Development Control Committee 02 September 2020

A Register No: 19/02677/FUL ​ Address: 16-18 Richmond Road & 2 Canbury Park ​ Road, Kingston Upon Thames,KT2 5EB

Ward: Canbury ​

Description of Proposal: Demolition of the existing buildings and the erection of a ​ part 9, 8 & 5 storey mixed use development fronting Richmond Road providing an A1/A3 use on the ground floor; 15 residential units on the ground and upper floors; erection of a 2-storey replacement building fronting Canbury Park Road to provide ancillary residential facilities at basement, ground and first floors; and provision of associated landscaping; cycle and refuse storage and associated works.

Plan Type: Full Application ​

Expiry Date: 04/09/2020 ​

Executive Summary

1. The application site is 0.027 hectares in size and has 2 frontages, 1 facing Richmond Road and a 2nd facing Canbury Park Road.

2. The site is located within Kingston’s Metropolitan Town Centre.

3. The application site fronts onto both the borough’s Strategic Walking and Cycling Network, and is located in close proximity to Kingston Railway Station.

4. The site has a public transport accessibility level (PTAL) rating of 6a-Excellent (where 6b is ranked as the 'best' level of public transport accessibility).

5. The application seeks Planning Permission for the following:

● Demolition of the existing buildings on the site and its redevelopment for residential purposes with Class A1/A3 use at ground floor ● The provision of 15 residential units comprising: ○ 4 x studio apartments (27%) ○ 6 x 1 bedroom units (40%) ○ 4 x 2 bedroom units (27%) and, ○ 1 x 3 bedroom unit (7 %) ● The provision of 1 Affordable unit - shared ownership. ● Cycle Parking for 22 including 2 cycle15 parking spaces for visitors.

6. The key issues to consider in this case are:

● The delivery of market and affordable dwellings,

● Scale and density of development;

● The impact of the development on the character and appearance of the area;

● The impact of the development on residential amenity of neighbouring properties and the standard of residential amenity for any future occupants of the development; and,

● The impact of the proposed development on heritage assets.

Key Policy Dashboard

Policy Area Standard / Guidance Proposal

Density 215-405 u/ha / 650-1100 551 units/1176 habitable hr/ha habitable rooms per rooms per hectare hectare (Central).

Cycle Parking 20 (adopted LP) 24

Housing mix (3+ 30% 7% bedroom units)

Affordable Housing 50% unless justified by 1 x 1-bed shared viability ownership (FVA submitted and independently assessed)

Site and Surroundings

7. The site is a small L-shaped plot located at the junction of Richmond Road with Canbury Park Road. The L-shaped plot is adjacent to and wraps around the rear of the public house located on the junction of Richmond Road and Canbury Park Road (Whelans), creating two frontages to the site on Richmond Road and Canbury Park Road respectively.

8. The existing building on Richmond Road was last used as a cafe, with accommodation above. 2 Canbury Park Road forms one half of a small shop front pair, forming part of a terrace of two storey properties. It has an A1 use (retail) at ground floor level and C3 use (residential) at first floor.

9. The site shares a boundary with the Whelans Kingston Pub to the north on Richmond Road, which has been recently refurbished, and with Network Rail land to the south. The main railway line to and from Kingston Station runs along this southern boundary with the recently extended platform

approximately 3.5m from the site.

10.The site is not located within a conservation area, and does not include any listed buildings. There are listed buildings in the vicinity of the site, most notably the Former Regal cinema (Gala Bingo Hall), which is Grade II listed and located directly to the north of the site.

11.The site occupies a gateway location to the town centre. It has an excellent public transport accessibility level (PTAL) rating of 6 a (where 6b is ranked as the 'best' level of public transport accessibility).

12.The surrounding area is mixed in character, with some 4 to 7 storey buildings in Richmond Road to the north of the site, a four storey block of flats with commercial uses on the ground floor on the opposite side of Richmond Road, and the substantial Gala Bingo Hall to the north of the junction with Canbury Park Road. There is an extant planning permission of the mixed use redevelopment of the Gala Bingo Hall.

13.The site and the neighbouring public house comprise 2 storey properties with commercial uses on the ground floor and residential premises on the first floor. Further to the east of the application site is the terrace of small two storey houses in Canbury Park Road. The neighbouring building at No.4 comprises a tattoo parlour with residential flat above.

14.The site falls within an area with a low risk of fluvial flooding and EA Flood Zone 1 (low probability). Outside the site, both Richmond Road and Canbury Park Road have a risk of surface water flooding, 1 in 30 and 1 in a 100 respectively, and the area to the south is within EA Flood Zone 2 (medium probability).

15.Kingston is designated as a Metropolitan Centre within the London Plan and Intend to Publish New London Plan. The site is also located within the Kingston Town Centre Action Area policy area.

16.The site is within an Area of Archeological Priority.

17.The site at 16-18 Richmond Road has previously been the subject of planning permission granted at appeal in 2009 for Redevelopment of site to provide six storey building consisting A3 (restaurants & cafes) on ground floor and basement and 9 residential units comprising 6 x 1 bedroom and 3 x 2 bedroom flats (07/12889/FUL). It is advised that the previous owner commenced work in April 2012. Pre-commencement conditions were discharged. Whilst the accompanying planning statement considers that the permission has been lawfully implemented, the applicant has been unable to support this assertion by means of a lawful development certificate, without which, and absent of compelling evidence, it is not accepted that the permission has been implemented. However, some of the matters addressed at the appeal are pertinent to this application.

Aerial View of site edged in yellow

Proposal

18.The application seeks full planning permission for the demolition of the existing buildings on site and redevelopment to provide approximately 56 sqm Class A1(retail)/A3(restaurant) at ground floor level and 15 new residential units comprising ● 4 x studio apartments (27%) ● 6 x 1 bedroom units (40%) ● 4 x 2 bedroom units (27%) and, ● 1 x 3 bedroom unit (7 %).

19.The development comprises two building forms, addressing both Richmond Road and Canbury Park Road. As such the site has two street frontages, with both parts extending back from the street to meet and form an 'L' shape.

20.The proposals includes the following key elements:

A. The erection of a part 9, 8 & 5 storey building, with residential units on the upper floors and an A1/A3 unit on the ground floor;

B. Replacement of 2 Canbury Road with a two-storey entrance building, including a refuse store on the ground floor and a home-working wintergarden space on the first floor. It would provide the main residential access to the development;

C. Creation of a rear landscaped communal courtyard area adjoining the entrance to the residential units to the rear;

D. The application has been revised during consideration. Initially it comprised a part 9 and 6 storey building with the main façade facing Richmond Road and a 2 storey semi-detached building to replace the existing at 2 Canbury Park Road. The revised scheme is part 9, part 8 and part 5 storeys, with the two storey building at 2 Canbury Park Road of the same scale and size as existing. The number of units has been reduced from 16 to 15;

E. A landscaped walkway and mews is proposed to the rear of the site and would provide a communal area for the use of the residential occupants; and,

F. The main façades to the part 9, 8 & 5 storey building would incorporate a brick grid system, articulated to express verticality. A secondary brick would be used to define the openings within the main frame, dividing the square grid to express a rectangular window proportions. The maximum height would be 28.4m.

CGI image of Richmond Road Elevation

G. The access to the residential units would be via 2 Canbury Park Road. The access to the commercial unit would be from Richmond Road;

H. 2 Canbury Park Road would contain the refuse storage area for the residential units, the main entrance and the first floor is proposed to be a home-working 'wintergarden' for the future occupants of the residential units. The building forms half of a pair of semi-detached houses. It would be rebuilt in a height and form to match the adjoining pair, but with a more contemporary detailing;

I. All units would meet / exceed the London Plan Space Standards. It is confirmed that all units have been designed in accordance with M4 (2) of the Building Regulations Approved Document, Accessible and

Adaptable Dwellings, with 10% of units complying with Cat M4 (3), Wheelchair user Dwellings;

J. The development would be car free;

K. A total 24 cycle parking spaces would be provided for the residential units, within a dedicated store at ground floor level;

L. A Financial Viability Appraisal (FVA) has been submitted with the application to determine the maximum level of affordable housing that could reasonably be provided on the site. The FVA indicates that the development when considered against the existing use value and associated development costs cannot support the delivery of affordable housing on-site. The FVA has been verified by an independent viability review; and,

M. Notwithstanding, the applicant has offered to provide:

● 1 x 1- bedroom shared ownership unit (equating to 7% of units).

Previous Relevant History

07/12889/FUL Redevelopment of site to Appeal Allowed provide six storey building 13/05/2009 consisting A3 (restaurants & cafes) on ground floor and basement and 9 residential units comprising 6 x 1 bedroom and 3 x 2 bedroom flats

12/12071/COND Details Required by Partially Discharged Conditions 3 (External 03/10/2012 Finishes), 5 (Levels & Pathway), 6 (Landscaping Scheme), 7 (Architectural Lighting), 10 (Noise Insulation), 12 (Construction Method Statement), 13 (Lifetime Homes), 15 (Vision Screens), 18 (Flood Evacuation Plan) and 19 (Archaeological Work) for Planning Permission 07/12889/FUL

Community Engagement

21. The developer has consulted the local community on the proposed development as part of the pre-application process. A public consultation event was held on 9 July 2019 with invitations sent to local residents, local councillors and community groups, and a website was set up for consultation and updates. It is advised that “consultation feedback has been mixed with approx. 50% of respondents supporting the proposals. Comments focused on scale, massing and design, the architectural character of Kingston, the use of the ground floor unit of 16/18 Richmond Road and the proposed sustainability measures for the site.”.

LOCAL REPRESENTATION AND CONSULTATION RESPONSES

22. A total of 129 neighbouring properties were notified of the planning application. In addition, it was publicised on site, with a site notice displayed in the vicinity of the application site and the details of the application were published in the local press.

23. The number of representations received from neighbours, local groups etc in response to notification and publicity of the application were as follows:

● 10 responses in support; and,

● 61 responses raising objection on the following grounds:

Highway Safety & Parking ● Concerns about parking and existing parking difficulties; ● The CPZ is not 24 hours, and no restrictions on Sunday; ● Canbury Park Road already busy with pedestrian traffic, will exacerbate situation; ● Busy junction is already dangerous, additional flats will make the situation worse; and, ● Disruption to main traffic route - traffic congestion.

Building Design, Excessive height and Character ● Excessive height, not in keeping with buildings on the road and in surrounding area which are nineteenth century two storey buildings; ● Lack of spacing around the building, or setback, unlike other higher buildings in the area; ● Inappropriate design, including height, shape and materials; ● Creation of precedent for high rise buildings in the area; ● Overbearing and out of scale; ● The consented 6 storey scheme is much more in keeping with location compared with the current scheme; and,

● The amendments have not meaningfully addressed concerns about height.

Impact on Residential Amenity ● Overshadowing and loss of sunlight to gardens and windows of residents in Canbury Park Road (Nos 2-46). The 2 hours sunlight on 21 March for at least half the garden is not enough (BRE Guidelines); ● Significant reduction to sunlight in gardens - currently enjoy sunlight in the evening, will be lost as a result of the development; ● Loss of privacy to gardens arising from proposed 9 storey building; ● Increased noise and disturbance; and, ● Overbearing and out of scale.

Quality of Proposed Accommodation ● The site is dark, noisy and overshadowed by the station bridge, not suitable for high level housing; and, ● Building too close to railway station, noise and disturbance for future residents;

Affordable Housing ● Lack of affordable housing.

Overdevelopment ● Shoehorning properties in just to meet spurious targets will kill the character of Kingston and creates problems with transport, local facilities etc.

Noise and Disturbance ● Noise and disturbance arising from completed development, and and during construction; and, ● Adverse impact of disturbance on existing business at 4 Canbury Park Road (tattoo shop/studio).

Inappropriate use ​ ● Lack of space for business and employment.

Impact on Local Services and Infrastructure ● Insufficient infrastructure to accommodate more housing, particularly schools, health surgeries, trains.

Flooding and Drainage ● Area under railway bridge floods regularly, also local houses have been subject of flooding.

Other Issues

● Impact on pub by having neighbouring residents that might seek to restrict its activite; and, ● Structural implications, as sited adjacent railway.

9 Responses expressing Support on the following grounds:

● This is a great location for a small retail/café space; ● The site needs to be revitalised and brought back into use; ● Kingston needs more homes close to public transport links to support sustainable living; ● Building is well designed and is visually attractive; and, ● Kingston needs more help to buy homes.

24. The following stakeholders were consulted:

25. North Kingston Forum (NKF): Objection raised on the following grounds: ​ ​ ● over development and “town cramming”; ● adverse impact on the setting of the Grade II listed foreigner Regal Cinema; ● loss of residential amenity due to overshadowing residential properties close by in Canbury Park Road; ● discrepancy in scale with Whelan’s PH adjacent; ● no setback from the street edge; and, ● The extant permission represents the upper limit of what would be acceptable in this location. NKF objections remain for the revised design.

26. Secure By Design (Metropolitan Police): No objection in principle. Security ​ ​ measures should be reserved by condition.

27. RBK Neighbourhood Traffic Engineer: No objection in principle, see details set ​ ​ ​ out within the main body of report.

28. Transport for London (TfL): The site is on the A307 Richmond Road and ​ ​ Canbury Park Road and is located less than 68 metres from the A308 Wood Street, which forms part of Strategic Road Network (SRN). i. TfL strongly supports car free development at this site given its high level of public transport connectivity and location in Kingston town centre. ii. TfL welcome the proposal of a delivery and servicing arrangement in place which will operate in accordance with the on street loading/unloading restrictions.

29. RBK Borough Environmental Health Officer (Pollution Control): Concerns about ​ ​ impact of noise and air quality on future residents of the development have been addressed through design development, including the use of sealed windows to

north and west elevations, with mechanical ventilation. No objection raised, subject to conditions.

30. Greater London Archaeological Advisory Service (GLAAS): No objection subject ​ ​ to conditions.

31. Network Rail: No response to date. ​ ​

32. RBK Biodiversity Officer: No objection subject to condition. ​ ​

33. Thames Water: to be reported. ​ ​

34. Environment Agency: No objection to the planning application. ​ ​

35. RBK Lead Local Flood Risk Officer: Initial concerns have been addressed. No ​ ​ objection subject to condition requiring finalised detailed drainage design.

Policies

36. The Borough Council as Local Planning Authority has a duty under Section 38 (6) of the Planning and Compulsory Purchase Act 2004 and Section 70(2) of the Town and Country Planning Act 1990 to determine this application in accordance with the Development Plan unless material considerations indicate otherwise. Section 70(2) of the Town and Country Planning Act 1990 (as amended) (1990 Act) requires local planning authorities when determining planning applications to “have regard to (a) the provisions of the development plan, so far as material to the application, (b) any local finance considerations, so far as material to the application, and (c) any other material considerations”. At present in relation to this application the relevant parts of the Development Plan consists of the Royal Borough of Kingston upon Thames LDF Core Strategy 2012 and the London Plan March 2016.

37. The current London Plan 2016 forms part of the Development Plan. The Intend to Publish London Plan 2019 is a material consideration in planning decisions. It gains weight as it moves through the process to adoption and the weight given to the policies is for the decision maker. The Intend to Publish Plan has been through the Examination in Public and the Panel Report has been published. On 13th March 2020, the Secretary of State wrote to the Mayor setting out his consideration of the Mayor’s Intend to Publish London Plan.

38. The NPPF states that policies in Local Plans should not be considered out of date simply because they were adopted prior to publication of the framework. However, the policies in the NPPF are material considerations which planning authorities should take into account. Due weight should be given to relevant policies in existing plans according to their degree of consistency with the NPPF (the closer the policies are to the policies in the Framework, the greater the weight they may be given). The NPPF falls within the other material considerations of the s.38(6) test.

Assessment

Housing Delivery

39. The NPPF directs that housing applications should be considered in the context of the presumption in favour of sustainable development. It further states that planning should deliver a wide choice of high quality homes, widen opportunities for home ownership and create sustainable, inclusive and mixed communities.

40.Policy 3.3 of the London Plan March 2016 states that the Mayor recognises the pressing need for more homes in London in order to promote opportunity and provide a real choice for all Londoners in ways that meet their needs at a price they can afford. Working with relevant partners, the Mayor will seek to ensure the housing need identified in paragraphs 3.16a and 3.16b of the London Plan (49,000 (2015-2036) and 62,000 (2015-2026)) is met, particularly through provision consistent with at least an annual average of 42,000 net additional homes across London which will enhance the environment, improve housing choice and affordability and provide better quality accommodation for Londoners.

41. Table 3.1 (Annual average housing supply monitoring targets 2015 - 2025) of the London Plan 2016 requires the delivery of 6,434 dwellings within the plan period 2015-2025 at rate of 643 dwellings per year within the Royal Borough of Kingston-upon-Thames which is almost double the previous rate of 375 dwellings per year identified in the 2011 London Plan.

42. The Intend to Publish London Plan has set a ten year housing supply target of 9,640 housing completions within the Royal Borough of Kingston-upon-Thames for the period 2019/2020 - 2028/29.

43. Policy CS10 of the Core Strategy 2012 states that the Council will seek to ensure that a broad mix of accommodation options are available to residents and that a range of local housing needs are met. It continues that the Council will expect all new residential developments to positively contribute to the Borough’s existing residential environment and character whilst optimising housing output in line with London Plan density policies.

44. The NPPF directs that local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their housing requirement set out in adopted strategic policies.

45. Paragraph 11d of the NPPF 2019 indicates that where there are no relevant development plan policies or the policies which are most important for determining the application are out of date (out of date includes, for applications involving the provision of housing, situations where the local planning authority cannot demonstrate a five year supply of deliverable housing sites) planning permission should be granted unless:

● the application of policies in the Framework that protect areas or assets of particular importance provides a clear reason for refusing the development proposed1, or

● any adverse impacts of doing so significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole.

46. The Council cannot demonstrate a 5 year supply of housing land as required by the NPPF 2019, the policies which are most important for determining the application are therefore considered out of date and the tests set out in paragraph 11d must be applied (tilted balance). These considerations should be given considerable weight in the assessment of this planning application.

47. Officers consider that the delivery of 15 units, a net addition of 13 dwellings representing 2% of the annual target, of which 1 unit would be affordable, at a time when the Council is unable to demonstrate a 5 year supply of housing, should be given significant weight in the determination of the planning application.

Optimising Housing Potential

48. Paragraph 117 of the Framework directs that planning decisions should promote an effective use of land in meeting the need for homes whilst safeguarding and improving the environment and ensuring, healthy living conditions. Paragraph 123 of the NPPF advises that “Where there is an ​ existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities, and ensure that developments make optimal use of the potential of each site”. ​

49. Policy 3.4 of the London Plan, directs that development, taking into account local context and character and public transport capacity, should seek to optimise housing output.

1 The policies referred to are those in the NPPF (rather than those in development plans) relating to: habitats sites (and those sites listed in paragraph 176) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, a National Park (or within the Broads Authority) or defined as Heritage Coast; irreplaceable habitats; designated heritage assets (and other heritage assets of archaeological interest referred to in footnote 63); and areas at risk of flooding or coastal change.

50. Policy D3 of the Intend to Publish London Plan (Optimising site capacity through the design-led approach) requires that all development must make the best use of land by following a design led approach that optimises the capacity of sites, including site allocations. The design-led approach requires consideration of design options to determine the most appropriate form of development that responds to a site’s context and capacity for growth, and existing and planned supporting infrastructure capacity. A design-led approach to optimising site capacity should be based on an evaluation of the site’s attributes, its surrounding context and its capacity for growth to determine the appropriate form of development for that site. The higher the density of a development, the greater the level of design scrutiny that is required, particularly qualitative aspects of the design, as described in Policies D2, D3 and D4 of the Intend to Publish London Plan.

51. It is noted that the Secretary of State, in considering Policy D3 of the Intend to Publish London Plan has directed that the Mayor provides “...further guidance as to the most suitable locations for higher density development - which could lead to inappropriate development or not maximising the potential of sites capable of delivering high density development. By not maximising the density of a site to reach its potential the Plan risks not delivering the homes and employment space that is needed”.

52. The SoS has instructed the Mayor of London not to publish the new London Plan until he has incorporated the directions set out in his March 2020 letter or provided the SoS with alternative policy wording to address his concerns. With regards to Policy D3 the SoS directs the policy is modified so as to read (although the Mayor can provide alternative wording in the spirit of the suggestion):

“A. The design of the development must optimise site capacity. Optimising site capacity means ensuring that development takes the most appropriate form for the site. Higher density developments should be promoted in areas that are well connected to jobs, services, infrastructure and amenities by public transport, walking and cycling. B Where there are existing clusters of high density buildings, expansion of the clusters should be positively considered by Boroughs. This could also include expanding Opportunity Area boundaries where appropriate. D Gentle densification should be actively encouraged by Boroughs in low- and mid- density locations to achieve a change in densities in the most appropriate way. This should be interpreted in the context of Policy H2.” ​

53. Objections have been raised to this development by local residents etc citing the density of the proposed development.

54. The proposal is for 15 units, with 32 habitable rooms (average 2.1 rooms per unit). To ensure adequate housing delivery the adopted London Plan Policy 3.4 requires that developers ‘optimise housing output’ taking into account local character and public transport capacity. Broad density ranges for different types of location are set-out in London Plan Table 3.2. For a site with central characteristics2 and a Public Transport Accessibility Level of 6 the appropriate density range is 215-405 units per hectare for schemes with 2.7-3.0 habitable rooms per unit, and 650-1100 habitable rooms per hectare. The proposal would equate to 551 dwellings per hectare and 1176 habitable rooms per hectare based on a site area of 272 sqm. This proposal therefore exceeds the number of units and habitable rooms identified in the London Plan density guidelines.

55. The London Plan and the Mayor’s Housing SPG directs that it is not appropriate to apply Table 3.2 [London Plan] mechanistically and states that the density ranges should be considered as a starting point rather than an absolute rule when determining the optimum housing potential of a particular site. The Plan acknowledges that the density ranges for particular types of location are broad, enabling account to be taken of other factors relevant to optimising potential including, local context, design and transport capacity are particularly important.

56. National Planning Practice Guidance seeks to avoid building homes at low densities and to use minimum density standards where appropriate. Going forward, the density matrix framework currently in the London Plan is proposed to be removed from the Intend to Publish London Plan. Instead, Policy GG2 Making the best use of land, directs

“To create successful sustainable mixed-use places that make the best use of land, those involved in planning and development must:

A) enable the development of brownfield land, particularly in Opportunity Areas, on surplus public sector land, and sites within and on the edge of town centres, as well as utilising small sites B) prioritise sites which are well-connected by existing or planned public transport C) proactively explore the potential to intensify the use of land to support additional homes and workspaces, promoting higher density development, particularly in locations that are well-connected to jobs, services, infrastructure and amenities by public transport, walking and cycling D) applying a design-led approach to determine the optimum development capacity of sites”.

2 Central – areas with very dense development, a mix of different uses, large building footprints and typically buildings of four to six storeys, located within 800 metres walking distance of an International, Metropolitan or Major town centre. London Plan 2016 Page 101

57. As noted above, there is a pressing need for additional housing and the London Plan density matrix is not intended to be applied mechanistically, and that account needs to be taken of local context and design. Whilst the density exceeds the ranges within the London Plan, this must be viewed in context, the application site is located within a central part of the Metropolitan Town Centre, within an area with excellent access to public transport and services. As such, it is considered that the housing density proposed on this site would not be inappropriate, and would make best use of land provided the development is in accordance with other local and national planning policies. Therefore, providing the development respects local character and context (as set out in detail below), it is considered that the proposal would optimise housing delivery in accordance with requirements of the Development Plan.

Local Infrastructure

58. Objections have been raised on the grounds that the local infrastructure cannot support the additional housing and density proposed in this location, particularly with respect to schools, and health facilities.

59. Policy D2 of the Intend to Publish London Plan relates to Infrastructure requirements for sustainable densities. It states that

“A The density of development proposals should: ​

1. consider, and be linked to, the provision of future planned levels of infrastructure rather than existing levels

2. be proportionate to the site’s connectivity and accessibility by walking, cycling, and public transport to jobs and services (including both PTAL and access to local services).

B Where there is currently insufficient capacity of existing infrastructure to support proposed densities (including the impact of cumulative development), boroughs should work with applicants and infrastructure providers to ensure that sufficient capacity will exist at the appropriate time”. ​

60. If approved the development would be subject to the Community Infrastructure Levy (the ‘levy’). The levy is a charge which can be levied by local authorities on new development in their area. It is an important tool for local authorities to use to help them deliver the infrastructure needed to support development in their area.

61. The levy can be used to fund a wide range of infrastructure, including transport, flood defences, schools, hospitals, and other health and social care facilities. The levy can be used to fund a very broad range of facilities such as play areas, open spaces, parks and green spaces, cultural and sports facilities, healthcare facilities, academies and free schools, district heating schemes and police stations and other community safety facilities.

62. Local authorities must spend the levy on infrastructure needed to support the development of their area. The levy can be used to increase the capacity of existing infrastructure or to repair failing existing infrastructure, if that is necessary to support development.

63. The development would be liable to pay the Community Infrastructure Levy (CIL) and the levy would fund the infrastructure requirements of the development.

Housing Choice and Mix

64. Policy 3.8 of the London Plan encourages a choice of housing based on local needs, while affordable family housing is stated as a strategic priority. This is supported by the London Plan Housing SPG, which seeks to secure family accommodation within residential schemes.

65. Policy DM13 of the Core Strategy states that the Council will ensure that the housing delivered is of high quality and the most appropriate type. The Policy stipulates that new residential development is expected to incorporate a mix of unit sizes and types. It requires that 30% of the proposed units should provide family accommodation, i.e. 3 or more bedrooms, unless it can be robustly demonstrated that this would be unsuitable or unviable.

66. The proposed mix of units does not meet the split as set out in policy. The development comprises a high percentage of small units (67% either studio or 1-bedroom units) and only 7% with three bedrooms. However, it has been demonstrated through the viability appraisal that it would not be viable to provide a higher number of three bedroom units. As it has been demonstrated through the viability appraisal that the scheme cannot support a higher number of three bedroom units, the proposed mix of units would not be in conflict with Policy DM13.

Mix No. of Units Percentage Type

studio 4 27% studio

1B2P 6 40% Flat

2B3P 2 13% Flat

2B4P 2 13% Flat

3B5P 1 7% duplex

Total: 15 Units

Affordable Housing

67. London Plan Policy 3.9 seeks to promote mixed and balanced communities by tenure and household income and Policy 3.12 seeks to secure the maximum reasonable amount of affordable housing. Policy H5 of the Intend to Publish London Plan and the Mayor’s Affordable Housing and Viability SPG page 5 set a strategic target of 50% affordable housing. Policy H6 of the Intend to Publish London Plan and the Mayor’s Affordable Housing and Viability SPG set out a ‘threshold approach’ whereby schemes meeting or exceeding a specific threshold of affordable housing (35% or 50% on industrial/public land) by habitable room without public subsidy and which meets other criteria are not required to submit viability information to the GLA, nor would the application be subject to a late stage review mechanism.

68. In support of this stance Core Strategy Policy CS10 seeks to maximise the delivery of affordable housing. Furthermore, Policy DM15 requires 50% of the units to be provided as affordable housing and proposals departing from these requirements will be expected to justify any lower provision through the submission of a financial appraisal.

69. A financial viability appraisal has been submitted with the application, this has been assessed by an independent third party consultant who has concluded that the development cannot support the delivery of affordable housing.

70. Notwithstanding, in recognition of the importance and need for affordable housing, the applicant has offered to provide 1 x 1-bedroom 2-person shared ownership unit (unit 2 at first floor level), to be secured by legal agreement. Officers conclude that this carries significant weight in favour of the proposal.

Quality of Accommodation

71. Policy 3.5 of the London Plan requires all new residential development to provide, amongst other things, accommodation which is adequate to meet people's needs. In this regard, minimum gross internal areas (GIA) are required for different types of accommodation, and new residential accommodation should have a layout that provides a functional space. The corresponding policies in the Intend to Publish London Plan are set out in Chapter 3, which states that housing development should be of the highest quality internally, externally and in relation to the wider environment. All the proposed new units would meet or exceed the minimum space standards.

72. All units satisfy or exceed the minimum floor space requirements. The units are of reasonable layout, and in the most part dual aspect. The ground floor studio unit is of single aspect (east) served by a single set of french windows opening onto a private courtyard. The submitted daylight assessment indicates that the studio would receive adequate internal lighting levels, compliant with BRE guidelines.

73. In terms of external amenity space standards, Policy DM13 states that appropriate amenity and play space shall be provided. The Mayor of London’s Housing SPG (Standard 26) recommends a minimum of 5sqm of private outdoor space to be provided for 1-2 person dwellings and an extra 1sqm should be provided for each additional occupant. Policy Guidance 13 of the RBK Residential Design SPD states that 10sqm of private amenity space should be provided per flat plus 1sqm per additional occupant and an additional 50sqm. Each of the proposed residential units would be provided with a balcony/winter garden of 5 sqm or more, and would be in compliance with the Mayor’s minimum standards. The shape and size of the balconies has been amended to provide a more usable rectilinear shape rather than the triangular shape as originally proposed, with a 2m depth. The 3 bedroom unit has a terrace of 20 sqm. The private amenity areas range from 5-20sqm. All amenity areas comply with the London Plan minimum space standards. It is noted that the proposal falls below the private amenity space requirements as set out in the Local Plan, this weighs against the development.

74. The proposal provides a ground floor communal amenity area courtyard (approximate maximum area 25 sqm) with integrated planting and seating to encourage social interaction. Additionally, the proposal incorporates a flexible communal workspace/wintergarden accommodation (22 sqm) at first floor level at no.2 Canbury Park Road, which would be for the use of all residential units. Such communal facilities are considered to provide reasonable communal facilities, with details, including management issues to be secured by condition. Notwithstanding, it is noted that the communal amenity space falls below the communal amenity space requirements as set

out in the Local Plan, this weighs against the development.

CGI Image of First Floor Communal Workspace/Wintergarden and Ground Floor Amenity Space

75. The application is accompanied by a Daylight and Sunlight Report which has assessed daylight and sunlight for future residents using BRE methodology. The report confirms that all habitable rooms meet or exceed the Average Daylight Factor (ADF) criteria, including those rooms served by winter gardens.The report also concludes that all living rooms will receive reasonable levels of sunlight availability taking into account site orientation.

Noise: ​

76. Noise conditions at the site are poor. Major noise sources in the area immediately surrounding the proposed development site include the adjacent main road (A307), the railway line and the Whelan Public House, which hosts live music events.

77. A Noise and Vibration Assessment has been submitted in support of the application. This report includes details of surveys to assess the potential noise and vibration impacts on the proposed dwellings. Based on the noise survey results, calculations have been undertaken to determine the acoustic requirements of the residential façades, so as to achieve acceptable internal noise levels, in accordance with the relevant standards. This assessment concludes that suitably-specified double glazing and trickle ventilators would be expected to provide the appropriate levels of sound reduction.

78. The report has been assessed by Environmental Health Officer, and as a result a further noise survey carried out to calculate the noise levels for the lounge windows (non-openable) which will face the Whelan's public house, the south-facing balconies, south-facing bedrooms and within the workspace and winter garden (thermal double glazing). The proposal has been revised to ensure that all north facing windows of habitable rooms overlooking the public house are to be non-openable and fixed shut, in order to prevent residents of the new development being disturbed by the operations of the existing public house adjacent, and in accordance with the Agent for Change principles to protect the continued operation of the existing public house.

79. The Environmental Health Officer Pollution Control (EHO) has assessed the revised acoustic report and is satisfied with the methodology and the acoustic specification of glazing and ventilation, which would ensure that with windows closed (and north facing windows fixed shut) acceptable internal noise levels would be achieved. It is noted that with windows open there would obviously be an increase in noise, both from railway and road traffic movements. The EHO advises that this will effectively be anonymous noise; the makeup of the acoustic environment in the area and may only be mitigated by closing windows. Station announcements will also form part of the "normal" running of the railway and while the report does not make any specific reference to this, any noise assessment using the typical parameters of long term LAeq measurements will essentially "hide" any noise from this source as noise from rail and road movements will be greater. The Environmental Health Officer notes that whilst this may not necessarily mean that announcements will be inaudible, using the typical assessment parameters to determine planning applications it would be difficult to refuse the application on this basis. The EHO also notes that complaints about station announcements are fairly uncommon, especially given the number of residential properties overlooking stations.

80. Overall the noise and vibration levels for the proposed development are considered acceptable, and the relevant mitigation measures have been designed within the scheme.

Air Quality

81. Paragraph 170 of the NPPF states that: "Planning policies and decisions should contribute to and enhance the natural and local environment by:

e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. "

82. Paragraph 181 of the NPPF states Planning policies and decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and Clean Air Zones, and the cumulative impacts from individual sites in local areas. Opportunities to improve air quality or mitigate impacts should be identified, such as through traffic and travel management, and green infrastructure provision and enhancement.

83. The Intend to Publish London Plan policy sets out measures to design out exposure to poor air quality and noise from both external and internal sources, should be integral to development proposals and be considered early in the design process.

84. The Royal Borough of Kingston has declared the whole borough as an Air Quality Management Area. The declaration was based on the risk of the objectives for nitrogen dioxide and PM10 being exceeded.

85. The applicant has submitted an Air Quality Assessment. This report has been examined by the Environmental Health Officer, who originally raised objection to the proposed development on grounds that residents of the development would experience unacceptably poor air quality due to poor existing environmental conditions at the site.

86. The report indicates that air quality at the proposed development site is expected to exceed the national air quality objective for long-term exposure to nitrogen dioxide up to the fifth floor. At ground and first floor levels, there are likely to be exceedances of the hourly exposure limit for the same pollutant. In order to mitigate the impact of the aforementioned environmental conditions on future occupants of the proposed development, the application proposes that a mechanical ventilation system be installed for flats up to and including the fifth floor, providing cleaner air taken from the roof level. Initially it was proposed that windows facing the A307 main road remain openable, at least above the first floor. The approach was not supported by the Pollution Control Team. Subsequently, it has been agreed that windows and winter gardens facing the A307 up to fifth floor level would be sealed where an exceedance of a National Air Quality Objective was modelled to occur, along with a mechanical ventilation system taking air in from the roof.

87. On the basis of the information provided, the Pollution Control Team have confirmed that they do not raise objection, as the information provided has demonstrated that it is feasible to mitigate the potential impact of local air quality upon future occupants. The precise details of the ventilation strategy would be addressed by condition.

Fire Safety: ​

88. A Fire Statement has been submitted in support of the application, as required by the Intend to Publish London Plan policy D12. The statement, which is prepared by a suitably qualified person, has addressed the requirements of the policy and confirms that the development would be designed to achieve high standards of fire safety.

Wheelchair Housing

89. As required by Policy 3.8 of the London Plan, provision is made for 2 (13.32%) wheelchair-user dwellings. The policy requires ten per cent of new housing to meet Building Regulation requirement M4 (3) ‘wheelchair user dwellings’, i.e. is designed to be wheelchair accessible, or easily adaptable for residents who are wheelchair users.

90. Two 2-bedroom wheelchair accessible units are provided, one on each of the first and second floors. The wheelchair accessible units are designed to be M4(3) compliant and show 1.5m turning circles in each room including the balcony.

91. As required by Policy 3.8, the remaining ninety percent of the new housing would be designed to meet Building Regulation requirement M4 (2) ‘accessible and adaptable dwellings’.

92. The proposed development includes level entry access to a lift serving all flats.

93. These measures would be secured by condition.

Playspace

94. In order to calculate the required provision of playspace for the scheme, the Mayor's play space calculator has been used. The calculator confirms that the development would have a total Playspace requirement of 13.8sqm, which cannot be accommodated on site.

95. The Council’s Planning Obligations SPD states if on-site provision cannot be provided, an equivalent financial contribution will be sought to fund off-site provision of, or improvements to an existing, adjacent or nearby playground. This could include improvements to access arrangements between the site and the playground.

96. As the Council does not have a set figure per sqm for off-site contribution, the applicant has proposed a figure of £200/sqm. (this figure is based on other London Boroughs, such as Camden and Southwark (£151-200/sqm). On this basis they propose a financial contribution of £2,760.00 as mitigation to offset the lack of play space provision. The Elm Road Recreation Ground is in close proximity (less than 300 metres) to the site, and it is considered appropriate to accept this offer to be used towards improvement to the play equipment.

Ground Floor Use

97. There is an existing A3 restaurant/cafe at ground floor on the Richmond Road frontage. The ground floor of 2 Canbury Park Road is vacant and understood to have last been used as a hairdressers. There is no land use policy objection to the replacement A1/A3 on the ground floor of 16-18 Richmond Road, which will help to enliven the street scene by providing interest and activity. The proposal is in accordance with Core Strategy Policies DM17 and DM19 and Kingston Area Action Plan Policies K1 and K2.

Character and Design

98. Paragraph 124 of the NPPF 2019 states that the Government attaches great importance to the design of the built environment. It states that “The creation of high quality buildings and places is fundamental to what the planning and development process should achieve” and “Good design is a key aspect of sustainable development, creates better places in which to live and work and helps make development acceptable to communities”. Paragraph 130 states inter alia that ​ where the design of a development accords with clear expectations in plan policies, design should not be used by the decision-maker as a valid reason to object to development.

99. Policy 3.5 of the London Plan 2016 states that housing developments should be of the highest quality internally, externally and in relation to their context and to the wider environment, taking account of strategic policies to protect and enhance London's residential environment and attractiveness as a place to live. It adds that the design of all new housing developments should enhance the quality of local places, taking into account physical context; local character; density; tenure and land use mix; and relationships with, and provision of, public, communal and open spaces, taking particular account of the needs of children and older people. Policy DM10 of the Core Strategy 2012

states that new development proposals will be required to incorporate principles of good design and those elements that are identified as contributing to the character and local distinctiveness of a street or areas which should be respected, maintained or enhanced.

100. The Intend to Publish London Plan at paragraph 3.3.6 states that “Good design and good planning are intrinsically linked. The form and character of London’s buildings and spaces must be appropriate for their location, fit for purpose, respond to changing needs of Londoners, be inclusive, and make the best use of the city’s finite supply of land. The efficient use of land requires optimisation of density. This means coordinating the layout of the development with the form and scale of the buildings and the location of the different land uses, and facilitating convenient pedestrian connectivity to activities and services”.

Design Review Panel:

101. The applicant undertook a pre-application design stage review with Design South East on 19/06/2019. Their response is summarised below:

102. Design South East expressed support for the principle of intensification of the site. The report states “We are satisfied with the ​ principle of a tall building of this scale on this site and feel that the proposed scale, height and massing as presented are potentially appropriate to its overall urban context. Activation of the ground floor on Richmond Road is positive, making an opportunity to provide commercial amenity where there is heavy footfall in close proximity to the railway station. The replacement of the 2-storey house-form on Canbury Park Road is also deemed suitable.”

103. Their report also notes that the Design Review Panel is “supportive of ​ the proposed height and massing of the development and feel that it is appropriate for its location subject to architectural refinement. The height set to match the neighbouring Kingston Regal development is appropriate; this will help form a distinct marker at this junction of central Kingston. The development will be the most prominent building in the immediate landscape, and as a residential scheme will need to demonstrate exceptional quality. It must have a resolved and distinct character, particularly in key long views towards the site, such as that from Hampton Court towards All Saints Church where this building will form the backdrop”.

104. In terms of outstanding issues at the time, the DRP noted that the “north elevation and the top of the building in particular require resolution”.

105. Since this time the design has been developed to respond to the issues identified, including the introduction of design detailing to the northern elevation.

Pre-Application Discussions

106. The applicant has engaged in Pre-application discussions with Council officers. It is important to note that the proposal has undergone a Design Review Panel and the applicant has submitted a VUCity model, which allows a review of the proposal more comprehensively and an understanding of all of the nuances of the proposed form.

107. A views study report which was produced in August 2019, comprehensively analyzed the proposed massing and outlined a recommendation of amendments which the applicant has taken on board in their final submission to alleviate some of the impacts on the immediate surrounding, namely the neighbouring Whelan’s Kingston pub at 20 Richmond Road, and Canbury Park Road

Development Context and Local Character

108. The site occupies a key location in relation Kingston Town Centre: in close proximity to / neighbouring Kingston Railway Station (1 minute walk). As such, the proposal would be seen and be experienced by a great number of people commuting in and out of Kingston on a daily basis.

109. It is also located in close proximity to Kingston Town Centre, the associated amenity of the town centre and the high street (9 minute walking distance to Market Place).

110. The site is also located in good connection to Central London, with an excellent PTAL rating of 6a (30-60 minutes railway commute to Central London).

111. The site is located in proximity and in view of a number of Grade II Listed Buildings and in some proximity to areas of special character as listed below:

Heritage Assets in Site Vicinity

112. Across the street to the North is the Grade II Listed Former Regal Cinema, also known as the ‘Gala Bingo’, an Art Deco brown brick building with red undertones, and light plaster and faience decoration concentrated around the entrance and cornice. Planning permission has been granted for a roof extension (and the building has been scaffolded ever since).

Online image before scaffolding and without consented roof extension:

113. To the East, there are two Grade II Listed buildings: the Former Sopwith Aviation Company Factory, and the Former Hawker Aircraft Experimental Shop, also known as Siddeley House. Both of these buildings have a historic link tracing back to the aviation production in

Kingston at the time of World War I, and they are both in similar coloured brick as the Gala Bingo down the street.

114. Siddeley House, the prouder of the two, is a three storey tall building, formed of a steel frame, brick clad with a flat roof. Its corner towers are set forward in red brick flanking the central entrance lined with engineering brick. Its windows are metal framed and small paned.

115. The other Grade II Listed Buildings in some proximity to the site are the Bentalls Depository, and Former Granada Cinema located to the south beyond Quebec House.

116. The Former Granada Cinema is very similar in its Art Deco style and to some extent materiality to Gala Bingo and Siddeley House. Bentalls Depository on the other hand is very different to the other three Grade II Listed Buildings, mainly due to its materiality and colour variation (predominantly white with green accents, whilst the others are brown /

red and white accents) but also because of its Grand Spanish/Italianate style facing the railway line.

117. It is important to note that these existing Grade II Listed Buildings already sit in something that can be described as a fairly eclectic context, a patchwork of various different historic styles, materiality and colour. It is also important to delineate that the first three buildings (Gala Bingo and the former aviation-related buildings) are sitting in a context much closer to the site, whilst Bentalls Depository forms a wider background context.

118. The site also sits in proximity to two areas of special character, Castle Street and Old London Road, but is not considered to be discernible from or affecting their setting.

119. More directly, the site is neighboured by two storey Victorian buildings. Immediately adjoining is Whelan’s Kingston PH, which forms a ‘book-end’ and turning the corner to the low-level two storey terraced houses along Canbury Park Road.

120. It is important to appreciate that although neighbouring the low-level housing along Canbury Park Road, the site is also surrounded by a medium-rise context,

● Regents Court across Richmond Road from the site (a G+3 and a pitched roof) ● Quebec House south across the railway from the site (a G+5 building)

121. The site is located in an area which transitions from low-level context towards North-East (in blue: highlighting indicatively buildings about 2 storeys tall), via low-medium-rise context (in orange: highlighting buildings between about 2 and 3 storeys) towards Kingston Town Centre high-medium-rise context (in red: buildings above 3 storeys tall) on South-West

122. As outlined in the Intend to Publish London Plan: “Change is a ​ fundamental characteristic of London, respecting character and accommodating change should not be seen as mutually exclusive. Understanding the character of a place should not seek to preserve things in a static way but should ensure an appropriate balance is struck between existing and any proposed change. Opportunities for change and transformation, through new building forms and typologies, should be informed by an understanding of a place’s distinctive character, recognising that not all elements of a place are special and valued” (page 112 of Intend to Publish version). ​

Development Concept & Site Layout

123. As referred to above, the site’s complexity can be described as the cumulative effect from its constrained footprint, its surrounding low-to-medium rise context and its immediate proximity to the railway station.

124. It is noted that the applicant attempted to acquire Whelan’s Kingston PH so as to incorporate it within their development site, but due to the pub’s recent refurbishment, the owner(s) were not willing to enter negotiations (this is the applicant’s submission).

125. The site includes 2 Canbury Park Road, a two storey low-level design fitting with Canbury Park Road context. This provides a separate residential entrance for the wider development, whilst allowing 16-18 Richmond Road to face the street via a commercial unit at ground floor, which is considered an appropriate approach to the site's orientation, the ground floor public realm and the development’s

presence on the street. Furthermore, placing the entrance along Canbury Park Road aids with avoiding overcrowding at the limited pavement line along Richmond Road.

126. The way the waste management and cycle storage facilities have been integrated within the proposed ground floor plan is considered appropriate.

Ground Floor Layout Plan

127. The development is furthermore seen positive for providing an optimal floor plan layout which takes best advantage of the southern-facing elevation by orienting its living rooms and balconies to face south, and, incorporating a communal workspace at the first floor of 2 Canbury Park Road, thus to some extent activating that frontage and providing some natural surveillance and visual interest along the street.

First Floor Layout Plan

128. As the development rises, it respectfully steps back away from the boundary line interfacing with the neighbouring rear gardens towards Canbury Park Road - this is considered to be a reasonable and sympathetic strategy, responding to the neighbouring east-side low-lying context.

Plan highlighting line of facade at fifth floor:

Height, Massing & Scale

129. Policy D9 of the Intend to Publish London Plan relates to tall buildings. It states that development proposals should address visual, functional and environmental impacts. The supporting text notes at para.3.3.3 states that “Tall buildings are generally those that are substantially ​ taller than their surroundings and cause a significant change to the skyline. Boroughs should define what is a ‘tall building’ for specific localities. In large areas of extensive change, such as Opportunity Areas, the threshold for what constitutes a tall building should relate to the evolving (not just the existing) context. This policy applies to tall buildings as defined by the borough. Where there is no local definition, the policy applies to buildings over 25m in height in the Thames Policy Area (a special policy area to be defined by boroughs in which detailed appraisals of the riverside will be required), and over 30m in height elsewhere in London” . ​

130. At this stage, the borough has not set its own definition of tall buildings.

131. The proposed development would be 9 storeys, with a maximum height of 28.4m on the Richmond Road frontage (below the 30m height identified in the draft London Plan). The 9 storey element has a relatively small footprint of 60sqm (GIA), with a stepped massing between 5-8 storeys.

132. It is recognised that the applicant has sought to ensure that the proposal sits comfortably as viewed from different locations, at different distances, and in relation to different surrounding buildings and in context. It is important to note that due to the eclectic character of the surrounding context, mediating comprehensively with all surrounding context has been a challenge which the proposed massing is considered to have responded to satisfactorily.

133. From an urban design / townscape point of view the proposal is considered to mediate in a satisfactory way between the immediate low-level context of Canbury Park Road and the medium-rise context of the Gala Bingo, Quebec House and Regents Court. Stepping down at rear towards the East and providing a consistent high-rise front at Richmond Road are considered to be appropriate to the site's potential and constraints. The development manages to successfully accommodate the greater height on the site by fitting into its context in a reasonable way.

Proposed elevation facing (west) Richmond Road

Proposed elevation facing south towards railway line (dashed red line shows previous iteration and blue line shows outline of consent granted at appeal 07/ 12889/FUL)

134. Long, mid and short range views have been submitted with the application. It is important to highlight that the proposed architectural form has been designed in a way that takes best advantage of its context as seen from various angles, distances and locations. Due to its sculptural articulation it becomes much more elegant at 45 degree viewing angles along the East-West axis where its elevation is narrowest. The proposed massing is considered an appropriate response in relation to the site’s footprint, location and the way it is observed from the surrounding context which allows views predominantly from the station square, arriving at junction of Richmond Road and Canbury Park Road, as seen from along Canbury Park Road and as seen far from the bus terminal at south-east.

135. There is limited visibility as seen from true north due to Canbury Park Road’s width of street and the Gala Bingo which conceals the proposed beyond the junction with Richmond Road. As well as from

the south due to the proximity to the obscuring railway line and Quebec House.

136. The images below showcase how different the predominant 45 degree viewing angles are in comparison to the less elegant limited glimpses of the more straight-on viewing positions:

137. It is appreciated that the proposal changes the existing relationship with Whelan’s Kingston pub, but it is considered that it contributes positively to the variety and rhythm of pedestrian experience along Richmond Road whilst also enunciating an entry point into the more urban Kingston Town Centre. The relative height dichotomy between Whelan’s Kingston pub and the proposed development is seen to be synergetic and is considered to be an interesting and mutually beneficial balance between old and new, not uncharacteristic for wider London.

138. The proposed massing is seen to be positively contributing to the skyline when arriving at the station via Fife Road: creating a more varied skyline ‘in conversation’ with Quebec House and the Railway Station “tower”.

139. It is considered that the public space is currently visually ‘leaking’ at north, further emphasised by the horizontal dynamic form and articulation of Quebec House which can be read to suggest movement towards north rather than lingering and dwelling in the public space fronting the station. It is considered that the proposed contributes to mending that perception by infilling the void, thus also providing a better enclosure for the public square in an exciting, invigorating, sculptural yet complementary way.

140. It is also noted that the previous appeal scheme (07/128898/FUL), which was considered at public inquiry in May 2009, which considered height and massing of a six storey building on the smaller site at 16-18 Richmond Road and concluded in respect of height and mass:

“6. Given the nature of the buildings lining Richmond Road, I find that the existing structure on the appeal site fits in well enough. On the other hand, I see no reason in principle why a 6 storey building could not provide an equally valid counterpoint for the other taller buildings. I accept that the proposals would not follow the older historic examples. However, the site is not within a conservation area and the taller buildings are now as much a part of the context as the older terraces. Much was made at the Inquiry of the site in relation to the northern gateway to the town. From my visits I found no definitive entry point but saw that the new apartments, the former cinema, the bridge and the Rotunda all build on each other to announce the town centre.It follows that the height of the proposed building would sit comfortably within this gateway even though it would not be essential to it.

7.... The north wall would rise vertically against the pub. However, while abrupt and unusual, in the context of the other tall buildings and the higher railway bridge, I consider that this wall would appear as an interesting rather than uncomfortable juxtaposition, I also note that the proposals were supported by the Council's Design Review Panel”.

Image of Appeal Scheme 07/128898/FUL: Richmond Road Frontage

141. Clearly the appeal observations relate to a lower building compared with the current application. However, the appeal scheme was still of considerable scale and bulk, and rose significantly above the height of the existing two storey building, and with a vertical junction to the neighbouring public house.

142. Whilst strong local objection has been raised to the height and massing of the proposed development, overall it is concluded that although tall and in a prominent location, the proposal would respond positively to this part of the town centre and would not adversely affect the character and appearance of the area.

Architecture, Detailing and Materiality

143. The proposal successfully picks up on the red-brick aesthetic, characteristic for Kingston Town Centre, but also the immediate surrounding formed by the abovementioned Grade II Listed Buildings (refer to ‘Development Context and Local Character’ subsection above). Red brick is also visually evident along Canbury Park Road and on the other side of the bridge as seen alongside the railway station - thus creating a dialogue with the other medium-rise buildings / vertical protrusions in the vicinity.

144. A secondary brick would be used to define the openings within the main frame, dividing the square grid to express a rectangular/ portrait window proportion.

CGI Canbury Park Road

145. It is considered that the proposed development successfully incorporates the following elements into the detailed design:

● breaking up the form into smaller masses is seen as positive and successful in integrating the proposed design into its surroundings; ● high-level slanting of facade at rear / east is seen to be positive; ● introducing a shadow-gap recess via expressing the core is seen positive; ● articulation of the north-facing facade has been an important and long-discussed point in the pre-application process, and has been further refined during the application. It is seen positive that a change in materiality has been introduced to break-down the massing visually in a subtle way, and the inclusion of additional features by introducing opaque glass panels and metal panels to match frames (to give the appearance of window openings) would add interest and enliven this facade whilst not compromising the future potential development / intensification of the Whelan’s Kingston pub site ● as mentioned above, the relationship with the pub is seen as a synergetic dichotomy between old and new; the proposed horizontal ‘frame’ banding aids greatly in creating a relationship

with the pub (banding almost matching the pub’s top of first floor and top of roof) ● use of brick and punctured windows is not expected to cause adverse reflected glare, and minimises outbreak of light pollution from internal lighting.

146. It would be important that the quality of architecture is not lost throughout the detailed design and construction of the development, and this would be ensured by detailed conditions.

Conclusions on Character and Appearance

147. 16-18 Richmond Road & 2 Canbury Park Road is a high-rise mixed use development, situated in one of the most well-connected locations in Kingston, in close proximity and with good access to Kingston Town Centre but also Central London (railway to Waterloo).

148. The site is located in an area of transition from low to medium rise, which when taken into account with the anticipated upcoming intensification in relation to its proximity to Kingston Railway Station and its footprint, outlines a complex set of objectives to inform its potential optimisation.

149. In spite of the existing low-lying context and constraints related to the site footprint, the site is considered to have a clear rationale to aspire for a higher density regeneration. The proposed scheme, although bold and prominent when it comes to its height, massing and presence along Richmond Road and Canbury Park Road, is considered to be a reasonable, well-articulated and positive addition to the wider Kingston townscape.

150. It is considered that the proposal would:

● fit in a considerate way with the surrounding heritage assets ● is considered to appropriately addressed the transition towards the currently low-lying context to its East, along Canbury Park Road, as well as to its North, at the neighbouring Whelan’s Kingston PH, whilst also not ‘closing any doors’ on any future potential intensification and development of the adjacent properties and the wider area around the railway station ● is considered to positively contribute to providing natural surveillance at ground floor and creating visual interest and activity along both Richmond Road and Canbury Park Road ● is considered to contribute positively to Kingston’s townscape and the locally experienced skyline by introducing variety, play and visual interest via a well-articulated and well-considered broken-down ‘sculptural’ form, subtle in its materiality (utilising a

complementary-coloured set of bricks fitting with its context) and architectural articulation. ● An articulation which attempts to negotiate between traditional and contemporary architecture by balancing visual order and sensory richness, as well as balancing the architectural boldness of the overall form via a subtle, playful and attentive fine-grain rhythm of detailing, fenestration and ornamentation.

151. For the reasons set out above, it is considered that the proposed development would relate appropriately to the character and appearance of the street and neighbouring properties and would be a high quality development of acceptable appearance such that it would not cause harm to the character or appearance of the surrounding area. The proposal would therefore accord with Core Strategy Policies CS8 and DM10 of the Council’s LDF Core Strategy, 2012.

Heritage

152. Section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 states “In considering whether to grant planning permission ​ for development which affects a listed building or its setting, the local planning authority or, as the case may be, the Secretary of State shall 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”.

153. Paragraph 193 of the Framework states that when considering the impact of a proposed development on the significance of a designated heritage asset great weight should be given to the asset's conservation. Paragraph 196 states that where a development proposal would lead to less than substantial harm to the significance of a designated heritage asset, the harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimal viable use.

154. As set out above, the site is within proximity to a number of listed buildings in the locality. A Heritage Assessment has been submitted to accompany this application.

155. It is agreed that in terms of townscape, there is an appreciable contemporary character to the area surrounding the application site - established by virtue of the flatted development to the north-west (former power station site), as well as the student accommodation scheme adjacent to the railway station/line to the south and the Rotunda mixed-use development. This development has introduced a noticeably more open grain than the former prevailing fine grain of historic development and the architectural identity is varied in heights, massing and grain.

156. The site's immediate setting is somewhat dominated by the massing of the railway station, railway line and associated infrastructure, to the south/south-west of the site. The piecemeal evolution of the area is evident with two-storey residential terraced housing, warehouses and industrial structures in the vicinity of the site, in conjunction with more recent intensive residential, office and mixed use development.

157. The existing buildings appear to possess relatively low architectural merit, with a plain architectural style utilising stock brick and other typically unexceptional materials. It is clear that some alterations, additions and repair works have occurred over the years. The pointing, in particular, appears to be modern and not particularly appropriate/sensitive repair work to the buildings.

158. In terms of the site's evidential value - it is agreed that as the site comprises buildings dating from the late 19th century, with a construction and materiality which is relatively unremarkable, the resultant overall evidential value is low.

159. The aesthetic value of the site's surroundings is varied in terms of architectural and townscape merit, but is relatively diminished in terms of its historic character and associations of a medieval town centre. The presence of the railway line and station infrastructure creates an imposing / clear physical division to the medieval core and finer grain of the historic town centre; the section north of the railway line is less sensitive in terms of townscape.

160. The former Sopwith Aviation Company Factory (Grade-II) and the former Hawker Aircraft Experimental Shop (Grade-II) are not particularly visible from the application site, due to the oblique angle in the road axis. The Bentall's Depository is Grade-II listed but given the distance from the site and the intervening buildings/structures, topography and heights of the buildings there is no connecting aesthetic value/link - and together with the absence of an historical or functional relationship, it is not considered that any redevelopment of the site would impact upon the setting of this asset. The impact on these heritage assets is neutral.

161. The former Regal Cinema possesses landmark value. This is derived from its imposing height and complete occupation of the block at the junction. The Heritage Assessment considers the impact of the proposed development to have a neutral impact. The spatial relationship and 'experience' of the Cinema site at street level is considered to not materially alter from that as viewed as existing. However, given the significance of the former regal Cinema is primarily concerning it’s interior and it has planning permission for substantial roof extensions, it is agreed the impact is neutral.

162. It is considered that the setting of the Castle Street area of special character would not be impacted.

163. It is concluded that the proposal would not result in harm to designated heritage assets or non-designated heritage assets.

Archaeology

164. The site is within an Area of Archaeological Significance (Kingston Town Centre). An Archaeological Desk-Based Assessment has been submitted as part of this planning application.

165. The assessment has been reviewed by the Greater London Archaeological Advisory Service (GLAAS) who advise that Boreholes excavated on the site in 2012 were archaeologically monitored and show that alluvial deposits including peat are present, demonstrating the presence of a former water course and the clear palaeoenvironmental potential of the site. Several such watercourses flowed through Kingston, and have been associated with potential timber platforms and Bronze Age pottery. The site is located away from the Saxon and later medieval core of Kingston, but is close to sites where Roman and prehistoric finds have been recorded.

166. Part of the site has not previously been developed, and the 19th century buildings are not thought to have deep foundations, therefore palaeoenvironmental deposits may exist beneath the existing buildings as well as in open areas.

167. The GLAAS advise that the development could cause harm to archaeological remains and field evaluation is needed to determine appropriate mitigation. Although the NPPF envisages evaluation being undertaken prior to determination, in this case considering the nature of the development, the GLAAS advise that the archaeological interest and/or practical constraints are such that It is considered that a two-stage archaeological condition could provide an acceptable safeguard. This would comprise firstly, evaluation to clarify the nature and extent of surviving remains, followed, if necessary, by a full investigation.

Impact On Residential Amenity

168. Paragraph 127(f) of the NPPF, 2019 and Policy 7.6 of the London Plan, 2016 (consolidated with changes since 2011) seek to ensure that development secures a good standard of amenity for all existing and future occupants of land and buildings.

169. More specifically, Policy DM10 of the LDF Core Strategy, 2012 seeks to safeguard residential amenity with regards to privacy, outlook, sunlight/daylight, and avoidance of visual intrusion.

170. Policy Guidance 16 of the Residential Design SPD advises that for all new residential development the priority should be to provide and protect acceptable levels of amenity for both existing and future residents. On smaller sites the prevailing character of the area may dictate what separation distances will be, but in general a minimum separation distance of no less than 21 metres shall normally be maintained between facing windows of habitable rooms and a separation distance of 7.5 metres shall be maintained between new habitable room windows and the boundary to neighbouring properties or 15 metres between new habitable room windows and the flank wall of a neighbouring property. Where the site topology, landscape features or adequate screening is in place it may be appropriate to relax these distances.

Daylight and Sunlight

171. A detailed Daylight and Sunlight Report, has been submitted to support this proposal, using BRE methodology and guidelines. The BRE Guide notes that if the Vertical Sky Component (VSC) within existing rooms with the development in place, is “both less than 27% and less than 0.8 times (20%) its former value, occupants of the existing building will notice the reduction in the amount of skylight. The area lit by the window is likely to appear more gloomy, and electric lighting will be needed more of the time.” The “no sky line”, is an appropriate tool where room layouts are known and provides an assessment on the impact on the daylighting distribution.

172. The most directly affected properties are the properties in the neighbouring terrace of houses in Canbury Park Road, particularly Nos. 4, 6 and 8. No 4 is a mixed use property, comprising a tattoo parlour at ground floor with large rear extension occupying much of the garden area, with residential flat above. No 6 and 8 are two storey houses located north-east/east of the development site. The terraces houses along Canbury Park Road back onto small gardens alongside the steep railway embankment.The BRE report has assessed the impact on lighting levels to windows and found that whilst there would be some loss of light this would be within the guidelines set out within the BRE methodology. The reduction in VSC is most noticeable within 6 Canbury Park Road, the report notes that a rear living room window would be most impacted, with the VSC reducing from 15.96 to 12.89 representing an 0.81 times the former value. The room is also served by windows on the front elevation. The daylight distribution test indicates that the room would continue to receive good levels of daylight with daylight distribution reductions of 7%, thus meeting the BRE Guide target criteria of not greater than a 20% reduction. It is

noted that the small galley kitchen (approximately 10.3m2), has not been assessed as the report states that given the size of the room it is not considered a “habitable” room. There is no local policy guidance relating to this issue. It is noted that the Mayor's Housing SPG on Housing at paragraph 1.3.19 states that “in some circumstances, a ​ large kitchen or kitchen dining room may be counted as a habitable room, but the approach varies between boroughs. There is no statutory definition for kitchens to be counted as a habitable room, nor is there any statutory size threshold... Generally, a kitchen with a small table and chairs in one corner, or a kitchen ‘bar’, would not be counted as a habitable room. A room with a clearly defined kitchen at one end and a clearly defined dining area at the other (with a dining table and chairs) would be counted as a habitable room. Whilst it is recognised that the small kitchen room would experience some loss of light, given the degree of separation from the building it is considered to receive adequate lighting levels for a room of this nature and it is accepted that it would not be appropriate to apply the BRE methodology to this non habitable room. The report has also assessed the impact of the development on Quebec House (south of the railway, Regents Court, Sopwith Way and the consented scheme at 22-30 Richmond Road (former regal Cinema) which sees reduction of VSC within the BRE target criteria. In terms of the adjoining PH, the first floor is storage and office areas above the pub. There is no staff accommodation or residential use on site.

173. Objection has also been raised on the grounds of loss of sunlight and overshadowing of gardens in Canbury Park Road. The BRE Guide states for a garden (amenity space) of an existing property, it is recommended that for it 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 21st March. If as a result of a new development an existing garden or amenity area does not meet the above, and the area which can receive two hours of sun on 21st March is less than 0.8 times its former value, then the loss of sunlight is likely to be noticeable.

174. The submitted Daylight and Sunlight assessment demonstrates that in respect of loss of sunlight on the ground, all neighbouring gardens in Canbury Park Road would be compliant with BRE Guidelines, which requires that at least half the amenity area should receive at least two hours of sunlight on 21 March. The closest affected property at No.4 would experience a loss of sunlight to the garden of 0.94 times compared with its former value, therefore satisfying BRE guidelines. The study confirms that all gardens would continue to meet the BRE target. Notwithstanding, as the proposed development is located to the west of the gardens, it is recognised that the proposal would result in increased shadowing of the gardens particularly in the afternoons.

Outlook and Privacy

175. The proposal has been amended during the application process to reduce the bulk and height as it addresses Canbury Park Road. It would step up in height towards the Richmond Road frontage - 5 storeys, 8 storeys and 9 storeys. The five storey element is closest to Canbury Park Road (3 metre separation to boundary with No.4 and 8 metre separation to the boundary with No 6 (10 metres to flank elevation).

176. The applicant has also made changes to address concerns of privacy intrusion towards rear gardens of properties along Canbury Park Road. The elevation facing those gardens has been reduced in height; and the east-facing elevation is relatively narrow and is almost fully either blank (with no windows) or is blanked out via privacy screens. The 1st - 4th floors layouts of the units at the east of the site were amended during the course of the application so that balconies on the east elevation are orientated to the south. An opaque glazed screen is proposed in the opening on the east elevation to allow more light to enter the balcony, but avoid overlooking. Also obscured glazing is proposed on the east facing windows of the studios at 5th- 7th floor, also to avoid overlooking from upper floors.

177. It is noted that the existing rear studio to the tattoo parlour at No.4 is built up to the boundaries. The upper floor bedroom of No 4 has windows facing the railway. No.6 has rear bedrooms on the first floor and a kitchen on the ground floor with windows on the flank elevation, but is further from the development and so the outlook from these windows is less directly towards the application site, but more towards the railway embankment. The outlook from gardens in Canbury Park Road would be affected by the proposed development, but it is considered that it would not cause an unacceptable sense of enclosure.

178. The rear elevation has been modelled to step away from these properties and has limited window openings. Overall, given the degree of separation, and this central town centre location, it is not considered that this impact would be to an unacceptable degree.

Conclusions on amenity

179. Officers recognise that there would be some loss of light and a greater degree of overshadowing to neighbouring properties, particularly to No.6 Canbury Park Road, but the loss remains within the BRE guidelines. It should also be noted that paragraph 123 of the NPPF, 2019, advises that “when considering applications for housing, authorities should take a flexible approach in applying policies or guidance relating to daylight and sunlight, where they would otherwise inhibit making efficient use of a site (as long as the resulting scheme would provide acceptable living standards). There will be some loss of

daylight and sunlight, and overshadowing of gardens, but it is within the acceptable range and compliant with the recommendations set within BRE Guidelines. Privacy concerns have been addressed through design measures.

180. Objection has been raised by many residents of Canbury Park Road and it is acknowledged that there will be some effect on these neighbouring residents, but for the reasons outlined above it is not considered that the living conditions of neighbours would be unduly harmed and it is not considered that these concerns would be so significant as to justify refusal of permission.

181. As such, the proposal is considered to comply with Paragraphs 127 and 182 of the NPPF, 2019, Policy 7.6 of the London Plan, 2016 and Policy DM10 of the LDF Core Strategy, 2012 as they will not have a significant adverse impact upon residential amenity.

Noise and Disturbance

182. Objections have been raised concerning noise from the proposed building works, impacting on the operation of the neighbouring business. This is not an issue that could substantiate grounds for refusing planning permission. It would be appropriate to control hours of building works by condition.

183. Issues have been raised regarding the potential noise and disturbance generated by the proposed development. It is acknowledged that the proposal would result in greater levels of activity and noise associated with the intensified use of the site for residential purposes. However, the proposal lies in a residential area where similar activities occur and is in a town centre location where a degree of noise and disturbance would be anticipated as normal.

Highways and Parking

184. National planning policy directs that in considering developments that generate significant amounts of movements, local planning authorities should take account of whether safe and suitable access to the site can be achieved for all people; and improvements can be undertaken within the transport network that cost effectively limits the significant impacts of the development. It continues by stating that development should only be prevented or refused on highway grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network are severe.

185. London Plan Policy 6.13 (Parking) states that the Mayor wishes to see an appropriate balance being struck between promoting new development and preventing excessive car parking provision that can undermine cycling, walking and public transport use.

186. Core Strategy Policies CS5, CS6, DM8 and DM9 are used to assess the potential impact of new development upon the surrounding highway network. The policies aim to reduce the need to travel by locating major trip generating development in accessible locations well served by public transport.

187. Policy DM10 states that development proposals should have regard to local traffic conditions and highway safety and ensure that they are not adversely affected. Policy DM9 states that new development should not contribute to congestion or compromise highway safety. Policy CS7 states that car use should be managed to ensure sustainability, road safety and reduce congestion, including car club schemes and the provision of electric vehicle charging points and managing on and off-street parking provision to promote sustainability and residential amenity.

188. A Transport Statement (TS) and Travel Plan Statement (TPS) have been submitted in support of the application.

189. The PTAL calculation indicates a rating of 6a at the site, demonstrating that the level of public transport accessibility is excellent. This is mainly due to the location of bus and train services. A nearby (70m) bus stop is located on Richmond Road, and the Cromwell Bus Station is located approximately 200m south of the site. Kingston Railway Station is situated 100m from the site and within 2-minutes walking distance. The station is served by South Western Railway, with direct services to London Waterloo, Wimbledon, Clapham and Twickenham.

190. The TPS notes there are 3 Car Club spaces located in proximity to the site on Down Hall Road to the west, and Elm Road and Queen Elizabeth Road both located to the east of the development site.

191. Parking: Given the location of the site and its high PTAL 6a rating, the ​ proposed development would be car-free and there would be no provision for on-site car parking. Residents of the development and their visitors would be excluded from the Council’s parking permit scheme, which would be secured by legal agreement.

192. To mitigate the parking restrictions for the site, it is proposed that each new resident will be entitled to 3 years car club membership for the first 3 years of occupation. This would also be secured by way of a legal agreement.

193. Cycle Parking: The Adopted London Plan minimum cycle parking ​ standards are: 1 space per studio and 1 bedroom unit, and 2 spaces per all other dwellings. The Intend to Publish London Plan minimum cycle parking standards are modified by introducing a standard of 1.5 spaces per 2 person 1 bedroom dwelling, and short stay parking for visitors: 5 to 40 dwellings: 2 spaces and thereafter: 1 space per 40 dwellings.

194. In respect of cycle parking numbers, it is proposed that a total of 22 secure, long stay spaces would be provided for residents and 2 short stay spaces would be provided for visitors.

195. The layout of cycle parking provision is considered to be acceptable in that it is conveniently and safely located, and accessible.

196. Traffic Impact: In terms of estimated trip generation, with a car free ​ ​ development, more than 90% of trips will be made by sustainable modes of transport and will not have any material impact on the operation of the transport network.

197. The trips to the A3 Café use are likely to predominantly pass by trips and would not result in any material impact to the transport network.

198. Delivery Servicing Plan (DSP): In accordance with the SPD on ​ Sustainable Transport, applicants are required to submit a Delivery Servicing Plan where the development involves significant or disruptive servicing activities. The site is located in the Town Centre on a major traffic route, and as such a DSP will be secured by condition.

199. It is stated that delivery and servicing for the A3/A1 use would be carried from the loading bay on Canbury Park Road. The existing loading bay is available for all loading purposes for 20 minutes.,

200. Highway Dedication: Part of the new building is set behind the ​ advertising hoarding on the existing site boundary line on the Richmond Road frontage. The Neighbourhood Traffic Engineer has advised that it would be preferable to remove the hoarding and widen the footway, at least to the end of the building and, preferably to the railway bridge. The applicant has clarified that the advertising hoarding falls on land outside of the applicant's ownership / control and therefore widening of the footway or the relocation of the hoarding would not be possible as part of this application.

201. In conclusion, the provision of a car club, for which free membership would be secured for new residents for a minimum 3- year period, together with a S106 agreement to preclude residents from obtaining a resident parking permit, is considered sufficient mitigation to support the car free development proposed in this location. Appropriate cycle parking is provided, and measures including detailed servicing plan and construction logistics plan would be secured by condition.

Environment and Sustainability

202. Paragraph 148 of the NPPF 2019 states that the planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.

203. Policy 5.1 of the London Plan 2016 states that there is an aim to achieve an overall reduction in London’s carbon dioxide emissions of 60 percent (below 1990 levels) by 2025. Policy 5.2(A) states that development proposals should make the fullest contribution to minimising carbon dioxide emissions in accordance with the London Plan energy hierarchy, and this should be demonstrated in an accompanying energy assessment. Where it can be demonstrated that the specific targets cannot be met fully on site, any shortfall may be provided off-site or through a cash in lieu contribution to the relevant borough to be ring fenced for secure delivery of carbon dioxide emission reduction elsewhere. (The target for new residential major development applications seek to achieve a minimum 35% regulated carbon dioxide emissions reduction against Building Regulations Part L 2013 on site. Remaining regulated carbon emissions up to 100% to be offset through cash in lieu contribution). Policy 5.2(B) seeks to ensure that major residential developments and non-residential buildings should be zero carbon. Policy 5.2 is complemented and supported by Policies 5.3 to 5.9 inclusive and as such energy assessments must fully address the requirements of these policies satisfying the Mayor's zero carbon policy.

204. Policy 5.3 states that the highest standards of sustainable design and construction should be achieved in London to improve the environmental performance of new developments and to adapt to the effects of climate change over their lifetime. Development proposals should also demonstrate that sustainable design standards are integral to the proposal, including its construction and operation, and ensure that they are considered at the beginning of the design process.

205. Policy SI3 of the Intend to Publish London Plan requires Major development proposals within Heat Network Priority Areas to have a communal low-temperature heating system.

206. Core Strategy Policy DM3 states that design proposals should incorporate climate change adaptation measures based on the type and extent of the main changes expected in the local climate throughout the lifetime of the development, this is likely to require a flexible design that can be adapted to accommodate the changing climate, e.g. provision of additional shading or cooling.

207. The application has been amended to reduce its carbon emissions, with the proposed energy strategy re-designed to ensure that the energy efficiency of individual properties can be optimised to significantly reduce carbon emissions. The combination of PV Panels and the proposed air source heat pump (ASHP) would result in the development achieving a 65.75% improvement over Part L, based on the SAP10 carbon factors. The ASHP would be located on the ground floor adjacent to the proposed retail unit in a secure plant room.

208. The building is located in a heat network opportunity area, and therefore although there is no heat network currently available, the development is required to incorporate a low temperature communal heating system in order to facilitate future connection, in line with the guidance in the Intend to Publish London Plan policy 'SI3 Energy infrastructure'. This has been specified for the development, along with an accessible plant room within the proposed basement at 2 Canbury Park Road to locate future heat exchange equipment and an appropriate location for pipework to enter the site from the road. As such the proposed development would be 'future proofed' to allow for connectivity to a district heat network should one come forward in the longer-term.

209. Following the energy hierarchy, passive design measures, energy efficient equipment and renewable energy have shown an improvement of 65.75% over Part L, based on the SAP10 carbon factors.

210. Overall, the development will achieve an improvement in regulated emissions over the Building Regulations Part L standards for regulated emissions of a minimum of 65.75%. The proposed development meets the London Plan target of a minimum 35% reduction in Part L emissions on site and a carbon off-set payment of £9,966 would meet with London Plan "Zero Carbon" requirements.

211. The revised energy strategy is considered to be acceptable in sustainability terms, subject to conditions/legal agreements related to a Carbon Offsetting financial contribution, future connectivity to a District Heat Network and securing the agreed targets.

Trees and Landscaping

212. There are no Tree Preservation Orders (TPO) in place.

213. The indicative landscape proposals include the ground floor courtyard and the home-working winter garden. Landscaping in these areas include low level planting, plant boxes, climber plants and small - medium sized trees.

214. Urban Greening: the Intend to Publish London Plan Policy G5 relates to urban greening, and states that major developments should include urban greening factors within their building design, with a recommended target of 0.4. The scheme has been revised in response to this policy and now includes a number of factors that contribute to urban greening (green roof or sedum, flower rich perennial planting, green wall and permeable paving). This provides an urban greening factor of 0.3. whilst slightly lower than the Mayor’s recommended target of 0.4, it is considered acceptable within this tight urban context which has sought to maximise urban greening feasibility.

Ecology/Biodiversity

215. The NPPF advises that when determining planning applications, local planning authorities should apply the following principle:

a) if significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused. ​

216. Policy 7.19 of the London Plan 2016 states that wherever possible development proposals should be planning for nature from the beginning of the development process and taking opportunities for positive gains for nature through the layout, design and materials of development proposals and that development should make a positive contribution to the protection, enhancement, creation and management of biodiversity.

217. Policy DM6 of the Core Strategy 2012 states that new developments should protect and promote biodiversity as part of sustainable design through the inclusion of sustainable drainage, tree planting, soft landscaping, habitat enhancement, green roofs and new or improved semi-natural habitats, where appropriate. The policy goes on to say that the Council requires an ecological assessment on major development proposals, or where a site contains or is next to significant areas of habitat or wildlife potential.

218. Given the urban location and heavy presence of street lighting in the local area, it is recommended that a precautionary destructive search of the roof prior to demolition. This would entail the removal of the roof tiles and any suitable bat roosting features by hand, under the supervision of a suitably qualified ecologist.

219. With regards to mitigation, the report recommends incorporating 4 built-in bat tubes, 4 swift built-in swift boxes and two other built-in nest bricks into the building.

220. Other features that would be included within the development include green roofs on the roofs of the fourth, eighth and ninth floors and planting within the ground floor courtyard area. The planting and the sedum roof landscaping will replace the hardstanding leading to an increase in biodiversity on the site.

221. The Biodiversity Officer has raised no objection subject to securing the mitigation measures as set out within the report.

222. In conclusion, the proposals have sought to minimise/mitigate impacts and subject to the implementation of appropriate mitigation and compensation measures, it is considered unlikely that the proposals will result in significant harm to biodiversity, indeed enhancements would be secured. These would be captured by way of a planning condition.

Flood Risk and Drainage

223. Policy DM4 and KTCAAP Policy K24 both concern flooding and seek to ensure that new development includes SUDS within schemes to reduce surface water runoff rates. Whilst Policy DM4 only requires a flood risk assessment for sites over 1 hectare, Policy K24 relates solely to Kingston Town Centre and flood risk assessments are required for all major developments within Flood Zone 1.

224. The site is within Flood Zone 1, with a low risk of fluvial flooding. The National Planning Policy Framework describes land within this zone as having a low risk of flooding at less than 1 in 1000 probability of river or sea flooding. The site is located adjacent to a Flood Zone 2 area to the south.

225. The application is accompanied by an FRA, which identifies the potential sources of flooding. The report notes that although the development lies within Flood Zone 1, it is expected that it may be affected by increased flood risk in the future as a result of climate change. Mitigation measures proposed include the setting of residential ground floor levels, flood warning systems and flood evacuation plan for the retail unit, and drainage systems and their maintenance measures to ensure that the site is safe for use for the lifetime of the development.

226. The proposal is also accompanied by a Drainage Strategy. The proposed drainage strategy would result in a reduction in surface water discharge. The proposal has been revised to address concerns initially raised by the Flood Risk Officer and, subject to conditions requiring submission of finalised design, is considered acceptable.

227. In conclusion, subject to appropriate safeguarding conditions, the development is compliant with Policy DM4 and K24, London Plan Policies 5.12 & 5.13, and the NPPF.

Refuse & Recycling

228. London Plan Policy 5.7 (Waste Capacity) requires the provision of suitable waste and recycling storage facilities in all new developments. Guidance states that refuse stores should be accessible to all residents and should satisfy local requirements for waste collection. As shown on the proposed plans, the scheme contains a refuse and recycling storage area at the main residential entrance foring 2 Canbury Park Road. Full details would be reserved by condition

229. The refuse storage area and collection point is located within a gated area within the curtilage of the site boundary. The collection point is adjacent to the existing loading bay on Canbury Park Road.

230. This proposed arrangement is considered to be acceptable in principle, with details to be secured by condition.

Contamination

231. Policy DM1 states that new development should minimise contaminated land impacts in line with industry best practice. Whilst London Plan Policy 5.21 seeks to ensure that development of brownfield land does not result in significant harm to human health or the environment.

232. A Phase 1 Environmental Report and is submitted as part of this planning application. The site walkover, historical mapping and environmental searches have identified potential sources of contamination. These include local services and employment premises such as the bus depot, coal yard, railway and works which have been undertaken off-site. Naturally occurring contaminants and asbestos from below the ground slabs and train brake pads have also been identified.

233. A risk assessment has been undertaken as part of the survey. Risk ratings of moderate or greater indicate potentially complete source-pathway-receptor linkages that can require further investigation and remedial measures. The following moderate or greater risks have been identified at the site.

● Site users, and workers in direct contact with contaminated soil ● Site users and workers inhaling contaminated dust ● Direct contact of soil with building materials ● Site users, neighbours and workers inhaling fibres (asbestos)

234. The report has been reviewed by the Environmental Health Officer who notes the historical contaminative land use with potential for active plausible pollution linkage considering the proposed end use. There is a high possibility of asbestos containing material and localised made ground across the site. The report recommends a site specific intrusive investigation which would require intrusive testing and laboratory analysis to confirm ground conditions and the geo-technical site specific characteristics and aggressivity of any made ground. There is a possibility of residual unexploded ordnance.

235. The site would only be suitable for its intended use subject further intrusive investigation undertaken to characterise the ground profile, remediation works (where appropriate) to address any contaminants present and further assessment of any unexploded ordnance (during construction). Accordingly, safeguarding conditions are recommended requiring that an additional risk assessment, detailed remedial strategy and verification plan should be submitted to the Local planning authority for agreement prior to commencement of development and remedial works.

236. With appropriate safeguarding conditions in place, the proposal would be compliant with Policy DM6.

Basement Impact Assessment

237. The development includes a small basement (approximately 38 sqm) beneath 2 Canbury Park Road (to house a plant room to allow future connectivity to a District Heat Network). A Basement Impact Assessment accompanies the application and demonstrates that there would be no adverse effects as a result of the small basement area. It is noted that whilst there are further investigations to undertake, there would be suitable mitigation and design measures in place to ensure that there are no adverse or harmful impacts on surface flow and flooding, groundwater flow and structural stability of surrounding properties.

Legal Agreements

238. Policy IMP3 of the Core Strategy 2012 states that the Council will use Planning Obligations to secure financial contributions to meet on and off site requirements which are required to support and mitigate the impacts of the development in accordance with the Council’s Planning Obligations SPD March 2017.

239. As of the 1st November 2015 the Council commenced the operation of a Community Infrastructure Levy (CIL) as a means of collecting monies to provide local infrastructure to offset the impact of developments. This replaced the S106 mechanism for collecting contributions for local infrastructure e.g. education and health with the exception of affordable housing. For the avoidance of doubt S106 contributions can only be collected to resolve site specific issues as a result of the proposed development.

240. In relation to this application, the following site specific and/or financial and infrastructure contributions are required to mitigate the adverse impacts of the development:

1. Affordable housing: 1 shared ownership units 2. An 'early stage review' if the development is not commenced within 2 years of the date of permission being granted and a “late state review” when 75% of the units are sold or let. Any surplus at the late review stage will be split 50:50 between the developer and RBK. 3. Preclusion from eligibility to obtain resident parking permits within the Controlled Parking Zone 4. Car club membership with free membership secured for new residents for a minimum 3-year period 5. Financial contribution of £9,966.00, by way of carbon off-set payment, to mitigate the short fall in carbon savings in achieving a ‘zero carbon’ development.

6. Section 278 highways agreement for the works to the public highway to resurface the footway on Richmond Road and Canbury Park Road between the two site frontages after construction works are finished and associated works including costs to delineate the limit of public highway (back of footway) with concrete edging or by a change in surface material (in case no dedication is agreed). 7. Obligation to secure access for the installation of the Heat Network pipework at a future date when the Heat Network comes forward; to provide appropriate space reserved within plant room, for heat exchangers and thermal stores; and to safeguarding suitable routes for pipework from the site boundary and making provision for connections to the future network at the site boundary. 8. Submission and Approval of marketing strategy and details for the 2 private wheelchair housing units 9. A commitment to provide local employment/training opportunities during the construction phase. 10.Older Child’s Playspace: A financial contribution of £2,760.00 towards improvement to the playground at Elm Road Recreation Ground.

241. Subject to the signing of this legal agreement the proposal complies with policies 3.12, 5.1 and 5.2 of the London Plan, 2016 and policies CS10, DM9, DM10 and DM15 of the LDF Core Strategy, 2012.

Community Infrastructure Levy

242. The application would be Kingston CIL liable which is presently set at £210/m2 for the additional residential floor space and £200 for net additional A1/A3 commercial floorspace. The application would also be liable to pay Mayoral CIL which is presently set at £60/m2 of additional floor area. The CIL charges are subject to the national Tender Price Index.

Conclusion/Planning Balance

243. Part (d) of Paragraph 11 of the NPPF states where there are no relevant development plan policies, or the policies which are most important for determining the application are out-of-date, the Council should grant planning permission unless:

i. the application of policies in this Framework that protect areas or assets of particular importance provides a clear reason for refusing the development proposed or;

ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

244. In this case, the Council cannot identify a 5-year housing land supply and so this application for residential development will be subject to paragraph 11 (d). As such, in line with Government Policy the development should be permitted unless the adverse impacts significantly and demonstrably outweigh the benefits.

245. The proposed development would make a contribution towards the Borough’s housing supply in terms of both market and affordable dwellings. The proposal for 15 residential units results in a net addition of 13 homes, which would contribute to the provision of accommodation within an established residential area and within a highly sustainable location. This carries significant weight in favour of the proposal. However, this benefit is tempered by the quality of the proposed units resulting from the poor existing environmental conditions at the site. Air quality at the proposed development site is expected to exceed the national air quality objective for long-term exposure to nitrogen dioxide up to the fifth floor. At ground and first floor levels, there are likely to be exceedances of the hourly exposure limit for the same pollutant. Noise conditions at the site are also poor. Major noise sources in the area immediately surrounding the proposed development site include the adjacent main road (A307), the railway line and train station, and the Public House, which hosts live music events. In order to mitigate the impact of the aforementioned environmental conditions on future occupants of the proposed development, the application proposes a number of measures. The applicant proposes that, in order to mitigate noise from the Whelan Public House, windows to habitable rooms facing the venue would be unopenable, and in order to mitigate the impact of poor air quality on future occupants, windows facing the street up to fifth floor level would also be required to be sealed, with the flats served by a mechanical ventilation system. However, all flats would be able to open at least one window on an unaffected elevation.It is further noted that the proposed development would not deliver private / communal amenity space in-line with the requirements in the Core Strategy, although it is noted that space has been provided in line with the Mayor’s requirements. Notwithstanding, this would weigh against the proposal.

246. The proposed development would make a contribution of 1 affordable dwelling (Shared Ownership). The developer has submitted an FVA which has been independently assessed by third party consultants. The independent consultants conclude, when using the standard inputs into the FVA, the maximum reasonable amount of affordable housing which could be secured is zero. Notwithstanding, the developer is offering 1 unit, this carries weight in favour of the proposal.

247. A significant degree of objection has been raised to the height and design proposed.The proposal would introduce a tall and prominent building in a prominent location, of significantly greater scale than its immediate context. It is within an area of transition from low to medium rise, in very close proximity to Kingston Railway Station, where higher densities would not be inappropriate so as to optimise the land. It is acknowledged that the properties nearby are of lower scale and density, but in terms of urban design the proposed scheme, although bold and prominent when it comes to its height, massing and presence along Richmond Road and Canbury Park Road, is considered to be a reasonable, well-articulated and positive addition to the wider Kingston townscape.

248. This height and massing results in a reduction in the amenity currently experienced by neighbouring residents, particularly as a result of loss of light and shadowing of neighbouring properties in Canbury Park Road. However, the loss would be within the parameters set out within BRE Guidelines.

249. Overall it is concluded, on balance, that the adverse impacts identified including the compromised residential amenity of units, and the limited impact on neighbouring occupants would not significantly and demonstrably outweigh the benefits of providing net additional 13 dwellings, including 1 affordable housing unit at a time when the Council is unable to demonstrate a five year supply of deliverable housing sites. As such, the proposal is considered to generally comply with the NPPF, The London Plan, 2016, The Intend to Publish London Plan, the LDF Core Strategy, 2012 and the Council's Residential Design Guide, 2013 .

Recommendation: Grant conditional permission subject to legal agreement and the ​ following conditions with authority delegated to the Assistant Director (Strategic Planning and Infrastructure) to amend any conditions, including to comply with the Section 106 agreement:

1 The approved development shall be carried out in accordance with the following drawings/details:

6132 Richmond Road, Kingston- Section with Sight Lines 6132 Richmond Road, Kingston- Perspective View Canbury Park Road (20) 400 Rev P5 - Proposed Richmond Road Elevation (00) 000 Rev P - Site Location Plan (00) 100 Rev P - Existing Ground Floor Plan (00) 101 Rev P - Existing First Floor Plan (00) 150 Rev P - Existing Site Plan (00) 400 Rev P - Richmond Road Elevation (00) 401 Rev P - Existing South Elevation (00) 402 Rev P - Existing East Elevation (00) 404 Rev P - Existing 2 Canbury Park Road Elevation Air Quality Assessment, Ref: J3899A/1/F3, (dated October 2019) Archaeological Desk-Based Assessment Ref: R13833 (dated May 2020) Transport Statement, Ref: TS01A, (dated 9 October 2019) Daylight and Sunlight Report, Ref: 2113/F REV02, (dated September 2019) Design and Access Statement, (dated October 2019) Ecological Impact Assessment, Ref: 4856.F0, (dated October 2019) Heritage and Townscape Assessment, (dated October 2019) Phase 1 Environmental Report, Ref: 1650-P1E-1, (dated 3 October 2019) Statement of Community Involvement, (dated 9 October 2019) Technical Note Construction Traffic Management Plan, Ref: TN01, (dated 27 September 2019) (20) 100 Rev P4 - Proposed Ground Floor Plan (20) 102 Rev P7 - Proposed Second Floor Plan (20) 105 Rev P7 - Proposed Fifth Floor Plan (20) 099 Rev P2 - Proposed Basement Floor Plan REV (20) 300 Rev P2 - Proposed Section A (20) 401 Rev P4 - Proposed South Elevation (20) 404 Rev P2 - Proposed 2 Canbury Park Road Elevation (27) 100 Rev P3 - Proposed Roof Plan Planning Statement, Revision A (dated February 2020) Daylight and Sunlight Letter (dated 20 February 2020) Richmond Road Energy Strategy Report Version 3 Transport Technical Note Addendum Design And Access Statement Addendum March 2020

Energy Statement dated June 2020 prepared by JAW Sustainability 6132 (UG) 105 Urban Greening- Proposed Fifth Floor Plan 6132 (UG) 109 Urban Greening- Proposed Roof 6132 (UG) 100 Urban Greening- Proposed Ground 6132 (UG) 101 Urban Greening- Proposed First Floor Plan 6132 (UG) 108 Urban Greening- Proposed Eighth Floor Plan (20) 108 Rev P5 Proposed Eighth Floor Plan Daylight and Sunlight Letter (dated 5 June 2020) Statement of Community Involvement, (dated 9 October 2019) Transport Technical Note, (20 February 2020) Fire Statement (dated 17 February 2020) Viability Assessment (dated 10 March 2020) Pedestrian Level Wind Desk-Based Assessment Ref: 2002453 - REV B (dated 6 April 2020) Design and Access Statement Addendum (dated March 2020) Basement Impact Assessment Report Ref: 4408-RBG-ZZ-XX-RP-GE-01001 (dated 21 May 2020) Design And Access Statement Addendum 2, (dated June 2020) Noise and Vibration Assessment Report (dated 5 June 2020) Energy Statement, Version 4 (dated June 2020) Flood Risk Assessment & Drainage Strategy Ref: 2019/D1739/FRA/4.1 (dated June 2020) Ventilation Strategy Rev 3 (dated 04 June 2020) Air Quality Mitigation Ref: J3899B/1/F1 (dated July 2020) (20) 150 Rev P3 - Proposed Site Plan (20) 101 Rev P7 - Proposed First Floor Plan (20) 103 Rev P7 - Proposed Third Floor Plan (20) 104 Rev P7 - Proposed Fourth Floor Plan (20) 106 Rev P5 - Proposed Sixth Floor Plan

Reason: For the avoidance of doubt and in the interests of proper planning.

2 The development hereby permitted shall begin before the expiration of three years from the date of this permission.

Reason: As required by Section 91 of the Town and Country Planning Act 1990 (as amended)

3 Prior to commencement of any development on site, a Construction Environmental Management Plan (CEMP) shall be submitted to, and approved in writing by, the Local Planning Authority. The CEMP shall comprise measures for controlling the effects of demolition, construction and enabling works associated with the development as may be approved

by the Local Planning Authority. The CEMP shall address issues including the phasing of the works, air quality (to include a management plan and monitoring), waste management, site remediation, plant and equipment, site transportation and traffic management including routing, signage, permitted hours for construction traffic and construction materials deliveries, and shall include details to ensure compliance with the requirements for non-road mobile machinery. The CEMP must meet the standards set out in the GLA SPG on the Control of Dust and Emissions During Construction.

The CEMP must ensure appropriate communication with, and the distribution of information to, the local community and the Local Planning Authority relating to relevant aspects of construction.

Appropriate arrangements should be made for monitoring and responding to complaints relating to demolition and construction. All demolition, construction and enabling work at the development shall be carried out in accordance with the approved CEMP unless otherwise agreed in writing by the LPA.

Reason: These details are required prior to commencement of development because the relevant works would take place at the beginning of the construction phase and in order to protect local air quality and safeguard the amenities of the surrounding residential occupiers, in compliance with h Policy 7.14 of the London Plan and the GLA SPG Control of Dust and Emissions during Construction and Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

4 No development shall take place including any works of demolition until a Construction Logistics Plan has been submitted to and approved in writing by the Local Planning Authority. The approved plan/statement shall be adhered to throughout the construction period. The statement shall provide for:

i) Provision for loading/unloading materials; ii) Temporary site access; iii) Signing system for works traffic; iv) A Basement Impact Assessment v) Measures for the laying of dust, suppression of noise and abatement of other nuisance arising from development works; vi) Means of enclosure of the site; vii) Wheel washing equipment; viii) The parking of vehicles of the site operatives and visitors; ix) The erection and maintenance of security hoarding; x) Measures for the protection of surrounding trees; and xi) Construction hours.

The approved Construction Logistics Plan shall be adhered to throughout the construction period for the development.

Reason: These details are required prior to commencement of development because the relevant works would take place at the beginning of the construction phase and in order to safeguard the amenities of the surrounding residential occupiers and to safeguard highway safety and the free flow of traffic in accordance with Policies DM9 (Managing Vehicle Use for New Development) and Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

5 Prior to the commencement of the development the applicant must submit details of how dust and emissions during construction and demolition are to be controlled. The applicant shall have regard to the GLA SPG on the Control of Dust and Emissions During Construction and Demolition. Such details shall normally include:

● An air quality and dust risk assessment ● An air quality management plan ● Site monitoring ● Compliance with the requirements for non-road mobile machinery. See http://nrmm.london/. Note: parts of the borough require the higher standards for the ‘Central Activity Zone’ and Canary Wharf. Details are available on the Non Mobile Machinery website.

Reason: These details are required prior to commencement of development because the relevant works would take place at the beginning of the construction phase and to protect local air quality and comply with Policy 7.14 of the London Plan and the GLA SPG Control of Dust and Emissions During Construction.

6 No demolition or development shall take place until a stage 1 written scheme of investigation (WSI) has been submitted to and approved by the local planning authority in writing. For land that is included within the WSI, no demolition or development shall take place other than in accordance with the agreed WSI, and the programme and methodology of site evaluation and the nomination of a competent person(s) or organisation to undertake the agreed works.

If heritage assets of archaeological interest are identified by stage 1 then for those parts of the site which have archaeological interest a stage 2 WSI shall be submitted to and approved by the local planning authority in writing. For land that is included within the stage 2 WSI, no demolition/development shall take place other than in accordance with the agreed stage 2 WSI which shall include:

A. The statement of significance and research objectives, the programme and methodology of site investigation and recording and the nomination of a competent person(s) or organisation to undertake the agreed works

B. The programme for post-investigation assessment and subsequent analysis, publication & dissemination and deposition of resulting material. this part of the condition shall not be discharged until these elements have been fulfilled in accordance with the programme set out in the stage 2 WSI.

Reason: This pre-commencement condition is necessary to safeguard the archaeological interest on this site. Approval of the WSI before works begin on site provides clarity on what investigations are required, and their timing in relation to the development programme and would ensure that matters of archaeological interest can be recorded in accordance with Policy DM 12 (Development in Conservation Areas and Affecting Heritage Assets) of the LDF Core Adopted April 2012. These details are required prior to commencement of development to safeguard the presence of, and establish the effective recording of, any heritage assets present on the site.

7 A Delivery and Service Management Plan shall be submitted to and approved in writing by the local planning authority before the occupation of the development hereby approved. The development shall only be occupied in accordance with the approved details.

Reason: In order to safeguard the amenities of the surrounding residential occupiers and to safeguard highway safety and the free flow of traffic in accordance with Policies DM9 (Managing Vehicle Use for New Development) and Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

8 The levels of buildings, roads, parking areas and pathways within the site shall only be in accordance with details which shall have previously been submitted to and approved in writing by the Local Planning Authority before development is commenced.

Reason: These details are required prior to commencement of development because the relevant works would take place at the beginning of the construction phase and to ensure that the appearance and functioning of the development is satisfactory and to safeguard the amenities of adjoining occupiers in accordance with Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012 and comply with Supplementary Planning Document 'Access for All' (July 2005).

9 No unit hereby permitted shall be occupied until the cycle parking provision shown on the approved plans has been completed, and thereafter, be kept free of obstruction and available for the parking of cycles only. Reason: To ensure the provision of adequate cycling facilities in accordance with Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

10 Before any piling takes place a piling method statement shall be submitted to and approved in writing by the Local Planning Authority. Any piling must be undertaken in accordance with the terms of the approved piling method.

Reason: These details are required prior to commencement of development because the relevant works would take place at the beginning of the construction phase and to safeguard the amenities of the occupiers of the neighbouring properties in accordance with Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

11 The site and building works required to implement the development shall be only carried out between the hours of 08.00 and 18.00 Mondays to Fridays and between 08.00 and 13.00 on Saturdays and not at all on Bank Holidays and Sundays.

Reason: To safeguard the amenities of the adjoining residential occupiers in accordance with Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

12 Prior to the commencement of any above ground level works, details of the hard landscaping and features, including samples of paving materials, shall be submitted to and approved in writing by the Local Planning Authority, and shall include product specifications. Where typicals are submitted, these are to be accompanied by a key typology plan / elevation The development shall be carried out in accordance with the approved details.

Reason: In the interests of visual amenity and also that the Local Planning Authority shall be satisfied as to the details of the development in accordance with Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

13 No development above ground level shall take place until details and samples for all facing materials, including a sample board of main facing materials (to include mortar & movement joint materiality), have been submitted to and agreed in writing by the Local Planning Authority. The

agreed scheme shall be implemented prior to the first occupation of the development and retained thereafter.

Reason: To ensure a satisfactory appearance on completion of the development in accordance with Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012. These details are required prior to commencement of development because the details would affect subsequent design of other elements of the scheme and must be agreed at the outset.

14 Detailed drawings at the scale of 1:10 / 1:20 of the following shall be submitted to and be approved in writing by the Local Planning Authority before the relevant part of work is begun.

(i) details of openings (windows, doors) including details of obscured glazing, (ii) balconies, railings (iii) entrances and lobby related materials (iii) guttering, rainwater pipes, drainage slots (iv) public cycle, waste bin, shelters & other relevant visible amenity infrastructure (v) integrated & non-integrated vents (vi) other accessories & services (including outdoor and publicly visible signage, lighting fixtures) (vii) green roof detailing, including ballast perimeter, or alternative Part B requirements (viii) shop front elevation and section with clearly indicated signage, lighting, entrance, and other typical for a shop front elements (ix) lighting strategy detailing secure public, communal and private environments.

All elements to be submitted in drawing format to ensure quality, appropriateness and principles of good design. Where typicals are submitted, these are to be accompanied by a key typology plan / elevation. As part of the conditions these are to include product specifications.

The details thereby approved shall be carried out in accordance with that approval in accordance with Policies DM10

Reason: In the interests of visual amenity and the character of the area and in accordance with Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

15 Prior to commencement of development works and remedial works, an additional risk assessment, detailed remedial strategy and verification plan shall be submitted to and agreed in writing by the Local Planning

Authority. On completion of the agreed remedial works, a closure report and certificate of compliance endorsed by the interested party/parties, shall be submitted to and agreed in writing by the Local Planning Authority, prior to the occupation of the site by end users. The works shall be of such a nature so as to render harmless the identified contamination given the proposed end-use of the site and surrounding environment including any controlled waters.

The closure report shall include details of the proposed remedial works and the quality assurance certificates to show that the works have been carried out in full in accordance with the approved methodology. Details of any post remediation sampling and analysis to show the site has reached the required clean up criteria shall be included in the closure report together with the necessary “Duty of Care” documentation detailing what waste material has been removed from the site.

All work should be in accordance with the HSE document “Protection of workers & the general public during the development of Contaminated Land”.

Reason: These details are required prior to commencement of development because the relevant works would take place at the beginning of the construction phase and to prevent harm to human health and pollution of the environment

16 If during implementation of this development, contamination is encountered which has not previously been identified, the additional contamination shall be fully assessed and a specific contaminated land assessment and associated remedial strategy shall be submitted to and agreed in writing by the Local Planning Authority before the additional remediation works are carried out. The agreed strategy shall be implemented in full prior to completion of the development hereby approved.

Reason: To prevent harm to human health and pollution of the environment

17 No flues or pipework shall be fixed to the elevations other than those shown on the drawings hereby approved or in accordance with details which shall have first been submitted to and approved in writing by the Local Planning Authority.

Reason: In the interests of the visual amenities of the area in accordance with Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

18 No fans, louvres, ducts, external lighting or other external plant other than those shown on the drawings hereby approved shall be installed without

the prior written approval of the Local Planning Authority.

Reason: To safeguard the amenities of the occupiers of the neighbouring properties and the visual amenities of the area in accordance with Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

19 Prior to any above ground level works, details shall have been submitted to confirm that the two identified wheelchair housing units specification/standards have been approved under the Building Regulation requirement M4(3). The units shall be built and maintained in accordance with the approved M4(3)specifications. All other units shall be built to meet Building Regulation requirement M4(2) ‘accessible and adaptable dwellings’.

Reason: To ensure that the development provides a range of homes to meet different needs and to ensure compliance with Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012, and Policies 3.5 and 3.8 Policy 3.8 of the London Plan 2016.

20 No unit hereby permitted shall be occupied until the refuse stores, and area/facilities allocated for storing of recyclable materials, as shown on the approved drawings have been completed in accordance with the approved plans. The developer and/or their successors in title shall take all reasonable steps to ensure that all refuse and recyclable materials associated with the development shall either be stored within this dedicated store/area as shown on the approved plans, or internally within the building(s) that form part of the application site, and that no refuse or recycling material shall be stored or placed for collection on the public highway or pavement, except on the day of collection.

Reason: To ensure the provision of refuse facilities to the satisfaction of the Council in accordance with Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

21 Prior to the occupation of any A3 unit within the development, details of the proposed extract ventilation system (including the extraction hood, internal fan, flexible couplings, three-stage filtration [grease filters, pre-filters and activated carbon filters], height of the extract duct above eaves level and anti-vibration mountings) shall be submitted to, and approved in writing by, the Local Planning Authority before construction commences. Particular consideration should be given to the high level discharge of kitchen extract air. The approved details shall thereafter be installed prior to the use of the premises and permanently maintained as such thereafter.

Reference should be had to the DEFRA document ‘Guidance on the

control of odour and noise from commercial kitchen exhaust’ available at: https://www.gov.uk/government/publications/guidance-on-the-control-of-od our-and-noise-from-commercial-kitchen-exhaust Note that despite being withdrawn by DEFRA, this guide still represents the most authoritative guidance on this subject

Reason: To protect local amenity and to prevent future issues of odour nuisance.

22 Prior to the occupation of any A3 unit within the development the applicant/occupier shall provide a scheme to the Local Planning Authority for its written approval detailing sound transmission reduction measures to be installed between the A3 use and any adjoining residential flat. The scheme shall be designed to provide at least DNTw+Ctr 50dB. Once agreed in writing by the Local Planning Authority the approved details shall be installed prior to the development being occupied and retained thereafter.

Reason: In order to safeguard the amenities of future residential occupiers of the development in accordance with Policy DM10 of the LDF Core Strategy Adopted April 2012.

23 Prior to the commencement of any above ground works details of the window openings on the North and West elevations, in particular how they will be maintained as non-openable, shall be submitted to and approved in writing by the Local Planning Authority. The development shall be carried out and occupied in accordance with the approved details. Reason: In order to safeguard the amenities of future residential occupiers of the development in accordance with Policy DM10 of the LDF Core Strategy Adopted April 2012.

24 Prior to superstructure work commencing, a report detailing measures to minimise the exposure of the development's future occupiers to air pollution with details for a ventilation strategy shall be submitted to and approved in writing by the Local Planning Authority. The development shall thereafter be carried out strictly in accordance with the measures so approved, and shall be maintained as such thereafter, unless otherwise approved in writing by the Local Planning Authority.

Reason: In order to safeguard the amenities and health of future residential occupiers of the development in accordance with Policy DM10 of the LDF Core Strategy Adopted April 2012.

25 Before the beneficial occupation of the development hereby permitted, all windows and openings shown as obscure glazed on the drawings hereby approved shall be fitted with, and retained in, obscure glazing to a minimum of level 3 on the standard scale. Any film used to achieve the

requisite obscurity level shall be non-perishable and tamper-proof, and shall be replaced immediately in the event that it ceases to result in obscurity to level 3. All such windows shall be fixed shut below a height of 1.7m from finished floor level. Reason: To protect the amenities and privacy of the occupiers of the adjoining residential properties in accordance with Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

26 The privacy screens shown on the approved drawings, shall be provided prior to occupation of the development hereby approved and retained thereafter.

Reason: To protect the amenities and privacy of the occupiers of the adjoining residential properties in accordance with Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

27 Except as specifically indicated on the approved drawings as amenity space, all flat roofs hereby permitted shall not be converted or used as a balcony or a sitting out area, and no access shall be gained except for maintenance purposes.

Reason: To protect the amenities and privacy of the adjoining residential properties in accordance with Policy DM10 (Design Requirements for New Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

28 No development above ground level (excluding demolition and site clearance) shall commence until a detailed landscaping scheme, based on the submitted Indicative Landscape Strategy and Urban Greening drawings hereby approved, shall have been submitted to and approved in writing by the Local Planning Authority. The landscape scheme shall include:

(a) detailed landscaping and planting plan (b) tree planting plan and specification (c) full specification of urban greening measures (d) maintenance plan and strategy for the elements identified above. (e)

The approved scheme shall be implemented within the first planting season following completion of the development and the tree planting and landscaping shall thereafter be maintained for five years to the satisfaction of the Local Planning Authority. Any trees or shrubs which die during this period shall be replaced in the first available planting season, and the area shown to be landscaped shall be permanently retained for that purpose only. Reason: In the interests of visual amenity and also that the Local Planning Authority shall be satisfied as to the details of the development.

29 The development shall be implemented and maintained in accordance with the recommendations made in the Ecological Assessment prepared by ECOSA dated October 2019, to include ecological enhancement/mitigation. Reason: To safeguard and protect the sites biodiversity and nature conservation value in accordance with Policy DM6 (Biodiversity) of the LDF Core Strategy Adopted April 2012.

30 The development hereby permitted shall incorporate security measures to minimise the risk of crime and to meet the specific security needs of the development in accordance with the principles and objectives of Secured by Design. Details of these measures shall be submitted to and approved in writing by the local planning authority prior to any above ground level works, and shall be implemented in accordance with the approved details prior to occupation.

Reason: In order to achieve the principles and objectives of Secured by Design to improve community safety and crime prevention in accordance with Policies CS14 (Safer Communities), DM10 (Design Requirements for New Developments including House Extensions), and Policy DM 22 (Design for Safety) of the LDF Core Strategy Adopted April 2012 and London Plan Policy 7.3 (Designing out Crime) and the NPPF.

31 Prior to occupation a Secured by Design final certificate shall be submitted to and approved by the Local Planning Authority.

Reason: In order to achieve the principles and objectives of Secured by Design to improve community safety and crime prevention in accordance with Policies CS14 (Safer Communities), DM10 (Design Requirements for New Developments including House Extensions), and Policy DM 22 (Design for Safety) of the LDF Core Strategy Adopted April 2012 and London Plan Policy 7.3 (Designing out Crime) and the NPPF.

32 The development shall be built and maintained in accordance with the details set out in the accompanying Energy Statement Version 4 dated June 2020 2020, prepared by JAW.

Reason: In the interests of Sustainability and Energy Conservation in accordance with Policies 5.2 (Minimising Carbon Dioxide Emissions) and

5.3 (Sustainable Design & Construction) of the London Plan (July 2016), Policy SI3 of the Draft London Plan, and Policy DM1 (Sustainable Design and Construction Standards) of the LDF Core Strategy Adopted April 2012.

33 Prior to commencement of any above ground level works, details of the proposed future proofing of the site by being connection ready for a supply of heat from an external third party District Heating Network, shall be submitted to and approved in writing by the Local Planning Authority. The development shall be fully implemented in accordance with the approved details, unless otherwise agreed in writing by the Local Planning Authority

Reason: These details are required prior to commencement of development because the details would affect subsequent design of other elements of the scheme and must be agreed at the outset and in order to ensure that all development is designed and built to make the most efficient use of resources, reduce its lifecycle impact on the environment and contributes to climate change mitigation and adaptation in accordance with Policy CS1 (Climate Change Mitigation) of the LDF Core Strategy Adopted April 2012 and Policies 5.1, 5.2 and 5.6 of the London Plan (2016).

34 Within 3 months of first occupation, evidence must be submitted to the council confirming that the development hereby approved has achieved not less than the CO2 reductions (ENE1) associated with meeting London Plan emissions requirements and internal water usage (WAT1) standards equivalent to Code for Sustainable Homes level 4 targets. Evidence requirements are detailed in the “Schedule of evidence Required for Post Construction Stage from ENE1 & WAT1 of the Code for Sustainable Homes Technical Guide. Evidence must demonstrate a minimum 35% emissions reduction compared to 2013 part L regulations, and internal water usage rates of 105l/p/day must be submitted to and approved by the Local Planning Authority, unless otherwise agreed in writing.

Reason: In the interests of sustainability and energy conservation in accordance with Policies 5.2 (Minimising Carbon Dioxide Emissions) and 5.3 (Sustainable Design & Construction) of the London Plan (July 2011) and Policy DM1 (Sustainable Design and Construction Standards) of the LDF Core Strategy Adopted April 2012.

35 Prior to commencement of groundworks (excluding site investigations and demolition), the applicant must submit a final detailed drainage design including drawings and supporting calculations and updated Drainage Assessment Form to the Lead Local Flood Authority for review and approval, aligned with the Sustainable Urban Drainage (SUDS) Strategy Report (February 2020) and associated drawings. A detailed management plan confirming routine maintenance tasks for all drainage components must also be submitted to demonstrate how the drainage system is to be maintained for the lifetime of the development.

Reason: To prevent the risk of flooding to and from the site in accordance with relevant policy requirements including but not limited to London Plan Policy 5.13, its associated Sustainable Design and Construction SPG, the Non-Statutory Technical Standards for Sustainable Drainage Systems and Kingston Council’s Local Plan Policy DM4.

36 No unit hereby permitted shall be occupied until evidence (photographs and installation contracts) is submitted to demonstrate that the sustainable drainage scheme for the site has been completed in accordance with the submitted details. The sustainable drainage scheme shall be managed and maintained thereafter in accordance with the agreed management and maintenance plan for all of the proposed drainage components.

Reason: To prevent the risk of flooding to and from the site in accordance with relevant policy requirements including but not limited to London Plan Policy 5.13, its associated Sustainable Design and Construction SPG, the Non-Statutory Technical Standards for Sustainable Drainage Systems and Kingston Council’s Local Plan Policy DM4.

37 The development shall be built and maintained in accordance with the details and mitigation measures set out in the accompanying Flood Risk Assessment and Drainage Strategy dated February 2020, prepared by RGP.

Reason: In the interests of Sustainability and Energy Conservation in accordance with Policies 5.2 (Minimising Carbon Dioxide Emissions) and 5.3 (Sustainable Design & Construction) of the London Plan (July 2016),

Policy SI3 of the Draft London Plan, and Policy DM1 (Sustainable Design and Construction Standards) of the LDF Core Strategy Adopted April 2012.

38 Prior to occupation of the development hereby approved, a Site Management Plan detailing how the flexible communal workspace/wintergarden accommodation at first floor level 2 Canbury Park Road, would be managed, maintained and controlled to ensure its use for all residential units within development. The development shall be maintained in accordance with the agreed details. Reason: In order to safeguard the amenities of future residential occupiers of the development in accordance with Policy DM10 of the LDF Core Strategy Adopted April 2012.

39 The use of the A1/A3 shall not be carried out outside the hours of 07:00 hours to 23:00 Monday to Sunday.

Reason: To safeguard the amenities of the occupiers of the neighbouring properties in accordance with Policy DM10 (Design Requirements for New

Developments including House Extensions) of the LDF Core Strategy Adopted April 2012.

Informatives:

1 The Party Wall Act 1996 requires a building owner to notify, and obtain formal agreement from, any adjoining owner, where the building owner proposes to: carry out work to an existing party wall; build on the boundary with a neighbouring property; in some circumstances, carry out groundwork's within 6 metres of an adjoining building.

2 The piling method statement should detail the type of piling to be undertaken, why this method has been selected, measures to be taken to minimise noise and vibration and a plan showing where the piles are to be installed. There are a number of different piling methods suitable for different circumstances. Guidance is contained in 8S5228 Noise control on Construction and Open sites - Part 4: Code of Practice for noise and vibration control applicable to piling operations. The contractor is required to take the best practicable means to minimise noise and vibration and the Council positively encourages the use of hydraulic, auger and diaphragm wall piling methods. Where complaints of noise and vibration are received it is expected that the contractor will undertake noise and vibration monitoring, with data reported back to the Environmental Health Service.

3 You are reminded that should the presence of any protected species be found as a result of development the developer would be obliged to fulfil their duties under the Wildlife and Countryside Act, 1981.

4 Your attention is drawn to the fact that planning permission does not override property rights and any ancient rights of light that may exist. This permission does not empower you to enter onto land not in your ownership without the specific consent of the owner. If you require further information or advice, you should consult a solicitor

5 Unless clearly specified otherwise, the base of the development shown on the approved plans is taken to be external ground level, and not a Damp Proof Course or Internal Finished Floor Level. The external ground level is expected to remain consistent before and after construction of the approved development unless specified otherwise on the approved plans.

6 Kingston Council has a statutory duty to officially name streets and number properties within streets. As your planning application is likely to require address changes, you are obliged to contact the Street Naming and Numbering Team to request official registration in accordance with

Part II of the London Buildings Act 1939. Failure to do this could result in delays/omissions by the post office, emergency services and other service providers. You can submit your application online via our website www.kingston.gov.uk

7 The development approved by this planning permission will be liable to pay the Mayor of London's Community Infrastructure Levy (MCIL) and the Royal Borough of Kingston upon Thames CIL. Payment will be due once the owner/developer serves a development Commencement Notice on the Council, and a payment Demand Notice has been received by the owner. Failure to submit a Commencement Notice will incur a surcharge of 20% of the chargeable amount or £2,500, whichever is the lower amount. When you have discharged all pre-commencement conditions the Council will issue a Liability Notice to the owner setting out the CIL calculations. Accompanying the Liability Notice will be a blank Commencement Notice and if necessary a blank Assumption of Liability form, both of which need to be completed and returned to the Council prior to development commencing. A failure to do so will incur a surcharge. Should you have any questions in respect of the contents of this letter or the CIL more generally, please contact the Council's Contact Centre by email [email protected] or phone 0208 547 5002.

8 In dealing with the application the Council has implemented the requirement in the National Planning Policy Framework to work with the applicant in a positive and proactive way. We have made available detailed advice in the form or our statutory policies in the Core Strategy, Supplementary Planning Documents, Planning Briefs and other informal written guidance, as well as offering a full pre-application advice service,

in order to ensure that the applicant has been given every opportunity to submit an application which is likely to be considered favourably.

Written schemes of investigation will need to be prepared and implemented by a suitably qualified professionally accredited archaeological practice in accordance with Historic England's Guidelines for Archaeological Projects in Greater London. This condition is exempt from deemed discharge under schedule 6 of The Town and Country Planning (Development Management Procedure)(England) Order 2015.

9

Evaluation: An archaeological field evaluation involves exploratory fieldwork to determine if significant remains are present on a site and if so to define their character, extent, quality and preservation. Field evaluation may involve one or more techniques depending on the nature of the site and its archaeological potential. It will normally include excavation of trial

trenches. A field evaluation report will usually be used to inform a 10 planning decision (pre-determination evaluation) but can also be required by condition to refine a mitigation strategy after permission has been granted. A single, shored trench is recommended to test the potential for palaeoenvironmental remains on the site, as indicated by the results of boreholes excavated in 2012.

Highway Notes: • Deliveries to the site should avoid traffic peak times, school arrival and pick up times. This is due to existing congestion along Kingston Town Centre which will be exacerbated with the proposals; • Deliveries to the site should avoid waiting on the highway as this could result in a reduction to road safety and emergency access; • Any parking that cannot be contained within the site must park considerately and safely, so as not to obstruct sightlines at junctions or site accesses. The applicant should be aware that any such parking will cause unnecessary concern and agitation within the local community; Should make full use of the site accesses to maximise the availability of off street parking • Service parking and deliveries should not cause any damage to the verges or margins, and no parking is allowed on both. • A license from the Compliance Team will be required to erect off site direction signs. This same team will issue the hoarding license (if necessary) and seek appropriate deposits. • It is not clear if a tower crane would be used. The applicant should be advised that a licence is needed for a tower crane, and should contact the Street Scene Compliance Team on 020 8547 5002. A traffic management arrangement for the delivery, erection, dismantling and removal of a tower crane (if it would be used) should be submitted for approval. • The applicant should be advised to consider if a parking suspension might be needed to allow access for big delivery construction vehicles involved. To apply for parking suspension (if needed), the applicant should contact the Environment Contact Centre on 020 8547 5002.

The provision of the above information ensures that the Borough and the applicant are able to consider the construction at an early stage. This ensures that construction and any traffic management is completed in a professional and timely manner.

Advanced Notice of Works

The proposals will lead to disruption to users of the highway network including the adjacent TfL and SRN in the Borough. As a result the applicant should contact the Boroughs Street Works Team (0208 547 5002. This must take place at least four month prior to works commencing due to the need to obtain TfL Network Assurance approval, and it is required under the New Roads and Street Works Act 1991, and the Traffic Management Act 2004, in order to satisfy the licensing requirements of the Highways Act 1980. This is to ensure the amenities of the surrounding residential occupiers and to safeguard highway safety and the free flow of traffic.

Highway Cleaning Should the access into the site during construction not be paved, spoil could be carried from the site onto the public highway. The access into the site should be paved to minimise the carryover of spoil onto adjacent roads. We would also require the applicant to sweep and wash down the adjacent roads to ensure that the public highway is kept clear of debris. This is to ensure a satisfactory road surface for road safety reasons at all times.

Road Condition Survey Applicant should be advised that the Council will require the applicant to undertake a road and footway condition survey before construction begins. This will take the form of a joint inspection with a member of the Highways Operation Team and will involve a photographic record and visual observation of the roads, verges and margins. The team would secure some deposit to ensure that repairing cost is covered should any damage result from the construction associated with this site.

Also, a license from the Highways Operation will be required to erect off site direction signs. This same team will issue the hoarding license (if necessary) and seek appropriate deposits.

Supporting Papers

The following papers supporting this report are available on the Council's website for inspection:

Application forms Deposited plans Air Quality Assessment, Ref: J3899A/1/F3, (dated October 2019) Archaeological Desk-Based Assessment Ref: R13833 (dated May 2020) Transport Statement, Ref: TS01A, (dated 9 October 2019) Daylight and Sunlight Report, Ref: 2113/F REV02, (dated September 2019)

Design and Access Statement, (dated October 2019) Ecological Impact Assessment, Ref: 4856.F0, (dated October 2019) Heritage and Townscape Assessment, (dated October 2019) Phase 1 Environmental Report, Ref: 1650-P1E-1, (dated 3 October 2019) Statement of Community Involvement, (dated 9 October 2019) Technical Note Construction Traffic Management Plan, Ref: TN01, (dated 27 September 2019) Planning Statement, Revision A (dated February 2020) Daylight and Sunlight Letter (dated 20 February 2020) Richmond Road Energy Strategy Report Version 3 Transport Technical Note Addendum Design And Access Statement Addendum March 2020 Energy Statement dated June 2020 prepared by JAW Sustainability Daylight and Sunlight Letter (dated 5 June 2020) Statement of Community Involvement, (dated 9 October 2019) Transport Technical Note, (20 February 2020) Fire Statement (dated 17 February 2020) Viability Assessment (dated 10 March 2020) Pedestrian Level Wind Desk-Based Assessment Ref: 2002453 - REV B (dated 6 April 2020) Design and Access Statement Addendum (dated March 2020) Basement Impact Assessment Report Ref: 4408-RBG-ZZ-XX-RP-GE-01001 (dated 21 May 2020) Design And Access Statement Addendum 2, (dated June 2020) Noise and Vibration Assessment Report (dated 5 June 2020) Energy Statement, Version 4 (dated June 2020) Flood Risk Assessment & Drainage Strategy Ref: 2019/D1739/FRA/4.1 (dated June 2020) Ventilation Strategy Rev 3 (dated 04 June 2020) Air Quality Mitigation Ref: J3899B/1/F1 (dated July 2020) FVA Consultant Response