture in accordance with London Plan Policy 7.6. It is important that the City Corporation controls the quality of materials and detailing through the use of planning conditions. The Corporation should also consider making it an obligation within the s106 agreement that the architects are retained throughout the build project, as a means of ensuring continuity and quality of design within the Broadgate Estate.

Landscape and public realm

31 The scheme interfaces with the existing public open space of Finsbury Avenue Square as well as creating a new public link from the Square to Sun Street. As discussed above, it is considered that the building would relate well to the public realm and would complement the character of Finsbury Avenue Square. Subject to achieving the fullest possible activation of the Whitecross Place façade, it is also considered that the development would improve the pedestrian realm along this existing street. Details of the surface treatments around the building, including on Whitecross Place and along the diagonal pedestrian link, should be submitted to ensure that the extended public realm ties in to the surface treatments within the wider Broadgate Estate. It is also noted that there are street trees on the Sun Street and Wilson Street frontages which should be retained, or replaced with at least an equivalent number if damaged or removed during construction (it is also noted that this is a key feature of the proposed wind mitigation measures, along with the planting of new trees). The detailed landscape design including, materials, tree planting and street furniture should be secured by condition to ensure compliance with London Plan Policy 7.5.

Wind

32 The environmental assessment that accompanies the scheme includes an assessment of the effect upon wind microclimate, which has been informed by wind tunnel tests. Consideration was given to the effect upon pedestrian thoroughfares in and around the site, and at locations representing entrances and amenity spaces. These receptors were generally expected to record an acceptable wind environment for their intended use when tested with the proposed development in place, including appropriate mitigation measures. An assessment was made for an existing scenario and a cumulative scenario taking into account approved developments in the surrounding area.

33 The mitigation measures to be incorporated into the development include the planting of new trees in the eastern passage between the building and 5 Broadgate and in Whitecross Place (as well as the retention of existing trees), the placing of “flag” baffles on either side of the Arcade and screen baffles near to the existing art installation on Sun Street. Measures have also been proposed to maintain comfortable wind conditions in the public space at thirteenth floor level. With mitigation measures in place an acceptable wind environment is expected for all receptors in both the proposed and cumulative scenarios. The applicant should confirm that the required mitigation measures will be installed and these should be secured by condition. Strategic views

34 The London View Management Framework SPG provides supplementary guidance relating to London’s key views (panoramas, river prospects, townscape views, and linear views)

page 7 and how they should be protected and managed. It expands on the guidance provided in London Plan policies 7.11 and 7.12.

35 Whilst the site is considered appropriate for a tall building, the development has the potential to impact on strategic views of St. Paul’s Cathedral, notably those from Westminster Pier (Linear View 8A.1), King Henry’s Mound (Linear View 9A.1) which the site sits between as well as the River Prospect from Waterloo (River Prospect 15B.2). As part of the environmental assessment which accompanies the scheme, the applicant has presented a wide range of verified view studies to demonstrate the potential impact on the relevant strategic views (including rendered views of the proposal from LVMF views 15B.1 & 2; and wirelines from LVMF views 8A.1; 9A.1; 10A.1; 13A.1; 13B.1; 16B.1 & 2; 17B.1 & 2).

36 When viewed from the River Prospect 15B.2, the tower will appear in the emerging cluster of tall buildings to the west of St Paul’s Cathedral. While the proposals would marginally increase the scale of development closest to the St Paul’s this will not negatively impact on the existing clear sky background or the current composition of the view. The dome and western towers remain prominent in the river prospect and therefore the proposals are not considered to adversely affect this strategic view.

37 The tower will not be visible from Linear View 8A.1 from Westminster Pier as it will be entirely obscured by the peristyle of the Cathedral or the Shell Centre and London Weekend Television buildings, thus maintaining the visual frame around the strategic landmark. The submitted views from King Henry’s Mound (Linear View 9A.1) also demonstrates that the proposed tower will appear as part of the emerging cluster of tall buildings around Bishopsgate and will not detract from the viewer’s ability to recognise and appreciate the Cathedral.

38 The visualisations presented within the application documentation demonstrate that the proposals are compliant with the LVMF and London Plan policies 7.11 and 7.12.

Historic environment

39 London Plan Policy 7.8 ‘Heritage Assets and Archaeology’ states that development should identify, value, conserve, restore, re-use and incorporate heritage assets where appropriate. The development site is positioned adjacent to a Grade II listed building at no.1 Finsbury Avenue. The Sun Street Conservation Area lies opposite the proposed development on the other side of Sun Street, and on the north eastern corner of Sun Street and Wilson Street is the Grade II listed Flying Horse Public House. The proposal would also be visible from a number of nearby conservation areas, including the South Conservation Area and the Bunhill Conservation Area. The Planning (Listed Buildings and Conservation Areas) Act 1990 sets out the tests for dealing with heritage assets in planning decisions. In relation to listed buildings, all planning decisions should “have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses” and in relation to conservation areas, special attention must be paid to “the desirability of preserving or enhancing the character or appearance of that area”.

40 The NPPF states that when considering the impact of a proposal on the significance of a designated heritage asset, great weight should be given to the asset’s conservation, and the more important the asset, the greater the weight should be. Significance is the value of the heritage asset because of its heritage interest, which may be archaeological, architectural, artistic or historic, and may derive from a heritage asset’s physical presence or its setting. Where a proposed development will lead to ‘substantial harm’ to or total loss of the significance of a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits

page 8 that outweigh that harm or loss. Where a development will lead to ‘less than substantial harm’, the harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.

41 With regard to the immediate neighbour, 1 Finsbury Avenue, this building formed part of the original design for the Broadgate Estate along with nos. 2-3 Finsbury Avenue. It is recognised that nos. 2-3 Finsbury Avenue make a contribution to the significance of No. 1 due to the similar design and materiality of these buildings and for being the work of the same architectural studio, although the buildings are not of high enough design quality to be listed in their own right. The proposed development would clearly alter the existing setting of the listed building. However, it is not considered that the impact would harm its significance. The proposed new building would be physically separate from the listed building, following the alignment of the existing passage between the buildings. The lowest part of the new building would be positioned to the west, and would be viewed in the street frontage adjacent to no. 1. The height of this element would approximately align with the height of no.1’s stair cores. Scenic lifts on the minor tower of the building would also face south towards the listed building, allowing the northern façade to be appreciated from a new vantage point. When viewed from the south from Wilson Street, the light colouration of the proposed building would provide a contrasting backdrop for the listed building, allowing it to be clearly distinguished and allowing its architectural elements to be better revealed.

42 In terms of the impact on the nearby listed buildings, conservation areas and the wider historic setting (which is audited within the submitted townscape heritage and visual impact assessment), it is recognised by GLA officers that the juxtaposition between old and new buildings is a defining and positive characteristic of the City of London. Whilst the building would alter the setting of the buildings in the immediate vicinity, it is not considered that existing building contributes to the historic significance of the setting, or that the new building would harmfully affect it. The proposal would be seen in conjunction with historic buildings and heritage assets in longer townscape and strategic views. However the proposed building would be seen in the background, in the context of an emerging tall building cluster in the City of London, and would not harmfully alter the setting or appreciation of those historic assets. Having carefully considered the townscape, built heritage and visual impact assessment, and having had special regard to the desirability of preserving the setting of Listed Buildings, GLA officers are of the view that the proposal would not harm the setting of Listed Buildings, and would not harm the character/setting of nearby Conservation Areas. Accordingly, GLA officers are satisfied that the application accords with London Plan Policy 7.8 and the NPPF.

Impact on future development sites

43 As mentioned above, the development would form one of several tall buildings within an emerging cluster of consented developments. Other nearby consented schemes include One Crown Place and Bavaria House in the Borough of Hackney.

44 One Crown Place is an approved scheme for mixed use development including residential uses within two towers of 29 and 33 storeys. This development site is positioned on the opposite side of Sun Street to the current proposed development, and would include south-facing residential units orientated towards the proposed towers at 2-3 Finsbury Avenue.

45 The GLA was supportive of the scheme at One Crown Place as this mixed use development, including residential uses, responded positively to the strategic objectives of City Fringe OAPF. Officers understand that the developers of this site have raised strong concerns regarding the current 2-3 Finsbury Avenue proposals, with respect to the impact of the taller elements of the proposed building on the outlook and daylight/sunlight to the consented

page 9 south-facing residential apartments. The Crown Place developers have suggested that the scheme could be amended to ensure a more sensitive relationship with the consented development.

46 Although the consented scheme at One Crown Place has not yet been implemented, GLA officers are keen to ensure that the proposed development on the Finsbury Square site does not prejudice the development potential or the quality of the consented scheme which, as mentioned above, is considered to contribute positively to the objectives of the City Fringe Opportunity Area.

47 It is understood that British Land are currently in discussions with the Crown Place developers to reach an agreed position, which may involve amendments to the proposed Finsbury Avenue scheme. Further discussion is strongly encouraged. In this regard, GLA officers request that the applicant submits further evidence to demonstrate that the design development of the proposals has taken into account the consented schemes, with particular regard to preserving reasonable outlook and daylight conditions for the residential development. To date, the submitted “Alternatives and Design Evolution” document within the ES does not explain how the development has taken into account any consented but unbuilt developments, and this could be updated, or an additional document provided. Also, it is noted that whilst a daylight and sunlight assessment has been appended to the ES which considers the impact of the proposals on One Crown Place, this is not currently accompanied by further explanation or conclusions. The impact on daylight and sunlight to the proposed units in Crown Place would appear to be significant according to this document, and further evidence should be submitted to explain why the impacts would be acceptable. Finally, evidence of the discussions with the developer of One Crown Place, including any agreed amendments, should be submitted to the Mayor before his decision making stage.

Inclusive access

48 This scheme represents an important opportunity to promote equal and convenient access to employment opportunities in accordance with the principles of London Plan Policy 4.12. The proposal would be a significant new building in the City, linking existing public open spaces and providing new publicly accessible facilities, including the public terrace. The building should achieve the highest standards of accessible and inclusive design in accordance with London Plan Policy 7.2. The applicant has set out its response to access and inclusion within the design and access statement.

49 The proposed development and public realm will create a new pedestrian desire line between Finsbury Avenue Square and the surrounding public highways. The pedestrian routes and entrances into the building will be step-free and at a gradient not exceeding 1:20. Entrances served by revolving doors would have a pass door to the side. There would be step free access to all passenger lifts, and all lifts (including the scenic lifts) would be DDA compliant. Based on the submitted information the proposals provide the key features for compliant and convenient access and are therefore capable of achieving the high standards for inclusive access to meet the needs of the public and commercial office tenants in accordance with London Plan Policies 4.12 and 7.2. A detailed access statement, which should include full details of external and internal accessible features of the building including finishes, fixtures and fittings as well as any constraints to providing full accessibility, should be secured by condition.

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Sustainable development

Energy strategy

50 For the purposes of assessing applications against the carbon dioxide savings target within London Plan Policy 5.2, the Mayor now applies a 35% reduction target beyond Part L 2013 of Building Regulations. In accordance with the principles of Policy 5.2 the applicant has submitted an energy strategy for the development, setting out how the scheme proposes to reduce carbon dioxide emissions in accordance with the London Plan energy hierarchy.

51 For first part of the energy hierarchy (Be Lean), a range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include high efficiency systems with high equipment coefficients of performance (COP) and energy efficiency ratios (EER), efficient LED lighting, high quality site-wide automatic controls/building management systems (BMS) and heat recovery on main office mechanical ventilation equipment.

52 The demand for cooling will be minimised through high performance coating glazed elements with low g-value of 0.3 and extensive solar shading with vertical fins along the glazed areas to further reduce the unwanted solar gains. Moreover, the heat distribution pipework will be designed to minimise pipe lengths and all heating and chilled water systems will be well insulated to prevent the internal heat generation in the building. Finally, a bypass will be designed into the air handling units of the building ventilation system to make use of ‘free cooling’ in the winter months. Heat will also be recovered from return air via high efficiency heat exchangers. In the Events Centre, a closed-cavity façade has been included as part of the design with automated shading devices installed within the cavity and external conditions being constantly monitored electronically. The shading device in the cavity is deployed automatically when solar radiation reaches a certain level.

53 An Overheating Analysis using thermal dynamic modelling has been undertaken to assess the overheating risk within the conditioned areas of the building. Its results demonstrate that all rooms in the building pass the Criterion 3 criteria for limiting solar gains, except for a Mezzanine Reception zone, due to the large proportion glazing. The applicant should provide information on the percentage of Criterion 3 fail in this zone and investigate further design measures in order to reduce the unwanted solar gains entering the zone.

54 The applicant is also required to provide information on the light transmittance of the glazing, due to the low g-value proposed, in order to ensure that any visual discomfort issues will be avoided for the staff.

55 The development is estimated to achieve a reduction of 687 tonnes per annum (27%) in regulated CO2 emissions compared to a 2013 Building Regulations compliant development. The savings stated do not match the savings calculated from the BRUKL file provided. The applicant should provide reasonable explanation as to why the savings do not match and outline the methodology used to calculate the carbon savings. The BRUKL sheet for the building including efficiency measures alone should also be provided to support any savings claimed.

District heating

56 For the second part of the hierarchy (Be Clean), the applicant has investigated potential connections to a district heating network. The applicant has identified that the Citigen district

page 11 heating network is within the vicinity of the development however a connection is not being proposed. Following the applicant’s investigation, there is chilled water capacity in the central plant of the network however the distribution infrastructure is at full capacity. Moreover, according to the applicant, there is heating capacity in both the central plant and the distribution infrastructure. However, it is stated in the Energy Strategy that E.ON have confirmed that the site is too far away from the central plant for connection to be commercially viable. The applicant is required to provide evidence of correspondence with the network operator (E.ON) and information on the likely cost of connection, the carbon intensity of the network and anticipated timeframes on likely network expansion.

57 In addition, and as discussed in the pre-application meeting, the applicant understands that E.ON is also developing another network to the north of the site and therefore connection to this network should be investigated, as an interim heating solution if the network is to be developed in the near future (i.e. less than 5 years).

58 The applicant has stated that a letter of intent has been signed between the developer and E.ON in respect of the potential future supply of heating and cooling to the building. The generation methods and carbon factors are not yet known for the proposed new network and therefore the Energy Strategy submitted has been based on a standalone solution at this time. The applicant should clarify if the above letter of intent is addressed to the Citigen network or the upcoming network and should provide evidence of the aforementioned letter.

59 The applicant is proposing to install a site heat network. This is proposed to be a common central HVAC plant (located at basement, mid-tower and tower roofs) serving the whole building. The applicant should further investigate how the number of energy centres can be minimised.

60 The applicant has provided a commitment to ensuring that the development is designed to allow future connection to a district heating network should one become available. Based on the Energy Strategy, capped-off connections will be provided in the building HVAC systems for anticipated district systems potentially being brought forward along Bishopsgate in the future.

Combined Heat and Power

61 The applicant has investigated the feasibility of CHP. However, due the intermittent nature of the heat load, CHP is not proposed. This is accepted in this instance.

62 The applicant should provide the space heating and domestic hot water demand figures (MWh annually) for the whole development.

Renewable energy technologies

63 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install high efficiency Photovoltaic (PV) panels which will provide an estimated 81 MWh/annum energy generation.

64 The applicant should provide information on the area (m2) of PV proposed and the kWp output of the proposed array. The applicant should also provide a detailed roof plan demonstrating the roof space utilised for PV installation.

65 A reduction in regulated CO2 emissions of 42 tonnes per annum (2%) will be achieved through this third element of the energy hierarchy.

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Overall Carbon savings

66 Based on the energy assessment submitted at Stage I, a reduction of 729 tonnes of C02 per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected, equivalent to an overall saving of 29%.

67 The on-site carbon dioxide savings fall short of the targets within Policy 5.2 of the London Plan. While it is accepted that there is little further potential for carbon dioxide reductions onsite, in liaison with the borough the developer should ensure the short fall in carbon dioxide reductions, equivalent to 168 tonnes of CO2 per annum, is met off-site.

Climate change adaptation

68 London Plan Policy 5.10 (Urban Greening) seeks a 5% increase in green infrastructure within the CAZ by 2030 in order to support urban greening and the capital’s response to climate change. GLA officers support the proposed planting of 11 new trees within the public realm. The applicant states that a green roof will be provided and this is welcomed. Further details of the size and position of the green roof should be submitted and the provision of the green roof should be conditioned. Subject to this, the proposals are therefore considered satisfactory with regards to London Plan Policy 5.10 and 5.11 (Green roofs).

69 The site is within Flood Zone 1, with no significant surface flood water risk at the site. Therefore the proposals are acceptable in terms of London Plan Policy 5.12. However there are wider surface water flood risks within the local area and it is therefore important that this development fully complies with London Plan Policy 5.13 (Sustainable Drainage), in order to manage and reduce surface water run-off.

70 The Sustainability Statement sets out that the development will use green/blue roof techniques to store rainwater at roof level and will have a rainwater harvesting system. Together these measures will accommodate surface water flows up to the 1 in 100 year event. This approach is considered to meet the requirements of London Plan Policy 5.13, and should be secured via an appropriate planning condition.

Transport

Car and Cycle Parking

71 Car parking is restricted to one blue badge space. The car free nature of the scheme is supported and is in accordance with London plan policy. The blue badge space should be provided with an electric vehicle charging point.

72 The development proposes 875 long stay cycle parking spaces at basement level, accessed via a lift, the location of which should be clarified. This meets London Plan standards and also provides showers, lockers and drying facilities. However, 12% of the total cycle parking is provided as lockers for folding bikes, which is a greater proportion than has been agreed elsewhere in the City and is also greater than surveyed proportions of folding bike use. It is also noted that only seven of the spaces are provided as Sheffield stands. The London Cycle Design Standards recommend that 5% provision of cycle parking for employment uses should be suitable for mobility or larger bikes and as such the amount of Sheffield stands should be increased.

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73 There is also a significant shortfall in short stay publicly accessible cycle parking, with ten spaces proposed on Wilson Street against a minimum London Plan requirement of between 148 and 206 spaces, dependent on the final use of some of the floorspace. Particularly given that short stay cycle parking was not secured for the neighbouring 1 Finsbury Avenue development, this is not acceptable and is likely to lead to significant amounts of informal cycle parking around the site.

74 In addition, the development will generate additional demand for cycle hire. Prior to any consent being granted for these proposals it is requested that discussions take place between TfL, the City and the applicant to determine how this development impact can be mitigated.

Trip generation

75 The trip generation methodology is acceptable and although the development will generate a number of trips across the various public transport modes, no site-specific public transport mitigation will be required beyond the mitigation for cycle hire mentioned earlier in this report and the Crossrail contribution referred to below. However, both the uplift in office space and the proposed conference centre will contribute to increased demand for taxis in the area and needs consideration in the context of wider taxi provision in the Liverpool Street area. In addition, this and other proposed development will increase demand at rail, underground and DLR stations. It is expected that a proportion of the borough CIL receipts from this development will contribute to funding of public transport accessibility or capacity improvements that can be delivered at stations affected in part by the proposed development. Step free access improvements at Liverpool Street station are likely to constitute an appropriate recipient of such CIL funding.

Travel Plan

76 A framework Travel Plan has been submitted with the application and is of a good quality. This Travel Plan should be secured through the Section 106 agreement for the site.

Servicing and Construction

77 Servicing is proposed to take place at basement level, accessed from Wilson Street via two vehicle lifts and managed via a Delivery and Servicing Plan that will need to be secured on any consent. It is noted that larger service vehicles waiting for a lift may obstruct pedestrians on Wilson Street, as the waiting area in front of the lifts is shorter than the lifts themselves. The City of London is also promoting freight consolidation to reduce the number of service vehicles entering the area, and to provide greater control over vehicle type and timings in order to provide better efficiency and security. There may be potential for incorporating consolidation here or within the wider Broadgate Estate.

Strategic transport contributions

78 In accordance with London Plan policy 8.3 the Mayor commenced CIL charging for developments on 1st April 2012. Within the City of London, the charge is £50 per square metre. The site is also in the area where section 106 contributions for Crossrail will be sought in accordance with London Plan Policy 6.5 and the associated Supplementary Planning Guidance (SPG) ‘Use of planning obligations in the funding of Crossrail’ (April 2013). In these situations, the Mayoral CIL will be treated as a credit towards the Section 106 Crossrail liability and this should be reflected in the wording of the Section 106 agreement.

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Local planning authority’s position

79 The City of London Corporation has been involved in pre-application discussions on this scheme and is understood to support the proposal in principle. A date has not been set for the City Corporation to formally consider the application at a planning committee meeting. Legal considerations

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

81 There are no financial considerations at this stage. Conclusion

82 London Plan policies on Central Activities Zone; offices; mix of uses; urban design, strategic views, the historic environment, inclusive access; sustainable development; and, transport are relevant to this application. Whilst the application is broadly supported in strategic planning terms, the application does not fully comply with the London Plan as set out below.

 Central Activities Zone: The proposed development would respond to established demand for office space within the CAZ, in accordance with London Plan polices 2.10 and 4.2.

 Offices: The proposal would provide high quality, flexible office accommodation that would contribute to the diversity of workspace and businesses within the CAZ in accordance with London Plan Policy 4.2. A proportion of flexible, affordable workspace should be secured as part of the s106 agreement.

 Mix of uses: The proposed mix of on-site uses is appropriate within the CAZ. An affordable housing contribution should be made as per the tariff established within the City of London Corporation Planning Obligations SPD.

 Urban design: This is an appropriate location for a tall building, and the proposed building is high in architectural quality. Minor improvements to the ground floor layout should be investigated, and once addressed the application would accord with London Plan policies 7.1, 7.4, 7.3, 7.5, 7.6 and 7.7.

 Strategic views: The development would not adversely affect strategic views and complies with London Plan Policy 7.12.

page 15  Historic environment: The development would not adversely affect the setting of listed buildings or heritage assets and would not cause harm to the historic environment. Accordingly the application complies with London Plan policies 7.8 and 7.10.

 Future development: The applicant should provide further information to demonstrate how the proposed development has taken into account its future neighbours, in particular the consented residential-led development at One Crown Place.

 Inclusive access: The approach to access and inclusion is supported in accordance with London Plan polices 4.12, 7.2 and 7.6. Detailed accessibility information should be secured via condition.

 Sustainable development: The proposed energy strategy and climate change adaptation measures are broadly supported in accordance with London Plan polices 5.2, 5.10, 5.11 and 5.13. However, further information is required with respect to overheating, light transmittance, clarification on the BRUKL calculations, correspondence with EON, space heating and domestic hot water demand figures, PV panel and green roof layout and confirmation that the shortfall in carbon reductions will be met off-site.

 Transport: The proposal is broadly acceptable in strategic transport terms; however, the applicant should address the matters discussed in this report with respect to cycle provision and cycle hire in order to ensure accordance with London Plan polices 6.3, 6.5, 6.9, 6.10, 6.13 and 6.14.

83 The resolution of outstanding issues could lead to the application becoming compliant with the London Plan.

for further information, contact GLA Planning Unit (Development & Projects Team): Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Katherine Wood, Senior Strategic Planner (case officer) 020 7983 5743 email [email protected]

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