Canada Water Site C in the London Borough of Southwark Planning Application No

Home , Canada Water, Canada Water bus station

planning report PDU/2240a/02 10 February 2010 Canada Water Site C in the London Borough of Southwark planning application no. 09-AP-1783

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

The proposal Redevelopment of existing retail warehouses and erection of six buildings varying in height from four to ten storeys, comprising 430 residential units, a 9,104 sq.m retail store, 1,287 sq.m of other retail/restaurant space, 644 sq.m of office space, 528 sq.m of community space and a basement car park for 340 cars.

The applicant The applicant is Conrad Phoenix (Canada Water), and the architects are Michael Aukett Associates for phase 1, and Wilkinson Eyre for phase 2.

Strategic issues The principle of this mixed-use development on previously developed and currently underutilised site is supported. The design and energy strategies proposed are broadly acceptable. There are outstanding issues relating to housing mix, affordable housing, transport, access and climate change mitigation.

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

Context

1 On 27 August 2009 the Mayor of London received documents from Southwark Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. This was referred to the Mayor under Categories 1A and 1C of the Schedule to the Order 2008: “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats”, and “Development which comprises or includes the erection of a building of one or more of the following descriptions – (c) the building is more than 30 metres high and is outside the City of London”.

2 On 6 October 2009 the Mayor considered planning report PDU/2240a/01, and subsequently advised Southwark Council that the application did not comply with the London

page 1 Plan, for the reasons set out in paragraph 100 of the above-mentioned report; but that the possible remedies set out in paragraph 102 of that report could address these deficiencies.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. On 19 January 2010, Southwark Council agreed a dual recommendation resolving to grant permission but giving delegated authority for officers to refuse permission if the Section 106 agreement is not signed before 19 April 2010, and on 21 January 2010 it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged, direct Southwark Council under Article 6 to refuse the application or issue a direction to Southwark Council under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application. The Mayor has until 10 February 2010 to notify the Council of his decision and to issue any direction.

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

Update

5 At the consultation stage, Southwark Council was advised that the application did not comply with the London Plan, for the reasons set out in paragraph 100 of the above-mentioned report; but that the possible remedies set out in paragraph 102 of that report could address these deficiencies:

• Housing and affordable housing: The viability of affordable housing should be assessed as each development phases is brought forward. The applicant should enter into discussions with the GLA and Southwark Council to discuss on how this can be achieved. An increase in family housing provision should also be investigated. • Transport: Further work and/or information is required on trip generation, modal split, and transport impact; car and cycle parking levels and management; improvements to the travel plan; and transport impact mitigation. Contributions of £90,000 per year for 3 years towards Improvements to bus capacity in the vicinity of the site (total of £270,000); £27,000 towards improvements at Canada Water bus station; and £7,000 towards improvements to TfL’s strategic walk network are sought. • Access: Access ramps should have a minimum gradient of 1 in 20 to facilitate easier wheelchair access. • Climate change mitigation: The applicant should provide information regarding the proposed energy centre, such as number of energy centres, location and that sufficient space has been allocated for the proposed equipment. The applicant should also investigate linking the cooling networks. Housing and affordable housing

Level of affordable housing

6 The level of affordable housing to be provided within the scheme at consultation stage was 26%. The applicant and Southwark Council have agreed an amended strategy to provide 27% affordable housing, with the provision to review the provided level should phase 1 of the development not be implemented within two years. An additional financial appraisal will be undertaken by the Council prior to phase 2 of the development. Both phases would be subject to a maximum provision of 35%, which is in line with Southwark Council policy. This programme will allow for a reconsideration of the scheme in light of changing economic conditions, and aligns with the approach suggested to the Council at consultation stage. As such, it is acceptable to officers.

page 2 Provision of additional family units

7 The applicant has stated that any increase in the number of family units would result in a decrease in overall unit numbers, including affordable housing. Additionally, it states that the London Plan and Housing SPG targets are London-wide rather than scheme specific, and that Southwark Council’s standards make it difficult to provide higher volumes of family accommodation within higher density schemes.

8 While the latter argument is partially accepted, much of the new development within this area is higher density, and family-orientated higher density schemes have been provided elsewhere. Additionally this is the second application on this site that the Mayor has considered, and that the reassessment of the original scheme could have provided for additional family units. Nonetheless the proposal as it stands will make a valuable contribution to local housing and the proposal complies with Southwark Council’s standards on the mix of units. On balance, while the level of family housing to be provided is disappointing, the scheme will provide other benefits to the area in terms of housing provision and regeneration, and as such this issue alone is not sufficient to justify a refusal of the scheme. Transport

9 At consultation stage, Transport for London (TfL) highlighted a number of concerns regarding trip generation, car parking levels and management, cycle parking, transport impacts, the travel plan, and pedestrian and highway proposals. A contribution of £304,000 towards improvements to bus services/facilities and the Strategic Walk Network was also requested to help mitigate the impacts of this development.

10 In order to mitigate the transport impacts of this development, TfL requested a contribution of £270,000 towards the provision of additional bus services, £27,000 towards necessary improvements to Canada Water bus station, and £7,000 for improvements to TfL’s Strategic Walk Network. These contributions have been fully agreed by the applicant, which is welcomed.

11 Additional information has been provided regarding the other outstanding concerns and some changes made to the proposal. In conjunction with the proposed planning conditions and Section 106 requirements, TfL is satisfied that most of the outstanding issues have now been resolved, with the exception of several unresolved issues relating to car parking.

Car parking

12 Residential car parking is currently proposed at a level of 0.34, which is significantly higher than the level of provision (ranging from car-free to 0.28 spaces per unit) associated with other recent developments in the area and is in excess of the maximum level set out in the draft Canada Water Area Action Plan (AAP), which recommends a level of 0.3. TfL advised that a maximum level of car parking in line with the emerging Canada Water AAP and which TfL fully supports, could be accepted. Despite protracted negotiations, the applicant has refused to reduce the residential car parking, and no justification has been provided for the higher level proposed.

13 Although the residential parking proposals are within the maximum levels set out in Annex 4 of the London Plan and the over-provision of residential parking from this site is not expected to result in a significantly detrimental impact on the highway network, TfL considers the proposals to represent a collective over-provision of car parking which could undermine the use of more sustainable modes, given the site’s excellent access to public transport. In addition, this and other developments in the area could cumulatively give rise to increases in car traffic, which would contribute towards the overall traffic congestion in the wider Rotherhithe area and impact bus journey times.

page 3 14 TfL therefore considers that the strategic transport concerns raised at consultation stage have not been satisfactorily addressed and that the application does not fully comply with London Plan policies 3C.1 Integrating transport and development, 3C.19 Local transport and public realm enhancements, 3C.20 Improving conditions for buses, 3C.23 Parking strategy, and 3C.24 Parking in town centres, as well as draft consultation replacement London Plan policies 6.1 Strategic approach, 6.7 Buses, bus transits, trams, and 6.13 Parking. Access

15 The requirement to ensure that all ramps within the scheme have a minimum gradient of 1 in 20 has been incorporated within the conditions of the draft planning permission. This will ensure that gradients within the scheme can be easily used by wheelchair users, and is acceptable to officers. Climate change mitigation

16 Officers consider that the proposal complies with the London Plan, as the applicant has provided amendments and information in response to initial concerns. These indicate that the energy proposals are feasible and deliverable. Of note is the provision within the section 106 legal agreement requiring the applicant to provide for links to a future district heating system. Other comments

Views

17 The Mayor’s consultation (stage 1) comments referred to the proximity of the development to the viewing corridor from Greenwich Park to St Paul’s Cathedral, as identified within the London View Management Framework (LVMF) and its draft replacement. While the building is not located within the corridor, it is close to the line of view, and the LVMF notes that buildings at the sides of corridors should be assessed for their potential to create a ‘canyoning’ effect.

18 An appended non-verified photograph from the Greenwich Park General Wolfe viewing point demonstrates that although the site is a tall building within the definition of the London Plan, its relatively low-rise nature of ten storeys, as well as its location outside of the corridor, the proposal will lie against the existing townscape, and that there will be no detrimental effects on either the corridor or the wider panorama.

Metropolitan Police Authority

19 Southwark Council received a representation from CgMs on behalf of the Metropolitan Police Authority (MPA), which requested space within the development for a Safer Neighbourhoods office. The MPA and the applicant could not agree the terms of the lease, which was requested on the basis of a peppercorn rent for a 25 year tenure, secured through the legal agreement. The applicant was requested as to whether it would to forego its £62,813 section 106 agreement contribution to community facilities in lieu of market (or lower) rent, but the applicant advised this was insufficient to cover the cost of the lost revenue. Should the MPA wish to occupy space in the development, it will need to enter into a commercial arrangement with the applicant on mutually agreed terms. Response to consultation

20 Southwark Council’s consultation process yielded responses from Thames Water, the Environment Agency and the London Fire and Emergency Planning Authority, none of which objected to the proposal, subject to the addition of suitable conditions. Additionally, 17 objections, two letters of support and one comment were received from the 1,235 nearby residents

page 4 who were consulted. The issues raised by residents include the perceived overcrowding of the area, the effects on local infrastructure including road and public transport capacity, the construction and height of the building and its effects on local amenity and wildlife, restriction of open spaces within the development to the wider community, archaeological impacts and the mix of uses.

21 The issues of strategic importance within the preceding list have been addressed within this, and the consultation (stage 1) reports. With regard to the capacity of the area and local transport networks, the scheme is part of an overall masterplanned regeneration of Canada Water, and is generally in line with the type and quantum of development proposed within the adopted plan. The supporting statements submitted with the application demonstrate that local infrastructure has been developed at a level that is able to absorb the additional population and movement. Of note is the forthcoming completion of the Jubilee Line upgrade, which when complete will provide a 33% capacity increase when compared with original (1999) service levels. Completion of Crossrail in 2017 is also expected to release additional capacity on the line. Article 7: Direction that the Mayor is to be the local planning authority

22 Under Article 7 of the Order the Mayor could take over this application provided the policy tests set out in that Article are met. In this instance the Council has resolved a dual recommendation to grant permission with conditions, subject to the successful entering of a s106 agreement by the applicant; or refuse the development if a planning agreement is not entered into by 19 April 2010. This satisfactorily addresses that matters raised at stage I, therefore there is no sound planning reason for the Mayor to take over this application. Legal considerations

23 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. The Mayor must also have regard to the guidance set out in GOL circular 1/2008 when deciding whether or not to issue a direction under Articles 6 or 7. Financial considerations

24 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance in Circular 03/2009 (‘Costs Awards in Appeals and Other Planning Proceedings’) emphasises that parties usually pay their own expenses arising from an appeal.

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

page 5 26 Should the Mayor take over the application he would be responsible for holding a representation hearing and negotiating any planning obligation. He would also be responsible for determining any reserved matters applications (unless he directs the council to do so) and determining any approval of details (unless the council agrees to do so). Conclusion

27 Despite some local opposition to the principle of a tall building in this location and other details of the scheme, and some residual officer concerns regarding the provision of family housing, most of the outstanding strategic issues have been resolved. The scheme forms part of a GLA and Council-approved masterplan for the intensification and regeneration of Canada Water, and will contribute a well-designed and high quality scheme within what will be an attractive precinct with excellent public transport accessibility.

28 The main officer objection to this proposal is on the basis of parking provision, which is provided at a level above the level recommended within Southwark Council’s draft Canada Water Area Action Plan. TfL has serious concerns that this level of provision may result in an overdependence on the private car, which is unnecessary in view of the excellent access to public transport within the immediate area. Although there is not likely to be any significantly detrimental impact on the local highway network, TfL is concerned that the cumulative impact of other developments in the area could lead to localised road network congestion.

29 Southwark Council is satisfied with the level of parking provided, even though the proposed levels exceed their Area Action Plan guidelines. The non-compliance with the guidelines is regrettable, but should be balanced against other planning considerations such as the need for regeneration of the site, its role in the overall regeneration of the Canada Water Area and the continuing operation of the Decathlon store, which anecdotally acts as regional attractor to the area. On balance, therefore, it is recommended that the Mayor should not intervene in determining this application, but allow Southwark Council to proceed in granting planning permission in accordance with its resolution of 19 January 2010.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager – Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Glen Rollings, Case Officer 020 7983 4315 email [email protected]

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planning report PDU/2240a/01 6 October 2009 Canada Water Site C in the London Borough of Southwark Planning application no. 09-AP-1783

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

The applicant The applicant is Conrad Phoenix (Canada Water), and the architects are Michael Aukett Associates for phase 1, and Wilkinson Eyre for phase 2.

RecommendationThat Southwark Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 100 of this report; but that the possible remedies set out in paragraph 102 of this report could address these deficiencies.

Context

1 On 27 August 2009 the Mayor of London received documents from Southwark Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 7 October 2009 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make. 2 The application is referable under Categories 1A and 1C of the Schedule to the Order 2008: “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats” and “Development which comprises or includes the erection of a building of one or more

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of the following descriptions – (c) the building is more than 30 metres high and is outside the City of London”.

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

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

5 The site is located to the east of the Canada Water basin and to the west of Surrey Quays Road. The site is 2.23 hectares and is currently occupied by two buildings, both accommodating retail warehouses with associated car parking. The sports goods retailer Decathlon occupies both retail warehouses. The site is bounded by Surrey Quays Road to the north, Albion Channel to the west, Canada Water to the south, and the Surrey Quays Shopping Centre to the east. The A200 Jamaica Road / Rotherhithe Tunnel Approach, part of the Transport for London Road Network TLRN and A200 Lower Road, part of the Strategic Road Network (SRN) are in close proximity. The site has a public transport accessibility level (PTAL) of between 5 and 6 on a scale of 1 to 6, where 6 is most accessible. Canada Water Underground and bus stations are within 300-400 metres, providing access to Jubilee line services and, from 2010, London Overground services on the extended East London Line. A wide range of buses operate in the area.

6 The site is located in the Canada Water regeneration area and is allocated as Site 29P within the Southwark Plan. The allocation sets out that any development should include retail and community/leisure use which would occupy the entire ground floor excluding residential lobbies and access ways and residential uses on upper floors. Office uses are also considered acceptable. No other uses are acceptable. The Plan indicates that the site could be considered for high density development and estimates residential capacity at 580 units.

7 Historically the site and wider area formed part of Surrey Docks and was redeveloped in the 1980s with low density residential and large scale commercial and industrial uses. The area is undergoing significant change with higher density mixed use schemes being developed and the replacement of under-utilised former industrial sites.

8 To the south-east of the site is Harmsworth Quays, a 24-hour newspaper printing works. To the west is Site D. The redevelopment of this site is nearing completion and comprises a series of blocks up to ten storeys in height. To the east, across Surrey Quays Road, is Site E, currently occupied by a retail warehouse but which is the subject of a planning application for a mixed use development. South of Harmsworth Quays, the site presently occupied by leisure facilities is currently the subject of Stage 1 consideration of a mixed use development incorporating student accommodation, housing, new leisure facilities and other uses. To the north-west is Site B, on which residential units are currently under construction, with a new public library to follow.

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Details of the proposal

9 The proposal comprises the demolition of the existing retail sheds and the development of:

• 430 residential flats.

• 9,104 sq.m. retail space to accommodate Decathlon in new premises.

• A further 1,287 sq.m of retail/restaurant space.

• 644 sq.m. of office space.

• 528 sq.m. of leisure/community use.

• Basement car park.

• Communal landscaped amenity space at both ground level and on a podium above the Decathlon store.

10 An indicative breakdown of the residential units is shown below.

Type Social rented Intermediate Market Total % Studio units 1 0 0 1 0.2% 1 bedroom 28 17 124 169 39.3% 2 bedroom 22 22 135 179 41.6% 3 bedroom 15 1 57 73 17.0% 4 bedroom 8 0 0 8 1.9 % Total 74 40 316 430 100% % 17.3% 9.3% 73.4% 100%

11 The development will be phased, with the first phase located to the south of a new boulevard running east-west between the Canada Water basin and the junction of Surrey Quays Road and Canada Street. The second phase is located to the north of the boulevard. This phased approach will allow continued trading by Decathlon.

12 The new 2-storey Decathlon store forms the heart of the development. It is wrapped in single- aspect residential flats on its northern and southern facades. Its eastern facade is wrapped with non-residential uses, including offices for Decathlon. The western facade, on the waterfront, provides the store entrance, Decathlon cafe and restaurant and cafe uses. The roof of the Decathlon unit is at 4th-floor level and provides communal amenity space for the residents of this part of the scheme, and is surrounded by largely dual aspect development rising to between six and ten storeys.

13 The second block in the first phase is located adjacent to the southern site boundary, facing Surrey Quays Shopping Centre. It is seven storeys in height, with retail and restaurant/cafe uses at ground-floor level, and flats both on the ground floor and in the levels above.

14 Phase 2 of the development is made up of residential units, with some ground-floor retail and community/leisure uses on the eastern and western edges. It is formed of three elements, with a four-storey maisonette and flats block located on the Albion Channel (Block A), an apartment block along the length of the boulevard (Block B), terminating at Canada Water basin with restaurant/cafe uses at ground floor and an apartment block following the curve of Surrey Quays

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Road, with non-residential units at ground floor (block C). The blocks range in height from four to nine storeys and surround a residential courtyard.

15 The Decathlon unit will be serviced at ground floor level from an internal service yard, which will be accessed from a new junction on Surrey Quays Road. Car parking for Decathlon and the residential units will be provided at basement level. Case history

16 The two retail warehouses, now occupied by Decathlon, were granted planning permission in the 1980’s. In 2003 an application was made to link the two retail warehouses together and this was refused. In March 2009 the Mayor provided initial comments on an application broadly similar to this one (ref PDU/2240/01), supporting the principle of redevelopment of this site. The application was subsequently withdrawn. Strategic planning issues and relevant policies and guidance

17 The relevant issues and corresponding policies are as follows:

• Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, draft Housing Strategy • Affordable housing London Plan; PPS3; Housing SPG, draft Housing Strategy • Density London Plan; PPS3; Housing SPG • Urban design London Plan; PPS1 Tall buildings/views London Plan; View Management Framework SPG, draft Revised View Management Framework SPG • Child play space Providing for Children and Young People’s Play and Informal Recreation SPG • Retail London Plan; PPS6; PPG13, draft PPS4 • Employment London Plan; PPG4; draft PPS4; Industrial Capacity SPG • Transport London Plan; the Mayor’s Transport Strategy; PPG13 • Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Wheelchair Accessible Housing BPG; Planning and Access for Disabled People: a good practice guide (ODPM) • Climate change London Plan; PPS1, PPS Planning and Climate Change Supplement to PPS1; PPS3; PPG13; PPS22; the Mayor’s Energy Strategy; Sustainable Design and Construction SPG • River Thames/flooding London Plan; Mayor’s draft Water Strategy; PPS25, RPG3B

18 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2007 Southwark Unitary Development Plan and the London Plan (Consolidated with Alterations since 2004).

19 The following are also relevant material considerations: • The Southwark Core Strategy (Pre-Submission Stage). • The Southwark Canada Water Area Action Plan, which is at preferred options consultation stage.

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Principle of land use

20 The site is located within the Canada Water/Surrey Quays Area for Intensification as designated by the London Plan. Policy 2A.6 of the London Plan seeks to exploit the public transport accessibility and potential for increases in residential, employment and other uses in these areas, through the provision of higher density development with more mixed and intensive uses.

21 Policy 5D.3 of the London Plan seeks higher density redevelopment at key transport nodes of good accessibility and in town centres within the Canada Water/Surrey Quays area. The intensification of Canada Water/Surrey Quays therefore focuses on the transport interchange and district shopping centre with significant potential for development of infill and intensification of existing commercial sites. Table 5D.1 of the London Plans identifies that the Canada Water/Surrey Quays area will be able to provide a minimum of 2,000 new jobs and 2,000 new homes by 2026.

22 The proposal involves the demolition of unsightly retail sheds that do not make efficient use of the site, and this approach is supported.

23 The principle of this mixed-use development in this location is generally supported in London Plan policy terms. The development is also in line with Southwark’s planning policies for the area and is broadly in line with the site allocation within the UDP. Housing and affordable housing

24 London Plan Policy 3A.10 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mix-use schemes. In doing so, each council should have regard to its own overall target for the amount of affordable housing provision. Policy 3A.9 states that such targets should be based on an assessment of regional and local housing need and a realistic assessment of supply, and should take account of the London Plan strategic target that 35% of housing should be social and 15% intermediate provision, and of the promotion of mixed and balanced communities. In addition, Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain residential development, and to the individual circumstances of the site. Targets should be applied flexibly, taking account of individual site costs, the availability of public subsidy and other scheme requirements.

25 Policy 3A.10 is supported by paragraph 3.52, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified.

26 The 2007 Southwark UDP set a target of 35% affordable housing in Canada Water, split 70/30 social rented to intermediate housing. An affordable housing toolkit submitted with the previous application demonstrated that only 20% affordable housing option was viable. This was unacceptable to Southwark Council. The revised scheme provides 430 units, of which 114 (26%) will be affordable. The tenure split will be 65% social rented, to 35% intermediate.

27 A financial appraisal, completed by Savills for the applicant, was calculated on the assumption that there would be 100 affordable units. It includes the existing use value and appears to make reasonable assumptions with regards to private sales. The development costs take account of the relatively high value of the existing Decathlon store.

28 The overall assessment is that the proposal would be unlikely to be viable with an affordable housing level of 25%. Discussions between the applicant and Southwark Council have produced the present scheme and updated section 106 package. Dependant on the market values at the time

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of completion the proposal may be able to provide more or less than 26% affordable housing. The intention is to build this proposal in phases over several years, by which time the housing market may have improved. An appropriate solution would be to assess the viability of the provision of affordable housing on commencement of each phase, the mechanism for which can be secured through the section 106 agreement.

29 This option prevents the applicant agreeing to provide a percentage of affordable housing that cannot be realistically delivered, and ensures the proposal complies with London Plan policy to provide the maximum reasonable amount of affordable housing should the market improve during the lifetime of the permission and construction.

30 The Mayor’s Housing SPG provides a London wide target for the mix of unit sizes within developments. The table below compares the proposed mix of units against the targets within the SPG.

Overall Social rented Intermediate Market SPG Scheme SPG Scheme SPG Scheme SPG Scheme 1 bed 32% 39% 19% 40% 66% 42% 25% 39% 2/3 bed 38% 59% 39% 50% 0% 58% 75% 61% 4 bed + 30% 2% 42% 10% 34% 0% 0 0%

31 The London Plan housing SPG sets a target that 30% of all units should be family units. The housing mix includes 19% family size units; 32% of the social rented units would be family size units. The London Plan housing SPG and the draft housing strategy sets a target that 42% of all social rented units should be family units. The proposal has a high proportion of one and two–bed units and provides a disappointing number of family sized units. As such consideration should be given to increasing the number of family size units in the scheme. Density

32 London Plan policies 4B.1 and 3A.3 outline the need for development proposals to achieve the highest possible intensity of use compatible with local context, the design principles of the compact city, and public transport accessibility. Table 3A.2 of the London Plan provides guidelines on density in support of policies 4B.1 and 3A.3.

33 Using the Southwark Plan formula for calculating density of mixed-use developments the density of the proposed development is 755 habitable rooms per hectare (hr/ha), which is a slight decrease compared with 775 hr/ha in the previous scheme. This density is within the levels set out in the London Plan density matrix for accessible sites, such as this one. This density is acceptable in strategic policy terms. Urban design

37 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B which address both general design principles and specific design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, the quality of new housing provision, tall and large-scale buildings, built heritage, views, and the Blue Ribbon Network.

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38 The applicant has not submitted an analysis of the potential impact on designated views. Whilst the proposal would sit someway to the north of the protected viewing corridors from Greenwich and Blackheath to St Paul’s Cathedral the applicant should demonstrate that the building would accord with the relevant London Plan policies and supplementary guidance set out in the London View Management Framework. The applicant has stated that it does not consider this to be necessary, as the site “lies some distance from the viewing corridor, and thus there is no reasonable prospect of an effect”. Nonetheless, the site is within the middle ground of the view corridors and care must be taken to ensure compliance with the framework. Specifically, the applicant should submit a Qualitative Visual Assessment of the appearance of the proposal in these views to demonstrate that this would comply with the relevant London Plan policies. Until this assessment is submitted the proposal is considered to be inconsistent with London plan policies 4B.14, 4B.16, 4B.17 and 4B.18, and therefore also inconsistent with policies 4B.1 and 4B.10.

39 This generally well considered high density housing scheme has been informed by the Canada Water Masterplan and the introduction of a variety of building forms and open spaces across the site is supported. The height and scale proposed is appropriate to the location, as is the variation in scale across the site, which adds to the visual interest of the scheme and responds well to its context.

40 The street layout is well integrated with the surrounding street and route network. Of particular importance is the access alongside the Canada Water basin and Albion Channel, and the proposal provides good access and a pleasant environment along these. The new route between the existing road intersection and the basin is welcomed, and while it is unfortunate that cross-site permeability is somewhat constrained by the large footprint of the proposed Decathlon store, there will be a much greater level of permeability than exists at present.

41 The majority of the ground floor comprises active uses including small local retail units and residential flats. All ground floor flats have outdoor private amenity areas to separate them from the public realm, including the sole studio apartment within the proposal. All flats on other floors have private amenity space. Flat cores punctuate the street frontages at regular intervals and should ensure regular pedestrian activity along the streets making them more secure. The efforts to ensure that there is active frontage around all external sides of the Decathlon store is particularly welcomed.

42 There is clear definition between public and private space across the site and there is sufficient space to provide for a high quality living environment.

43 The flats comprise a mixture of single and dual aspect units. Some of the single aspect units face predominantly north and the applicant has tried to address this issue by providing the units with openings to their flank elevations and generous balcony spaces, which are welcome aspects of the scheme. All of the flats have reasonably generous balcony and terrace provision and the mix of flats includes some larger 4-bedroom maisonette flats.

44 The external articulation and treatment of facades is of a good quality and responds well to the aspirations for the area set out in the Canada Water masterplan. The use of different architects for the two phases of the scheme, with a common palette of materials, ensures that there is sufficient variation in treatment across the site to provide interest and character.

45 The success of the proposal will be dependant on the use of high quality materials and detailing to both the building and landscaping. The use of robust materials and high quality finishes should be secured by condition to ensure the proposal would have a positive impact on the surrounding townscape.

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46 In summary, the proposal is generally consistent with relevant London Plan design policies, but is not currently supported by the necessary assessment of its impact on the protected views from Greenwich and Blackheath to St Paul’s Cathedral. Until this assessment is submitted the proposal is considered to be inconsistent with London plan policies 4B.16, 4B.17 and 4B.18, and therefore also inconsistent with policies 4B.1 and 4B.10. The applicant should address this before the scheme is referred back to the Mayor. Children’s play space

47 Policy 3D .13 of the London Plan sets out that “the Mayor will and the boroughs should ensure developments that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 97 children within the development. The guidance sets a benchmark of 10 sq.m of useable child playspace to be provided per child, with under-5 child playspace provided on-site. As such the development should make provision for 970 sq.m of play space.

48 This development includes 11,100 sq.m of communal amenity space of which 555 sq.m incorporates playable elements and 30 sq.m is dedicated play space. A large amount of open space is located close to the development at Russia Dock Woodland/Stave Hill Ecological Park, King George Field and Southwark Park. The applicant is also proposing a financial contribution of £61,889 for open space, £17,925 for children’s play equipment and £302,508 for sports development. A contribution of £61,889 to help address district park deficiency is also proposed. This approach is acceptable. Retail and employment

49 The development will be phased to allow the existing Decathlon store to continue trading. The retail impact assessment submitted with the application recognises the London Plan’s designation of the area as an area for intensification, and an increase in retail space connected with the consolidation of Decathlon’s trading facilities, as well as some smaller retail holdings. It also notes the closure of the existing retail warehouse on Site E; no similar use is proposed in that site’s redevelopment.

50 The new retail and office uses are well serviced from public realm and have clear separation from the other uses within the scheme, avoiding ambiguity. The proposals will strengthen the strategic function of the Canada Water / Surrey Quays area and are in compliance with the London Plan.

Transport (Transport for London comments)

Trip generation and transport impact

51 As raised with the previous application, TfL considers the trip generation and modal split to be unacceptable and not representative of current travel patterns in the Canada Water area as these are based on outdated surveys. The mode split should be recalculated based on sites which are more representative of this development. Further details of the proposed retail uses should also be provided to support the developer’s assumption that there will be no external trip generation.

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52 TfL also considers the transport impact assessment to be unacceptable, particularly for the Jubilee line and buses, as they are not based on accurate service patterns and the network assignment is not realistic. In order to comply with London Plan policy 3C.2 Matching development to transport capacity, further work is needed on the above, along with a revised assessment of the cumulative impacts of planned/proposed development which should include Surrey Quays Leisure Site; additional information about this will be sent to the developer. An assessment of Canada Water Underground station’s ability to accommodate the expected increase demand as a result of this development as well as cumulative developments is also necessary; London Underground’s Station Planning Standards and Guidance should be used as the basis for this assessment.

Car parking and management

53 A total of 147 car parking spaces have been proposed for the residential element of the proposal (including 45 disabled, 5 car club, and 1 electric vehicle space), which equates to 0.34 spaces per unit and represents an increase in the level of parking from the previous application. This is significantly higher than the level of provision (circa 0.25 spaces per unit) associated with other developments in the area and is in excess of the maximum level set out in the draft Canada Water Area Action Plan (AAP). Furthermore, TfL expects the provision of a number of electric vehicle charging points in line with the Mayor’s essential standard set out in the Sustainable Design and Construction SPG.

54 TfL considers that this over-provision of car parking could undermine the use of more sustainable modes, given the site’s excellent access to public transport, and would contribute towards the overall traffic congestion in the wider Rotherhithe area. In order to be considered compliant with London Plan policy 3C.23 Parking strategy, the level of residential car parking must be reduced; TfL also requests that the council restrict occupiers of the development from future eligibility for car parking permits.

55 A total of 193 car parking spaces (12 of which are disabled spaces) are proposed for the non-residential elements, which is within maximum London Plan standards. Given the bulky nature of some goods sold at Decathlon, TfL accepts this level of retail parking provided that these spaces are made available to all users as town centre car parking, in line with London Plan planning policies and the overall aspirations for the Canada Water area as set out in the draft AAP. However, the proposed management of the car park does not appear to make these spaces fully available as town centre parking and therefore cannot be considered compliant with London Plan policy 3C.23 Parking strategy. Further discussions regarding this car parking are required to ensure the most efficient use of car parking and avoid unnecessary over-provision in the Canada Water area; appropriate provision for use as town centre parking will need to be secured as part of any planning permission.

Cycling and walking

56 A total of 473 cycle parking spaces (of which 430 are in basement cycle parks and 43 would be at surface-level for visitors) are proposed for the residential element, which equates to 1.1 spaces per unit and is in line with TfL’s cycle parking standards. The means of access, layout, and parking areas for cyclists must be secure and not be prohibitive to use. Further information is needed.

57 In relation to the non-residential uses, a total of 64 cycle parking spaces have been proposed (of which 32 would be located in the retail car park and 32 at surface level). Although this is within TfL cycle parking standards, a minimum of 36 sheltered and secure spaces are required for the Decathlon store staff and a minimum of 28 spaces are also required for the other

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retail and office staff. All staff cycle parking must be sheltered and secure, and should be provided within secure internal areas; showering and changing facilities should be provided where possible.

58 Additional cycle parking for visitors to the site is necessary and should be conveniently sited at grade in various locations around the development. TfL notes that the existing visitor cycle parking for Decathlon visitors is well used and a significant amount should be provided for this use.

59 TfL expects the level of staff cycle parking provision and visitor spaces to be increased and suitably provided in order to comply with London Plan policy 3C.22 Improving conditions for cycling. Additional details on the location, type, access routes, and security arrangements are required.

60 The improvements to pedestrian routes and facilities are generally welcomed, although the number and location of pedestrian crossings have not been considered holistically with other emerging developments. In order to ensure a joined-up approach to the provision of pedestrian facilities, TfL expects an appropriate planning condition to be agreed concerning the location and design of the proposed pedestrian crossings.

61 The site should have greater integration with TfL’s Strategic Walk Network, which runs around the peninsula; potential connections and improved signage within the site should be further investigated and funded by the developer. TfL also seeks a contribution of £7,000 for improvements to the Strategic Walk Network in the vicinity of the site. This will ensure compliance with London Plan policy 3C.21 Improving conditions for walking.

Buses & London Underground

62 Additional capacity and new bus links will be required on the bus network in the Canada Water area as a result of this and other forthcoming developments in the area. Subject to the results of the additional work required on the trip generation and modal split, TfL considers that at least one additional return journey between Canada Water to the City in the AM peak will be required as a result of this development. To provide this additional capacity, TfL will require a Section 106 contribution of £90,000 per year for 3 years (total of £270,000). In addition TfL requests a minimum contribution of £27,000 towards improvements to Canada Water bus station; this level of contribution is comparable with those agreed from other developments in the area.

63 Further details are required concerning the impact on and potential relocation of any bus stop. Prior to any agreement with TfL on the relocation of this stop, the developer must provide drawings showing the relocated stop, the design of which must comply with the TfL technical advice note Accessible bus stop design guidance (BP1/06, January 2006) and be agreed by TfL.

64 TfL remains concerned about the likely delays to bus services resulting from the introduction of zebra crossings on Surrey Quays Road and raised tables on Surrey Quays Road. In line with TfL’s Bus Priority Team technical advice note BP2/05, any other pedestrian crossings over Surrey Quays Road should be kept at grade to reduce delays, damage and risk of passenger injury. Measures should also be taken to ensure that any landscaping proposals complement highway safety and operation. Overall, TfL considers that the current proposals do not comply with London Plan policy 3C.20 Improving conditions for buses and further discussion is required.

65 TfL is concerned that the increased density of development on this site in conjunction with other developments in the area may create an unacceptable level of demand for public transport, particularly at Canada Water Underground station and on the Jubilee line. The assessment of the cumulative impact on the Jubilee line needs to be revised and the cumulative impact assessment should be updated to reflect the existing situation. At this stage, TfL considers that the current

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proposals do not comply with London Plan policy 3C.2 Matching development to transport capacity. Further discussion is required.

Servicing, construction, and travel planning

66 TfL welcomes the developer’s intention to prepare a servicing management strategy and a construction management plan; these will need to be secured as part of the Section 106 agreement. TfL recommends that storage space, including cold storage facilities, be provided within the concierge in order to allow the on-site management to accept deliveries on behalf of residents. All construction access routes and access details need to be approved by TfL prior to the commencement of any works due to the potential impacts on buses and the nearby TLRN and SRN. This will help to ensure compliance with London Plan policies 3C.17 Tackling congestion and reducing traffic and 3C.25 Freight strategy.

67 A framework travel plan has been prepared but is of poor quality and content, with virtually no measures and no commitments to achieve or deliver any element of the travel plan. TfL considers that this travel plan fails to provide any commitment or confidence that efforts will be made to deliver modal shift and travel demand management, and therefore cannot be considered compliant with London Plan policy 3C.3 Sustainable transport in London. Further detailed comments on the travel plan will be sent to the developer. An improved travel plan should be produced prior to the Mayor considering this again at Stage 2. The final travel plan should be secured, monitored, reviewed, and enforced through the Section 106 agreement.

Section 106

68 Subject to the results of the revised trip generation and modal split analysis as required above, TfL requests the following:

• £90,000 per year for 3 years towards bus capacity improvements (total of £270,000) • £27,000 towards improvements at Canada Water bus station • £7,000 towards improvements to TfL’s Strategic Walk Network. 69 This is in addition to any transport requirements the council may have or any further mitigation which may be necessary as a result of the requested further analysis.

Conclusion

70 In summary, a number of issues must be fully addressed in order to comply with London Plan policies and mitigate the transport impacts of the development. These include further work on trip generation, modal split, and transport impact; car and cycle parking levels and management; improvements to the travel plan; and transport impact mitigation. Access

71 100% of the units in Phase 1 and 90% of the units in Phase 2 meet ‘Lifetime Homes’ standards and 10% in each phase are wheelchair accessible. Some gradients serving residential core entrances are proposed as more than 1 in 20 and it is recommended that these grades are lessened to enable better wheelchair access.

Climate change mitigation

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72 The London Plan requires developments to make the fullest contribution to the mitigation of, and adaptation to climate change, and to minimise carbon dioxide emissions (Policy 4A.1).

73 Policies 4A.2 to 4A.8 of the London Plan focus on how to mitigate climate change, and the carbon dioxide reduction targets that are necessary across London to achieve this. Developments are required to be adaptable to the climate they will face over their lifetime and address the five principles set out in policy 4A.9 of the London Plan.

Energy

74 The applicant has broadly followed the energy hierarchy in Policy 4A.1. Sufficient information has been provided to understand the proposals as a whole and to verify carbon dioxide savings in principle. However, further information is required to fully assess the proposal.

75 The baseline emissions for the development have been calculated using a combination of modelling for the residential and non-domestic elements. The total baseline emissions are estimated to 1,715 tonnes of carbon dioxide per annum.

76 In order to model the energy consumption and associated carbon emissions for the residential element SAP 2005 has been used. A series of representative flats have been modelled that are naturally ventilated. The residential element part of the total emissions is 872 tonnes per annum. For the non-domestic element the energy consumption and related carbon emissions have been calculated using approved software. The non-domestic element part of the total emissions is 842 tonnes.

77 The applicant has taken into account the carbon emission from non-regulated energy usages, i.e. appliances and equipment, which is in line with the requirements of the London Plan.

78 The applicant has proposed a series of demand reduction measures that intend to reduce carbon emissions beyond the baseline emissions. Measures proposed include daylight sensors and low energy lighting, more stringent insulation and air tightness standards than those required by current building regulations. The domestic and small retail elements will be naturally ventilated and the Decathlon store will be mechanically ventilated.

79 The reduction for the domestic elements will be 11% over its baseline emissions and for the non-domestic elements it will be 24%. Overall it will be a 17% reduction over the development’s baseline emissions including non-regulated energy use.

District heating

80 The strategy suggests that a communal heating network would supply the dwellings, however it is not clear whether all non-domestic use would also be connected. The applicant should confirm that all heat demands are met through the communal heating.

81 It is recognised by the applicant that a district heating scheme is being investigated for the area, supplied by the SELCHP waste incineration plant and if this goes ahead it will be the preferred option for heating provision. Should it be possible to connect to the district heating scheme the estimated carbon savings will be 31%.

82 There is an Area Action Plan developed for the area and the applicant should investigate this and put the energy strategy within this context. Consideration has also been taken for the possibility of connecting to the Canada Water site E. This is supported and should be investigated further. Also, exploring the possibility of connecting to site B which already will incorporate an energy centre that will link site A and B together would be welcomed, although it is recognised

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that the canal divides the two sites. In addition the Leisure Park redevelopment site should be considered for linking heat networks.

83 The applicant should provide information regarding the proposed energy centre, such as number of energy centres, location and that sufficient space has been allocated for the proposed equipment.

Combined Heat and Power

84 The proposals include combined cooling heat and power, CCHP, for supplying part of the domestic hot water, heating and cooling demands with a capacity of 340 kW electric output. It is unclear how the CHP has been sized and the applicant should clarify this.

85 The carbon dioxide reduction due to CCHP would be a further 30% over and above the reductions due to energy efficient design.

86 Cooling would be supplied partly by the CCHP system and partly by electric chillers. The carbon dioxide reduction is included within the CHP reductions. The applicant has briefly considered linking the communal heat networks at site C and site E. The applicant should also investigate linking the cooling networks.

Renewable energy technologies

87 The proposals include 1,410sq.m. of photovoltaic panels with 100 kW electric output, which would further reduce the carbon dioxide emissions by 5%. Further information about the location of the panels is required.

88 The renewable technology chosen is appropriate for the development, subject to areas having a southern component and not subject to major shading. Climate change adaptation

89 The London Plan promotes five principles in policy 4A.9 to promote and support the most effective adaptation to climate change. These are to minimise overheating and contribute to heat island effects; minimise solar gain in summer; contribute to flood risk reduction, including applying sustainable drainage; minimising water use; and protect and enhance green infrastructure. Specific policies cover overheating, living roofs and walls and water.

90 In line with policy 4A.10 of the London Plan particular attention should be paid to use of passive design and natural ventilation. The Code for Sustainable Homes pre-assessment report predicts that code level 4 will be achieved.

91 Policy 4A.14 of the London Plan seeks to ensure that surface water run-off is managed as close to its source as possible, and sets out a hierarchy of preferred measures to achieve this. Policy 4A.11 seeks major developments to incorporate living roofs and walls where feasible. Policy 4A.16 of the London Plan seeks to ensure that new development has proper regard to the impact on water demand and existing capacity by minimising the use of treated water and maximising rainwater harvesting opportunities. Roof runoff will be used for watering the public amenity space within the site.

92 The applicant proposes several green and brown roofs. Other provisions within the development include grey water recycling and the fitting of low flow appliances. Flood risk

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93 The site lies within Flood Zone 1 of the defended Thames floodplain, which would not ordinarily require a flood risk assessment. However as the site is larger than a hectare, a full flood risk assessment was carried out for the previous application, in accordance with Planning Policy Statement 25. The assessment remains valid for the present application.

94 The greatest source of potential flooding on site is tidal flooding from the River Thames. With the exception of four surveyed heights at the north-west corner of the site all levels of the site are higher than the 1 in 1000 flood level adjusted to take account of climate change. In addition ground levels in the surrounding area of Rotherhithe are higher than the modelled tidal flood water levels in the River Thames and as such the site is not expected to flood even in the event of catastrophic failure of the flood defences. In any case the building levels will be 6m above the expected flood level in the case of failure of the flood defences.

95 Groundwater flooding is not considered a significant source of potential flooding due to the ground condition in Rotherhithe as well as the extent of urbanisation in the area.

96 The development will result in an increase in permeable ground cover on site and as such a reduction in surface water runoff is expected.

97 The development complies with London Plan policy in this regard. Legal considerations

98 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application. Financial considerations

99 There are no financial considerations at this stage. Conclusion

100 London Plan policies on the principle, housing, affordable housing, density, urban design, children’s play space, retail and employment, access, affordable housing, child play space, climate change and transport are relevant to this application.

• Principle of land use: The principle of the development of this site for a mixed use development complies with London Plan policy. The intensification of the use of this currently underutilised site is welcomed.

• Housing and affordable housing: The viability assessment supports the proposed provision, although provision could be increased with a phased section 106 agreement. The mix of dwelling sizes does not comply with London Plan policy, owing to an under- provision of family sized units. • Density: The proposed residential density is within the guidance range contained in table 3A.2. As a result, the proposal complies with policies 4B.1 and 3A.3 of the London Plan.

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• Urban design: The proposal is broadly consistent with relevant London Plan design policies, but is not currently supported by the necessary assessment of its impact on the protected views from Greenwich and Blackheath to St Paul’s Cathedral. Until this assessment is submitted the proposal is considered to be inconsistent with London plan policies 4B.16, 4B.17 and 4B.18, and therefore also inconsistent with policies 4B.1 and 4B.10.

• Children’s play space: There is a shortfall in the level of on-site provision, which does not comply with the benchmark set in the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’. The applicant is proposing mitigation measures including contributions to nearby off-site improvements, which are considered to be acceptable.

• Retail and employment: The applicant has identified that there is a need for this development and it has been concluded that the increase in floorspace is appropriate for this centre. As such the application complies with the London Plan in this regard.

• Transport: TfL has a number of key concerns relating to the development proposals and requires significant further work and information before this application could be considered acceptable in London Plan policy terms.

• Access: The proposal has been designed to be accessible for everyone. As a result the proposal complies with policy 3A.5 of the London Plan. However, the proposal would benefit from the revision of ramp gradients to ensure better wheelchair accessibility.

• Climate change mitigation: The application broadly complies with the London Plan energy hierarchy however further information needs to be submitted before it can be concluded that the application fully complies with the London Plan in this regard.

• Climate change adaptation: The application complies with the London Plan in this regard. • Flood risk: The application complies with the London Plan in this regard.

101 On balance, whilst the application conforms generally to the London Plan, its fails to secure compliance in several regards.

102 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

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• Climate change mitigation: The applicant should provide information regarding the proposed energy centre, such as number of energy centres, location and that sufficient space has been allocated for the proposed equipment. The applicant should also investigate linking the cooling networks.

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