planning report GLA/3757a/01 21 January 2019 Station Square in the Royal Borough of Greenwich planning application no. 18/4187/F

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

The proposal A full application comprising 619 residential units, 1,174 sq.m. of office space, 580 sq.m. of retail space, and a 309 sq.m. nursery, within eight buildings of 9 to 20 storeys; a new bus station interchange; and two new public spaces.

The applicant The applicant is Kidbrooke Partnership LLP (a joint venture bewteen Notting Hill Genesis and Transport for London), and the architect is Glenn Howells.

Strategic issues Principle of development: The principle of a high density, residential led, mixed use scheme, which includes retail, small business space, and social infrastructure is strongly supported in line with the London Plan and the draft London Plan. Affordable housing: The applicant proposes 51% affordable housing, made up of 55% London Affordable Rent and 45% shared ownership, which meets the requirements for the fast track route and is supported. Affordability thresholds and an early stage viability review must be secured in the section 106 agreement attached to any permission. Urban and inclusive design: The proposals are generally of a high design quality, with good residential quality; subject to further information on the existing footbridge, boundary treatments, and private amenity space. Inclusive access requirements should be secured by condition. Historic environment and strategic views: The proposals would cause ‘less than substantial’ harm to the character and appearance of the Blackheath Conservation Area and the setting of listed buildings within it; however, the public benefits of the scheme outweigh this harm. Transport: Further information is required on cycle parking. Climate change: Further information is required on the energy strategy, the surface water drainage strategy, and water consumption targets.

Recommendation That Greenwich Council be advised that the application does not yet comply with the London Plan and the draft London Plan, for the reasons set out in paragraph 80 of this report; but that the possible remedies set out in that paragraph could address these deficiencies.

page 1 Context

1 On 6 December 2018, the Mayor of London received documents from Greenwich 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 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan and the draft 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, 1B(c) and 1C(c) of the Schedule to the Order 2008: • Category 1A “Development which comprises or includes the provision of more than 150 houses, flats or houses and flats; • Category 1B(c) “Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises the erection of a building or buildings outside Central London and with a total floorspace of more than 15,000 square metres; • Category 1C(c) “Development which comprises or includes the erection of a building that is 30 metres high and is outside the ”.

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

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

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

6 The 1.7 hectare site lies directly north of Kidbrooke Station, bounded by the railway line to the south, the A2213 (Kidbrooke Park Road) to the north and west, and the A2 (Rochester Way Relief Road) to the east. The brownfield site mainly comprises scattered scrub and woodland, but also includes the locally adopted Henley Cross highway, which provides access to the Henley Cross bus terminal within the site, and the northern entrance of Kidbrooke Station.

7 The wider area is characterised by a mix of residential, commercial, educational and community uses. Kidbrooke Village lies to the south (see below). To the north is a large retail shed with residential beyond, warehousing/distribution units, allotments and a secondary school (). To the east is the new National Maritime Museum storage facility, with more residential use beyond.

8 The site falls within the outline Kidbrooke SPD masterplan, approved in June 2009 for renewal of the Ferrier Estate (GLA Ref: PDU/2245). Within this, Kidbrook Village to the south of the site is coming forward in six phases and once complete, will deliver 4,882 new homes, and the majority of a local town centre. Berkeley Homes is currently implementing Phase 3, which includes the ‘Kidbrooke Village Centre’ directly south of Kidbrooke Station, and 1,354 residential units in seven buildings of up to 21 storeys. In October 2018, full planning permission (LPA Ref: 18/2904/F) was granted for the new Kidbrooke Station immediately to the south of the site.

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9 The site is draft allocation K1 in the Councils’ Issues and Options Consultation Draft Site Allocations Local Plan (2016), identified for the Kidbrooke Station interchange, local town centre, and housing.

10 The A2 Rochester Way Relief Road and the A2213 Kidbrooke Park Road form part of the Transport for London Road Network (TLRN). The nearest part of the Strategic Road Network (SRN) is the A206, Woolwich Road, situated approximately 2.7 kilometres to the north. Kidbrooke Station is located directly south of the site and is operated by Southeastern Railway, and North Greenwich Underground station is located 4.5 kilometres to the north. There are 3 bus stops within 150 metres of the site, including a bus stand at Henley Cross within the site. TfL’s WebCAT software indicates that the site records a public transport accessibility level (PTAL) of 3 (moderate), on a scale of 0-6b, where 6b is the highest.

Details of the proposal

11 A full planning application for a comprehensive development comprising 619 residential units, 1,174 sq.m. of office space, 580 sq.m. of retail space, and a 309 sq.m. nursery, within eight buildings of 9 to 20 storeys. A new bus station interchange is proposed within ‘Station Square’ to the west of the site, which is the focus for non-residential uses at ground floor level as part of the new local centre, with a residential square to the east. A shared surface route connects Station Square to the residential square. Case history

12 On 2 May 2018, a pre-planning application meeting was held at City Hall for a “residential-led mixed use development of circa 600 new homes, commercial ground floor uses (Use Classes A1-A4 and D1-D2), a hotel (Use Class C1), public realm, bus stops and facilities and station access in an improved transport interchange; and improved pedestrian and cycle access”. On 25 June 2018, a pre-application advice note was issued, which concluded that the principle of the proposed scheme was supported; however, more family sized London Affordable Rent units were requested, some design concerns were raised, and further work was required in relation to climate change and transport issues.

13 On 12 September 2018, a further pre-application meeting was held for a “residential led mixed-use development within 8 buildings of up to 24 storeys, comprising 651 residential units (50% affordable housing, 49% affordable rent, 51% shared ownership); 564 sq.m. of retail/commercial space and 874 sq.m. of workspace; public realm, including Station Square and a smaller residential square to the east; and an improved transport interchange, incorporating new station access, two bus stops and three bus stands”. On 1 October 2018, a pre-application advice note was issued, which concluded that the principle of development of the site, including 50% affordable housing, was strongly supported; however, there were concerns about the impact of the surrounding roads on residential quality, including air quality; and heritage concerns arising from the height of the two tallest buildings.

Strategic planning issues and relevant policies and guidance

14 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 Greenwich Core Strategy and Development Management Policies Development Plan Documents (2014), and the 2016 London Plan (Consolidated with Alterations).

15 The following are also relevant material considerations:

page 3 • The National Planning Policy Framework 2018 and National Planning Practice Guidance. • The draft London Plan 2017 and the Mayor’s Minor Suggested Changes, which should be taken into account on the basis explained in the NPPF. • In August 2017, the Mayor published his Affordable Housing and Viability Supplementary Planning Guidance. This must now be read subject to the decision in R(McCarthy & Stone) v. Mayor of London. • Royal Greenwich Local Plan: Site Allocations, Issues and Options Consultation (February 2016). • The Kidbrooke Development Area Supplementary Planning Document (SPD) (2008).

16 The relevant issues and corresponding policies are as follows: • Employment London Plan; draft London Plan • Town centres London Plan; draft London Plan; Town Centres SPG • Social infrastructure London Plan; draft London Plan; Social Infrastructure SPG • Housing London Plan; draft London Plan; Housing SPG; Housing Strategy; Shaping Neighbourhoods: Play and Informal Recreation SPG; Shaping Neighbourhoods: Character and Context SPG • Affordable housing London Plan; draft London Plan; Housing SPG; Housing Strategy; Affordable Housing and Viability SPG • Urban design London Plan; draft London Plan; Shaping Neighbourhoods: Character and Context SPG; Housing SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG; Accessible London: achieving an inclusive environment SPG • Transport London Plan; draft London Plan; Transport Strategy • Climate change London Plan; draft London Plan; Sustainable Design and Construction SPG; Environment Strategy

Principle of development

17 London Plan Policy 2.13 states that development proposals within intensification areas should seek to optimise residential and non-residential densities and support the policy directions set out in Annex 1 of the London Plan. Map 2.4 of the London Plan identifies Kidbrooke as an intensification area and Annex 1 sets the policy direction for development, in particular how development will be integrated with the station, provide improved bus links to surrounding area, with capacity for at least 4,400 homes.

18 The Council’s Core Strategy identifies the site as within the Kidbrooke Strategic Development Location, being appropriate for significant growth. The Kidbrooke Development Area SPD identifies that the site is to be developed for a residential-led mixed use development, which includes a mix of residential use and open space. The site is draft allocation K1 in the Councils’ Issues and Options Consultation Draft Site Allocations Local Plan (2016), which identifies the site for the Kidbrooke station interchange, local town centre, and housing.

Residential

19 London Plan Policy 3.3 ‘Increasing Housing Supply’ recognises the pressing need for new homes in London and Table 3.1 gives an annual monitoring target of 2,685 new homes per year in Greenwich between 2015 and 2025. Policy H1 ‘Increasing Housing Supply’ and Table 4.1 of the draft London Plan sets Greenwich an increased annualised average housing completion target of 3,204 units per year between 2019/20 and 2028/29. The proposal to introduce

page 4 residential use to this vacant site responds positively to London Plan and draft London Plan policies to increase housing supply and optimise sites and is strongly supported.

Employment, town centre uses, and social infrastructure

20 London Plan Policy 4.7 ‘Retail and town centres’, and draft London Plan Policy SD8, take a town centres first approach for town centre uses.

21 London Plan Policy 4.2 and draft London Plan Policy E1 ‘Offices’ support new office space of different sizes. Policy E2 ‘Low-cost business space’ of the draft London Plan supports the provision of low-cost B1 business space to meet the needs of micro, small and medium-sized enterprises.

22 London Plan Policy 3.16 ‘Social infrastructure’, and draft London Plan Policy S1, seek to protect and enhance social infrastructure provision.

23 The proposal includes 1,174 sq.m. of office space in eight units, targeted at SME occupants; 580 sq.m. of retail space; and a 309 sq.m. nursery, most of which is focused around the proposed Station Square, within the northern part of the new local centre. The level of small business space is broadly in line with that identified in the Kidbrooke SPD. The applicant proposes that the office units will have target rental levels below the Borough average, which is welcomed, and should be appropriately secured within the section 106 agreement.

24 During pre-application discussions, an under-provision of social infrastructure was identified by GLA officers compared to that originally envisaged in the Kidbrooke SPD, and the Council specifically identified a local need for nursery space. This is reflected in the applicant’s Environmental Statement, which finds that provision of social infrastructure is generally good, apart from nursery space. GLA officers agree with this assessment. The application therefore incorporates a nursery with capacity for 70 children, which goes beyond that expected to be generated by the application proposals, which is welcomed.

25 The proposals include a good spread of non-residential uses, which will provide active uses to the surrounding public realm; are focused within the new local centre; are not excessive in scale; and are broadly in line with the SPD and the emerging site allocation. The uses are supported.

Transport infrastructure

26 London Plan Policy 6.2 and draft London Plan Policy T3 seek to safeguard existing transport functions and improve bus infrastructure.

27 The existing Henley Cross bus terminal on the site will be re-provided with an improved quality, and increased capacity for future expansion from the present single decker, single route service; providing accessibility to North Greenwich tube station, Woolwich and transport interchanges, which is supported.

Principle of development - conclusion

28 Overall, the principle of a high density, residential led, mixed use scheme, which includes retail, small business space, and social infrastructure as part of a new local centre, is strongly supported in line with London Plan, draft London Plan, and local policies.

page 5 Housing

29 The table below shows the proposed residential mix and tenures:

Market Sale Shared ownership London Affordable Rent Total Studio 28 0 0 28 (5%) 1 bed 107 81 56 244 (39%) 2 bed 157 75 54 286 (46%) 3 bed 18 1 42 61 (10%) Total 310 157 152 619 51% (hab rm)

Affordable housing

30 London Plan Policy 3.12 ‘Negotiating Affordable Housing’ seeks to secure the maximum reasonable amount of affordable housing. Policy H5 ‘Delivering affordable housing’ of the draft London Plan and the Mayor’s Affordable Housing and Viability SPG set a strategic target of 50% affordable housing. Policy H6 ‘Threshold approach to applications’ identifies a minimum threshold of 35% (by habitable room) affordable housing, whereby applications providing that level of affordable housing, with an appropriate tenure split, without public subsidy, meeting other relevant policy requirements and obligations to the satisfaction of the borough and the Mayor, as well as investigating grant funding, can follow the ‘fast track route’ set out in the SPG. This means that they are not required to submit a viability assessment or be subject to a late stage viability review. Policy H7 of the draft London Plan and the Mayor’s Affordable Housing and Viability SPG sets out a preferred tenure split of at least 30% low cost rent, with London Affordable Rent as the default level of rent, at least 30% intermediate (with London Living Rent and shared ownership being the default tenures), and the remaining 40% to be determined in partnership with the local planning authority and the GLA.

31 The Mayor’s Affordable Housing and Viability SPG identifies a threshold for the fast track route of 50% affordable housing for schemes on public land, which is also included in the draft London Plan. This recognises the potential for development on surplus public sector land to make a higher contribution to affordable housing delivery than private land. This threshold applies on this site as the site comprises public land.

32 The application proposes 51% affordable housing (by habitable room), made up of 55% London Affordable Rent, and 45% shared ownership, which meets the requirements for the fast- track route and is supported. The proposal meets Greenwich’s affordable homes policy requirement on the basis of 35% affordable housing with a split of 70% London Affordable Rent and 30% shared ownership; with the remaining 16% affordable housing to make 51% overall, provided as shared ownership.

33 The affordability of intermediate shared ownership units must be in accordance with the Mayor’s qualifying income levels, as set out in the Mayor’s Affordable Housing and Viability SPG, and the London Plan Annual Monitoring Report, including a range of income thresholds. The applicant has provided indicative income ranges of up to £55,000 for one-bed units and up to £75,000 for two-bed units. Affordability thresholds must be secured in the section 106 agreement attached to any permission.

page 6 34 The requirement for an early stage viability review must be included in the section 106 agreement, to be triggered if an agreed level of progress on implementation is not made within two years of any permission being granted, in accordance with Policy H6 of the draft London Plan and the Mayor’s Affordable Housing and Viability SPG.

Housing choice

35 London Plan Policy 3.8 ‘Housing Choice’ encourages a choice of housing based on local needs, while affordable family housing is stated as a strategic priority. Policy H12 ‘Housing size mix’ of the draft London Plan states that boroughs should not set prescriptive dwelling size mix requirements for market and intermediate homes; and for low cost rent, boroughs should provide guidance on the size of units required to ensure housing meets identified needs.

36 The market and shared ownership units provide mainly one and two bed units, which is supported in this location in close proximity to the Station, and allows the shared ownership units to offer better affordability. The affordable rent tenure includes family-sized units of 28% by unit, and 43% by habitable room, which represents a considerable increase on the 15% by habitable room proposed at pre-application stage and is supported.

Children’s play space

37 London Plan Policy 3.6 and Policy S4 of the draft London Plan seek to ensure that development proposals include suitable provision for play and recreation, and incorporate good- quality, accessible play provision for all ages, of at least 10 square metres per child, with further detail provided in the Mayor’s ‘Shaping Neighbourhoods: Play and Informal Recreation’ SPG.

38 The GLA child yield calculator provides an estimate of 182 children, requiring 1,820 sq.m, of play space. The proposal includes this amount of play space for all age ranges spread across the site, within the podium level residents’ spaces, and within the public realm. The location of play space has been moved away from surrounding roads as a result of pre- application discussions, which is welcomed in response to potential air quality impacts. The application documents provide indicative designs and facilities. The application also demonstrates that a wide range of public open space and play facilities are available within a 10- 12 minute walk of the site. The play space strategy is supported.

Urban design

39 The applicant has engaged well on design matters in pre-application discussions, and has responded positively to officers’ comments, which is welcomed.

Site layout

40 The proposal includes two public squares, with the larger Station Square to the north- west of the site and the smaller, residential square to the south-east. Station Square includes more hard landscaping as a civic space within the local centre, and contains the bus interchange, comprising two bus stops and two bus stands, as well as providing access to the entrance to Kidbrooke Station. Commercial uses and primary residential entrances activate the edges of Station Square, with a pavilion and garden space at its centre. The residential square includes softer landscaping treatments, with a public garden and children’s playspace, and links to the neighbourhood to the north via the existing subway, and to the south via the existing footbridge over the railway line. It is noted that the existing footbridge will pass in close proximity to the proposed residential units in Block H, and the applicant should provide further detail on how privacy, outlook, and amenity will be protected.

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41 The shared surface route running parallel to the railway line, with vehicle access limited to refuse and servicing, links the two public squares, and also provides separation between the residential blocks and the Station and trains. A planted green screen, trees, and landscape buffer provide additional protection from the impacts of the Station and rail line. The proposals incorporate a good spread of entrances to activate public routes, including duplex units.

42 A northern green buffer slopes up to the adjacent roadway, providing shelter from road traffic impacts, with retained trees and new trees and planting. The distance between the roadway and proposed buildings was widened during pre-application development to a minimum of 7 metres and in most locations greater than this, further reducing impacts of the adjacent roads. The slope is utilised by locating inactive ground floor frontage towards the back of the blocks, allowing for high levels of active use fronting onto the public realm. A woodland walk is proposed through the green buffer, linking Station Square with the north-east of the site and areas beyond. Although the relationship between the roads and the residential blocks has improved during pre-application development, the applicant should consider a planted green screen along the northern boundary, similar to that along the railway line, would provide greater security against potential anti-social behaviour, as well as further reducing negative environmental impacts.

Residential quality

43 London Plan Policy 3.5, and Policy D4 of the draft London Plan set out housing quality, space, and amenity standards, with further detail provided in the Mayor’s Housing SPG.

44 The applicant has responded well to some pre-application concerns about residential quality, moving the blocks away from the surrounding roads, removing one block completely in order to increase separation distances, and removing overly deep studio units that limited daylight/sunlight penetration.

45 The application materials indicate that 95% of units have access to a private balcony, terrace, or winter garden; however, some lower level units do not have private amenity space. It is recognised that these units have access to shared residents’ amenity space; however, private amenity space would normally be expected to be provided for these units, as per the Mayor’s Housing SPG, and further justification is required where omitted.

46 Access cores are well distributed across the site, providing legible entrances and efficient core to unit ratios, with a good proportion of dual aspect units (56%). The number of single aspect units have been minimised, with those that were north-east facing at pre-application stage now removed. The applicant’s daylight and sunlight analysis finds that the vast majority of the new units within the proposal will receive very good levels of daylight, achieving an overall average daylight factor (ADF) compliance of 80% in the cumulative context with the Kidbrooke Village proposals.

47 Separation distances between habitable rooms in residential units generally achieve a minimum of 21 metres, going beyond that suggested by the Mayor’s Housing SPG.

48 Overall, the residential quality proposed is good.

Density

49 London Plan Policy 3.4 and draft London Plan Policy D6 ‘Optimising housing density’ seek to optimise the potential of sites, having regard to local context, design principles, public

page 8 transport accessibility, and capacity of existing and future transport services. 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 draft London Plan Policies D4 ‘Housing quality and standards’ and D2 ‘Delivering good design’.

50 The proposal would have a density of approximately 1,058 habitable rooms, or 377 units, per hectare, accounting for the mixed use nature of the proposals. This is above the guidance ranges in Table 3.2 of the London Plan (based on the site’s PTAL of 3 in a ‘central’ setting) and above the thresholds set out within Policy D6 of the draft London Plan, and therefore requires a greater level of design scrutiny, although it is recognised that the potential improvement in the site’s PTAL could result in the proposals being within these density ranges/thresholds. The proposals have been subject to two reviews by Greenwich Design Review Panel during pre- application development, review by the Mayor’s Design Advocates, as well as benefiting from Council and GLA urban design input, and the applicant has responded positively to comments. It is also noted that the location in an emerging neighbourhood, including tall buildings, and adjacent to a station, supports higher densities. As discussed in this report, the proposals are considered to be of a high design quality, providing good residential quality, and do not demonstrate symptoms of overdevelopment. A management strategy has been provided in line with draft London Plan Policy D6. The proposed density is therefore supported.

Height, massing and appearance

51 London Plan Policy 7.7, and draft London Plan D8 ‘Tall buildings’ set out the Mayor’s requirements for tall buildings.

52 The application includes an assessment of the proposals against London Plan Policy 7.7, demonstrating that the inclusion of tall buildings is appropriate in this location. The massing arrangement places the two tallest 20 storey buildings at either end of the site, relating to the 21 storey Birch House as part of Phase 3 of Kidbrooke Village, which also includes 17, 15 and 10 storey buildings. The six central blocks are either 16 or 9 storeys, linked by one/two storey podiums with residents’ amenity space and a public space above. The taller elements are generally of a slender form, with generous separation distances allowing daylight/sunlight to reach public space and residents amenity space. The tallest blocks were lowered in height during pre-application development in order to reduce heritage impacts, and better relate to the heights and massing of Kidbrooke Village.

53 More widely, the applicant’s Townscape and Visual Impact Assessment (TVIA) demonstrates that the proposals will be visible from surrounding areas; however, the buildings sit well within the emerging cluster of buildings of similar height and massing at Kidbrooke. As discussed below, the proposals are considered to cause some limited harm to heritage assets; however, this is very limited and outweighed by the public benefits of the scheme.

54 Considering the high design quality of the proposals; the location of the site adjacent, and partly within, an emerging local centre; with good transport connections; and existing and emerging high-rise buildings, the height and massing of the proposals is supported.

55 The use of brick as the main material provides a robust and contextual appearance, while three different tones introduce a suitable degree of variation. The neutral tones respond to both Phase 3 of Kidbrooke Village to the south, as well as minimising heritage impacts in views from Blackheath. Red brickwork is proposed for the central pavilion, providing a welcome splash of colour. The architectural appearance of the proposal is of a high quality and is supported. The final appearance of the proposals will be subject to the quality of the materials and detailing, which should be appropriately secured by the Council.

page 9 Inclusive design

56 London Plan Policy 7.2 ‘An Inclusive Environment’ and Policy D3 of the draft London Plan seek to ensure that proposals achieve the highest standards of accessible and inclusive design (not just the minimum). Policy 3.8 of the London Plan and Policy D5 require that at least 10% of new build dwellings meet Building Regulation requirement M4(3) ‘wheelchair user dwellings’ (designed to be wheelchair accessible or easily adaptable for residents who are wheelchair users); and all others must meet Building Regulation requirement M4(2) ‘accessible and adaptable dwellings’.

57 The proposal includes lift access to the existing footbridge in the eastern public square, which should be secured as part of any permission. Plans of wheelchair accessible units are provided for a range of unit sizes, which are spread across buildings and tenures. The Council should secure M4(2) and M4(3) requirements by condition as part of any permission.

Urban design - conclusion

58 Overall, the design of the scheme is considered to be of a high quality, subject to clarification of a small number of issues as detailed above. Historic environment and strategic views

59 The Planning (Listed Buildings and Conservation Areas) Act 1990 sets out the statutory duties for dealing with heritage assets in planning decisions. In relation to listed buildings, all planning decisions should “have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses”, and in relation to conservation areas, special attention must be paid to “the desirability of preserving or enhancing the character or appearance of that area”. London Plan Policy 7.8 and Policy HC1 ‘Heritage conservation and growth’ of the draft London Plan state that development should conserve heritage assets and avoid harm.

60 London Plan Policy 7.10 ‘World Heritage Sites’ and draft London Plan Policy HC2 state that development should conserve, promote and enhance their Outstanding Universal Value. Further guidance is provided in the Mayor’s supplementary planning guidance ‘London World Heritage Sites - Guidance on Settings’, and the Maritime Greenwich World Heritage Site (WHS) Management Plan (Third Review 2014). As a place of Outstanding Universal Value, the WHS is a designation of the highest order, and as such it is an important planning consideration. The WHS also contains a number of statutory designations, which afford protection individually and collectively. This includes the Grade I listed Old Royal Naval College, Queen’s House and Observatory buildings; the Greenwich Park Conservation Area; and a number of scheduled monuments in the Park, which is a Grade I registered park and garden.

61 The NPPF states that when considering the impact of a proposal on the significance of a designated heritage asset, great weight should be given to the asset’s conservation, and the more important the asset, the greater the weight should be. Significance is the value of the heritage asset because of its heritage interest, which may be archaeological, architectural, artistic or historic, and may derive from a heritage asset’s physical presence or its setting. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. Where a proposed development will lead to ‘substantial harm’ or total loss of the significance of a designated heritage asset, consent should be refused, unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss. Where a development will lead to ‘less than substantial harm’, the harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.

page 10 62 Although the site does not contain any heritage assets, the height of the proposed buildings mean that it would be visible from, and have an impact on, a number of heritage assets. The applicant’s Designated Heritage Assets study and Townscape and Visual Impact Assessment (TVIA) provide an assessment of heritage assets and the impact of the proposals.

63 Views across Blackheath from the north, towards Blackheath Village and the Grade II listed buildings on Montpelier Row are considered by GLA officers to be of high significance in relation to the setting of the listed buildings and the character and appearance of the Blackheath Conservation Area, and strongly reinforce the village feel of the Conservation Area. The proposed tall buildings will be seen alongside consented and existing buildings of a similar scale as part of Kidbrooke Village, and as such, it should be acknowledged that there is some harm to this view. However, the heights of the buildings having been reduced during the pre- application process, and any harm is now considered to be 'less than substantial'. The public benefits of the scheme include the regeneration of a vacant site; additional good quality housing, including 51% affordable; new community facilities; new public spaces; new business units; as well as economic and regenerative benefits to the wider area. These public benefits are considerable and outweigh the harm caused. In coming to this conclusion, GLA officers have had special regard to the desirability of preserving listed buildings and their settings and have given considerable weight to the harm caused to heritage assets.

64 London Plan Policy 7.12 and Policy HC4 ‘London View Management Framework’ of the draft London Plan state that development should not harm strategic views, with further detail provided in the Mayor’s supplementary planning guidance ‘London View Management Framework’ (LVMF SPG). The site is within the Protected Vistas Extension of ‘London Panorama: Primrose Hill’ (Assessment Point 4A.1 looking towards St. Paul’s Cathedral) and the application includes an analysis of the impact on this view. The top of Blocks A and H would not be visible above the existing 1 Eversholt Street building at Euston, and would sit behind the consented towers on the Convoys Wharf site. No harm would therefore be caused to this view.

Transport

65 The site is largely inaccessible at present and the proposal will introduce pedestrian and cycle access across the site. The design of the streetscape reflects the increasing importance of designing for Healthy Streets and to encourage the use of sustainable modes such as walking and cycling, in line with Policy T2 of the draft London Plan.

66 As a result of the good pedestrian environment around the site identified within the PERS audit, results of pedestrian comfort level assessments, and proposed pedestrian amenity and cycle improvements in proximity of the site, it is not expected that the forecast increase in walking and cycle trips will result in a reduction in amenity for pedestrian and cycles in the vicinity of the site.

67 The trip generation methodology used for assessing the site was discussed in detail at pre-application stage and agreed. The number of trips that the development will generate is not substantial and will not significantly impact public transport modes and the highway.

68 The proposals include 76 car parking spaces within the car park at ground and first floor level of two of the buildings, with a further 6 car club spaces provided on street. The low car parking ratio is welcomed given the location and PTAL of the site and conforms to draft London Plan Policy T6. A total of 19 Blue Badge spaces are proposed, serving more than 3% of the dwellings, with the capacity to increase to 10% if required. A car park design and management plan has been submitted in line with draft London Plan Policy T6 to demonstrate how parking demand will be satisfied within the scheme, which should be secured by condition. Electric

page 11 vehicle charging points (EVCPs) are proposed in accordance with the London Plan, which should be secured by condition.

69 Cycle parking is proposed in line with draft London Plan Policy T5. The location and design of cycle parking should be secured by condition. London Cycling Design Standards recommend that at least 5% of spaces should be capable of accommodating a larger cycle (through stands or similar), which should be confirmed, as should the provision of showers and storage facilities for non-residential uses.

70 A framework travel plan and delivery and servicing plan (DSP) have been provided. The full travel plan should be secured, enforced, monitored and reviewed as part of the section 106 agreement and the DSP should be secured by a condition. The submitted construction logistics plan and it should be secured by condition.

71 The Mayoral Community Infrastructure Levy (CIL) is applicable at a rate of £35 per square metre (GIA).

Climate change

Energy

72 Based on the energy assessment submitted, compared to a 2013 Building Regulations compliant development, an on-site reduction equivalent to an overall saving of 38% of carbon dioxide per year in regulated emissions is expected for the domestic element; and 37% for the non-domestic element. Further information has been requested on modelling outputs, gas boiler efficiency, overheating, the district energy network, the site heat network, combined heat and power, and photovoltaics, which must be provided before the proposals can be considered acceptable in accordance with Policy 5.2 of the London Plan and Policy SI2 of the draft London Plan, and the carbon dioxide savings verified. Full details have been provided to the applicant and the Council.

Sustainable drainage and flood risk

73 The approach to flood risk management for the proposed development complies with London Plan Policy 5.12 and draft London Plan Policy SI.12.

74 The surface water drainage strategy for the proposed development partly complies with London Plan policy 5.13 and draft London Plan Policy SI.13. Further consideration should be given to rainwater harvesting and tree pits. Additional attenuation storage volume calculations and evidence should be also provided.

75 The proposal does not yet meet the requirements of London Plan Policy 5.15 and draft London Plan Policy SI.5, as it does not meet the water consumption targets for non-residential developments, which should be reconsidered.

76 Full details on these requirements have been provided to the applicant and the Council.

Local planning authority’s position

77 Greenwich Council officers have engaged in pre-application discussions with the applicant since February 2018. The application is expected to be considered by Committee in March 2019.

page 12 Legal considerations

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

79 There are no financial considerations at this stage. Conclusion

80 London Plan and draft London Plan policies on employment; town centre uses; social infrastructure; housing; affordable housing; urban design; inclusive design; transport; and climate change, are relevant to this application. The application does not yet comply with the London Plan and the draft London Plan, for the reasons set out below; however, the possible remedies stated could address these deficiencies: • Principle of development: The principle of a high density, residential led, mixed use scheme, which includes retail, small business space, and social infrastructure is strongly supported in line with the London Plan and the draft London Plan. • Affordable housing: The applicant proposes 51% affordable housing, made up of 55% London Affordable Rent and 45% shared ownership, which meets the requirements for the fast track route and is supported. Affordability thresholds and an early stage viability review must be secured in the section 106 agreement attached to any permission. • Urban and inclusive design: The proposals are generally of a high design quality, with good residential quality; subject to further information on the existing footbridge, boundary treatments, and private amenity space. Inclusive access requirements should be secured by condition. • Historic environment and strategic views: The proposals would cause ‘less than substantial’ harm to the character and appearance of the Blackheath Conservation Area and the setting of listed buildings within it; however, the public benefits of the scheme outweigh this harm. • Transport: Further information is required on cycle parking. • Climate change: Further information is required on the energy strategy, the surface water drainage strategy, and water consumption targets.

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for further information, contact the GLA Planning Team: Juliemma McLoughlin, Chief Planner 020 7983 4271 email [email protected] John Finlayson, Head of Development Management 020 7084 2632 email [email protected] Matt Christie, Team Leader, Development Management 020 7983 4409 email [email protected] Martin Jones, Principal Strategic Planner, Case Officer 020 7983 6567 email [email protected]

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