planning report PDU/0039a/01 6 February 2013 Shell Centre, Waterloo in the London Borough of Lambeth planning application no. 12/04708/FUL

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 proposal Redevelopment of site for mixed use development containing up to 798 residential units, offices, community uses, and retail floor space in seven buildings up to 37 storeys, together with landscaping, public realm and associated works.

The applicant The applicant is Braeburn Estates and the lead architect is Squire and Partners.

Strategic issues The principle of a mixed office and residential development in the CAZ and Waterloo Opportunity Area is in accordance with strategic objectives for this highly accessible location, and would benefit London’s World City status.

The site is within a location identified for tall buildings, and the architecture, form and scale of development is acceptable in principle. The site is within the setting of the Westminster World Heritage Site, and the scheme has been designed to limit the extent of impact on this and other strategic views. Public realm improvements around the site and the wider Waterloo area require further discussion, including Hungerford Car Park. Further work on the transport strategy, particularly the London Underground ticket hall and parking levels is also required, together with wider section 106 contributions, in order to ensure that the scheme fully accords with the London Plan.

The scheme includes affordable housing, which is still the subject of discussion and negotiation to ensure the maximum reasonable amount would be delivered. Other strategic issues such as inclusive design, climate change mitigation and adaptation and residential quality are acceptable, subject to further information being provided as detailed in the report below.

Recommendation

That Lambeth Council be advised be advised that the scheme is broadly acceptable in strategic policy terms however, the matters set out in paragraph 106 require further consideration and discussion before it can be confirmed that the proposal fully complies with the London Plan.

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Context

1 On 2 January 2013 the Mayor of London received documents from Lambeth 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 12 February 2013 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 the following categories of the Schedule to the Order 2008:

1A Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats;

1B Development which comprises or includes the erection of a building in Central London (other than the City of London) and with a total floorspace of more than 20,000 square metres;

1C Development which comprises the erection of a building that is more than 30 metres high and is outside the City of London.

3 Once Lambeth 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 2011 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 application site relates to the Shell Centre, the corporate headquarters for Shell International Petroleum Co Ltd, known as the ‘Upstream’ building. This office development is bounded by Belvedere Road, Chicheley Street, York Road and the Hungerford Viaduct. It comprises 10 storey wing buildings on three sides of the north courtyard with the 28 storey Shell Tower on the Belvedere Road frontage, overlooking Jubilee Gardens and the River Thames.

7 There is a basement across the site, which contains leisure space for Shell employees, including a swimming pool, a sports club and a theatre. The southern end of the basement contains a multi-level 300 space car park, accessed from Chicheley Street, above which, at ground level is a raised podium (previously the subject of development proposals).

8 There is an entrance to the London Underground within the site, fronting York Road and above that a raised pedestrian bridge providing a route over York Road to Waterloo Station, through Elizabeth House.

9 The site has a public transport accessibility level (PTAL) of 6b on a scale of 1 to 6 where 6 is most accessible. The site is adjacent to Waterloo Station, providing mainline rail, Bakerloo,

page 2 Jubilee, Northern and Waterloo and City line Underground services, and a range of bus connections. The nearest bus stops are directly adjacent to the site on York Road and are served by routes 76, 77, 211, 341, 381, 507 and RV1. River services are also available from the London Eye Millennium Pier.

10 The site is located within the South Bank Conservation Area.

Details of the proposal

11 The scheme proposes the retention of the existing Shell tower fronting Belvedere Road (28 storeys/105 metres) and demolition of the surrounding wing buildings to provide a series of eight buildings ranging in height from 12 to 37 storeys. In total, up to 218,008 sq.m. of floor space would be provided, comprising up to 798 residential units, together with approximately 76,000 sq.m. offices, 6,000 sq.m. retail, and 2,500 sq.m. of community and leisure uses. Public realm, landscaping, servicing and basement parking (270 spaces) are proposed, together with works to the London Underground station, link bridges and adjacent roads.

12 There are a series of architects which have been employed for each building with Squire and Partners having developed the masterplan:

 Building 1: 12 storey offices with ground floor retail (Squire & Partners)  Building 2: 17 storey offices with ground floor retail (KPF)  Building 3: 32 storey residential (236 flats) with ground floor retail and reconfigured LU Station (Patel Taylor)  Buildings 4A and 4B: 37/30 storey residential (322 flats) with ground floor retail (Squire and Partners)  Block 5: 15 storey residential (108 flats) with ground floor retail (Stanton Williams)  Block 6 & 7: 21/11 storey residential (98 flats) with ground floor retail (Grid Architects)

13 Planning permission is sought for two alternative options for Building 3. Option A proposes 236 units, whilst Option B proposes 270 units, giving an overall total of either 764 or 798 units. The alternative scenario is to enable an alternative mix of units to be provided, to respond to market conditions as the scheme comes forward.

14 The scheme also proposes two scenarios in relation to the York Road footbridge. Option 1 would see the bridge retained and reconfigured, whilst Option 2 sees it removed.

15 Conservation Area Consent is being sought for demolition of the buildings. Permission is also being sought for external alterations to the Shell Tower, and listed building consent to re- locate the existing Franta Belsky Fountain. These applications are not referable to the Mayor. Case history

16 Planning permission was granted under appeal in 2004 for a 9-storey building on the podium site adjacent to the Shell Tower, to contain up to 70,000 sq.m. of commercial floor space. The previous Mayor supported the scheme. This scheme was implemented though not completed and the planning permission remains extant.

17 Pre-application discussions have taken place regarding the current scheme, where the masterplanning principles of the scheme, the heights and design of the buildings, and public realm proposals have been considered acceptable by offices. Clarification on a number of points was required, including affordable housing, access, transport and climate change.

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Strategic planning issues and relevant policies and guidance

18 The relevant issues and corresponding policies are as follows:

 World city role London Plan  Housing – affordable housing London Plan; Housing SPG; Housing Strategy; draft Revised Housing Strategy;; Providing for Children and Young People’s Play and Informal Recreation SPG  Density London Plan; Housing SPG  World Heritage Sites London Plan; World Heritage Sites SPG; Circular 07/09  Tall buildings/strategic views London Plan, LVMF SPG (2012)  Urban design London Plan;  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy  Transport and parking London Plan; revised Early Minor Alteration to the London Plan; the Mayor’s Transport Strategy  Crossrail/CIL London Plan; Mayoral Community Infrastructure Levy; Crossrail SPG

19 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 Lambeth Core Strategy 2011, the saved policies of the Lambeth Unitary Development Plan 2007 and the 2011 London Plan.

20 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework  The adopted Waterloo Opportunity Area Planning Framework (2007)  Waterloo Area SPD (2009), revised draft (2012) and draft Waterloo Station Interchange SPD (2011)  The draft Revised Early Minor Alteration to the London Plan

Principle of development

21 The scheme proposes a mixed use development, including residential, offices and retail uses in accordance with London Plan policies relating to the Central Activities Zone and the Waterloo Opportunity Area. Whilst the office floor space provision decreases by approximately 6,500 sq.m., there is an increased retail provision and as such, no overall loss in commercial floor space on the site. The redevelopment would accommodate approximately 4,120 office based jobs, up to 295 retail jobs and around 50 jobs in the community/leisure uses. In total up to 4,465 jobs would be created - an additional 2,000 jobs compared to the existing Shell Centre. Up to 700 construction jobs per year are expected during the build out.

page 4 22 The scheme proposes high quality, flexible floor plates that would suit a range of potential occupiers and re-provides accommodation for Shell itself, which has temporarily relocated staff in Canary Wharf. The development provides an opportunity to reverse the trend in Waterloo’s office market which has been in decline and falling behind other South Bank locations such as Bankside and London Bridge. Over 7,000 jobs have been lost in Waterloo in the past 30 years, whilst the neighbouring areas in Southwark have grown by 16,000. This is despite Waterloo’s highly accessible riverside location. The economic benefits of the scheme, in terms of increased local spending and job opportunities for local people are acknowledged and welcomed. In this respect, the applicant has committed to providing local training and employment contributions and has indicated its commitment to creating opportunities for employment, in partnership with local stakeholders. These commitments should be secured as part of any section 106 agreement.

23 The scheme proposes ground floor shops, cafes, restaurants, bars, leisure and community uses, fronting on to the public spaces and pedestrian routes. The scheme creates an appropriate level of active frontage with uses to serve the new residential and office populations, as well as visitors to and through the site in accordance with London Plan policy 2.10. The applicant has submitted a retail study, which confirms that the proposed retail uses in the scheme would enhance and complement the existing local and specialist independent retail offer found in The Cut and Lower Marsh, rather than compete with them. The proposed development is targeted to largely take advantage of the new spending generated by occupiers of the development itself. This is accepted. Housing

24 The principle of residential development of the site is acceptable - Lambeth’s annual monitoring target is 1,195 units additional homes per year between 2011 and 2021, and the proposal represents over 65% of the Council’s annual provision.

Affordable housing

25 The scheme is proposing 96 affordable homes on site, comprising 52 affordable rent “extra care” units, and 44 intermediate rent units, both located in Building 3. In Option A, this equates to 13.5% affordable housing, when factoring in the associated communal floor space for the extra care units. In Option B, this equates to close to 13%.

26 In addition, the applicant is also investigating the possibility of providing additional affordable homes off-site in an effort to increase the affordable housing offer. This is subject to further discussion, based on the findings of the toolkit appraisal, which at the time of reporting was still under review by the Council’s independent surveyor. This review will need to analyse in detail the costs and values that have been inputted to the toolkit and verify the assumptions that have been made in relation to rent levels. This requires particular scrutiny, given the very high sales levels being achieved on similar riverside residential sites. Given the high property values generated by the elevated position and views afforded from many parts of the development, it is accepted the provision of genuinely affordable units on this site will be challenging. Furthermore, all parties involved are in agreement that this scheme provides a catalyst for resolving the longstanding matter of the Hungerford Car Park and the applicant has expressed a willingness to secure this area as part of the adjoining Jubilee Gardens. Discussions regarding the overall s106 package and allocation of available funds would be expected to address this key strategic issue.

27 In terms of the extra care units, it is noted that London Plan policy 3.8 makes it clear that developments should provide for a range of housing types, taking into account the housing requirements of different groups. It is acknowledged that the extra care units will meet a particular housing need and takes into account the changing age structure of London’s population and, in

page 5 particular, the varied needs of older Londoners as set out in the Mayor’s Housing SPG. However confirmation that this type of housing will be meeting the Council’s need for older persons housing and will free up larger family homes elsewhere in the borough, as claimed by the applicant, is required. Information regarding under occupancy of affordable family units within the borough should be made available to assist this assessment and the Council should confirm that the units that are freed up would continue in use as part of its affordable housing stock.

28 It is acknowledged that discussions regarding the affordable housing offer are on going and further analysis is required in order to satisfy London Plan policies, the Housing SPG and the borough’s housing policies. A draft of the section 106 legal agreement will need to be provided to the GLA prior to the Stage 2 referral in order to be clear that the application submission reflects London Plan policy and the Housing SPG, and that there is a transparent programme of affordable housing delivery secured as part of the development.

29 In terms of tenure, the on-site provision would deliver an approximate 55/45 affordable rent/intermediate tenure split, which is broadly compliant with London Plan policy 3.12, which seeks to ensure that development proposals deliver a 60:40 tenure split. Subject to the outcome of discussions regarding the off-site affordable housing offer and what tenure this would comprise, the proposed tenure mix is acceptable.

30 As noted in the London Plan, there are also circumstances where boroughs should consider whether it is appropriate to put in place provisions for re-appraising the viability of schemes, and maximise affordable housing provision, taking into account the possibility of increased sales values in the future. Given the phasing and delivery programme, such an approach might be appropriate for this scheme, and also given the length of time that may pass from initial toolkit appraisal to actual build out. This approach has been agreed on the neighbouring Elizabeth House scheme.

Housing mix

31 The housing mix is made up of the following:

Table 1: Housing mix (source: submitted Affordable Housing Statement)

32 The scheme proposes approximately 11% studio flats, 30% one-bed, 44% two-bed, 14% three-bed, with 1% four-bed units. This principle of an alternative scenario which responds to market conditions is logical and accepted. The development is however, skewed towards studio and one bed units. It is acknowledged that in this central location, with the density of development proposed, that the mix is likely to contain a higher proportion of smaller units, but further discussion (including confirmation from the Council’s housing team) will be appropriate in

page 6 order to be clear as to what extent the determined mix reflects local needs and the Council’s housing requirements

33 In the affordable housing element, there are no larger family sized units, which as noted above, is partially due to the extra care housing being proposed and the affordability of the units overall. Details regarding the larger family homes that are being freed up elsewhere by the provision of extra care homes should be provided with clarification that the high proportion of one- bed elderly care units is appropriate and meets local need. If off-site affordable housing provision is being brought forward, it is expected that a higher proportion of family units will be provided.

Residential quality

34 The proposal complies with the space standards set out in table 3.3 of the London Plan. The applicant has provided a checklist of the scheme’s quality against the London Housing Design Guidance, which confirms that for the most part the scheme meets these standards. There are some areas where the scheme does not fully comply, for instance in Building 4A and 4B, there are 39 units which are single aspect north facing studio units. This is unfortunate however, given that this largely applies to private studio flats, with extensive views over the city at the upper levels and that this applies to less than 5% of the total units, this is accepted.

35 The Housing Design Guide also sets out that any single core on each floor should serve no more than eight units. This is to ensure that residents feel a strong sense of ownership over communal spaces minimising the amount of maintenance required. In Building 3, there are a number of floors that would have up to nine units per floor (eleven units per floor in Option B). This applies to 18 out of the 28 levels of accommodation. This is unfortunate, and the applicant should provide further justification to demonstrate that the scheme will provide the sense of ownership sought in guidance. There are some other units where the scheme does not fully comply with the standards, such as balcony depths for some of the units in Buildings 4A and 4B and internal room sizes, but the extent of these is low relative to the scheme overall, and given the high quality of the development, this is acceptable.

36 Overall, the residential layouts are well considered and of high quality, although it is noted that given the proximity to the railway, it is expected that the facade design of the affected units will need to incorporate specialised mitigation features. Specific conditions would be expected to secure these details.

Density

37 The site is centrally located and has a high public transport accessibility (PTAL) of 6B. The applicant has calculated the density, based on net residential area as being approximately 1,300 habitable rooms per hectare (hrha). Whilst this slightly exceeds the density range of 650-1,100 hrha, in light of the location within the CAZ, Waterloo Opportunity Area and contribution that the scheme is making to place shaping in Waterloo, the proposed density is appropriate, reinforced by its high quality design.

Children’s play space

38 Using the methodology within the Mayor’s play space SPG, it is anticipated that there will be approximately 75 children residing within the residential element of the development, with approximately 44 under 5 year olds. 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. The redevelopment proposals would include approx 719 sq.m. of communal gardens and 2,106 sq.m. of public realm and the applicant is proposing informal playable space in these spaces, with older children being catered for through existing facilities, such as Jubilee Gardens, with financial

page 7 contributions being offered to improve them. Given the density of the scheme, the extension to Jubilee Gardens over Hungerford Car Park is even more imperative. Strategic Views

39 The site is not located within any of the Protected Vistas as identified within the London View Management Framework (LVMF) Supplementary Planning Guidance (2012), but would be visible within some London panoramas, river prospects and townscape views such as Alexandra Palace (1A.1), Parliament Hill (2B.1), Primrose Hill (4A.2), Serpentine (23A.1), St James Park (26A.1) , Lambeth Bridge (19A.1 and 19A.2), Parliament Square (27A.1 and 27A.2), Westminster Bridge (18B.1), Westminster Pier (8A.1), Victoria Embankment (20A.1), Hungerford Footbridge (17A.2), Embankment Gardens (20B.1), Waterloo Bridge (15A.1 and 15A.2), Southwark Bridge (12A.2) and Blackfriars Bridge (14A.1). All views have been provided in the applicant’s assessment together with an assessment of the cumulative impact with the proposed Elizabeth House.

40 In terms of the panoramas, the development proposal would have negligible impact on these views as it is seen as part of the developing cluster of taller buildings in the Waterloo Opportunity Area. The strategic views in which the proposal is likely to have the most impact are from St James’s Park, Parliament Square, Hungerford Footbridge and Waterloo Bridge.

41 From St James’s Park (26A.1), the upper parts of the new buildings are seen in conjunction with the Foreign and Commonwealth Office’s group of buildings, framed by the London Eye, and with The Shard to the right. The proposed buildings appear as part of the existing group of buildings to the right of Duck Island, and as noted by the applicant, do not dominate or compete with the existing buildings.

42 From the bridges and the embankment, the main impact of the proposal relates to its relationship with the post war buildings on the South Bank and County Hall. The proposal complies with the visual guidance in that it will strengthen the composition of the emerging cluster of tall buildings in the Waterloo area and will not dominate the other landmark buildings that characterise that area or diminish their relationship with the river. The horizontal feature of these buildings will not be compromised.

43 From Parliament Square (27A.1 and 27A.2), a small part of the top floor of the lower block of Building 1 would be seen on the left side of the interval between the Clock Tower and Portcullis House but would have no effect on views of the fleche of County Hall. World Heritage Sites

44 The proposal is located on the South Bank, within 1 km of the Westminster World Heritage Site (WHS) and the proposal would be viewed in the context of the wider setting of the Palace of Westminster. In accordance with guidance on heritage assets, where the proposal is seen within the context of the WHS, it should also be assessed in terms of its impact on the Outstanding Universal Value (OUV) of the WHS. The applicant is expected to demonstrate that the scheme does not cause adverse impacts on the WHS or it setting (including any buffer zone), and would not compromise a viewer’s ability to appreciate its OUV, integrity, authenticity or significance.

45 The likely effect of the proposed development on the quality of the views and setting of the WHS has been assessed by the applicant through both strategic views identified in the LVMF as well as other views into and out of the WHS itself. This assessment is welcomed as the main impact of the proposed development on the WHS is in relation to its visual integrity.

page 8 46 As noted above, in terms of the LVMF views from the bridges and from within the setting of the WHS, it is concluded that there is sufficient distance between the proposal on the South Bank and the WHS to enable a continued appreciation of the Palace of Westminster, and in particular The Clock Tower, in line with the visual management guidance of the LVMF SPG.

47 From the Parliament Square LVMF views (27A.1 and 27A.2), again, as noted above the proposal also complies with the visual guidance in that it is set away from the Houses of Parliament and very small part of the top floors of the lower block of Building 1 will be visible to the left of the interval, allowing clear sky to be maintained around the Clock Tower to preserve the OUV of the WHS. As well as the LVMF viewpoints, the applicant has also assessed other views from within the World Heritage Site and demonstrates that the proposal would not unduly impact upon the visual experience of the WHS from Parliament Square as a whole and maintains a separation from Big Ben.

48 As noted during the consideration of the Elizabeth House scheme previously, in accordance with the Mayor’s London World Heritage – Guidance on Settings SPG 2012, the NPPF and UNESCO operational guidelines, there are other physical and experiential elements of settings, such as public realm, routes, and accessibility for example that are important factors to consider in the assessing the overall impact on the WHS. The new routes and public realm being proposed are welcome and whilst these would be felt most strongly within the immediate area of Waterloo itself, they would also make a contribution to London’s World City role, improving links to the cultural areas of the South Bank, which in turn would also help to improve and enhance the wider setting of the WHS. This is welcomed however, in order to fully qualify the overall impact on the setting of the WHS, the applicant should explicitly set out the ways in which the scheme would conserve and enhance the authenticity, integrity, significance and OUV of the WHS. The applicant should expand on this point and demonstrate that the elements of setting that contribute to the appreciation of the OUV have been considered in full. Tall buildings, urban design and public realm

49 The principle of redeveloping the site is acceptable in design terms. The design and layout of the existing wing buildings at present make little contribution to the public realm and redevelopment would enable opportunities to improve connectivity and create active frontages in accordance with strategic objectives for Waterloo.

50 The existing Shell Centre is a key tall building within the South Bank area of Waterloo, and the Waterloo OAPF characterises this, together with the ITV Tower and King’s Reach Tower as forming a commercial spine behind the South Bank’s riverside buildings. As such, the principle of further tall buildings in a cluster around the Shell Tower and in proximity to Waterloo Station (another appropriate area for tall buildings) is acceptable.

51 In terms of building scale, massing and heights, the buildings step up across the site from 11 to 37 storeys. The step up in heights from south to north is logical in terms of respecting rights-to-light and views from the Westminster World Heritage Site in particular and also helps minimise LVMF impact in St James’s Park views. The views analysis demonstrates that the Shell Tower’s retains its prominence and that the architecture contributes positively to the skyline, as a development in itself and when combined with the Elizabeth House proposal.

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

page 9 in the group when viewed across the river. The buildings on the immediate river frontage are lower than the Shell building, and whilst the residential buildings behind it are as tall or taller, in the perspective views they do not dominate or compete with the Shell Tower. The majority of the new buildings have a grid structure expressed in a stone that echoes the treatment of the original Shell Centre. The grid treatment gives the group a unity, whilst the variations in the way the grid is expressed on the individual blocks avoids this becoming monotonous or overbearing.

Public realm

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

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

55 The applicant’s aspirations for Chicheley Street and Belvedere Road in terms of providing shared surfaces and resolving the current issues regarding servicing and coach parking are welcomed, in principle. The layout proposed will mean that Chicheley Street will become an important route from the station via the proposed Elizabeth House scheme, as noted above. The detailed design will be expected to address the fact that a range of users, including TfL buses, Duck Tours and coaches, servicing vehicles, and pedestrians will be sharing this space. Comments noted in paragraph 59 below, in relation to ensuring accessible fully solution, are also noted. In relation to Belvedere Road, the applicant notes the desire to turn the Shell Centre around so that it has a frontage on to the newly re-designed Jubilee Gardens. This is welcomed, and as noted above, the intention to resolve the uses on Hungerford Car Park will assist in improving the public realm and appearance of this important river side location.

56 The new route along the southern edge of the railway viaduct is welcomed in terms of providing links to the South Bank and views and links to the river and Charing Cross Station beyond from the newly created Victory Arch Square (part of Elizabeth House proposals). The intention to open up the arches so that there is dual frontage to this space and to Concert Hall Approach is welcomed. Arrangements with respect to servicing and deliveries would need to be clarified so as to ensure that neither this nor Concert Hall Approach revert to a service lane. The northern flanks of Buildings 4A and 4B have been discussed previously, with respect to the animation of the ground floor elevations. Whilst some changes have been made to increase their transparency, it is considered that the applicant could go further and create more active and open elevations on to this route. Further discussion, including visualisations would be welcomed.

page 10 Microclimatic conditions have been considered and it appears that wind and light conditions would not unduly impact upon the pedestrian experience.

57 In terms of building layouts and spaces between the buildings, the proposed masterplan shows a range of public and semi-private spaces and routes through the site. The spaces between the buildings are reasonably tight, and with some 800 residential units and a commensurate amount of commercial space, as well as visitors to the South Bank from Waterloo Station, there would intensive use of these spaces. The intention to alter the London Underground entrance so that it faces into the site, rather than on to York Road as existing, will also add pressure on these spaces and routes from a range of users with different expectations. The spaces within the masterplan have all been carefully considered in terms of the uses that open onto them, the way people move through them, and the way the landscaping defines them, and crucially their fit and interface with Jubilee Gardens and the South Bank, with nowhere in the site far from the open aspect to and across the River Thames. Overall the routes through the buildings, and the scale, layout and function of the spaces have been well considered and will delivery a step change in the quality of the public realm in this key strategic location.

Inclusive design

58 The application is accompanied by access statements for both the masterplan and for each individual building, which cover the principles of inclusive design, access across the site, pedestrian routes, drop off points, and a commitment to Lifetime Homes and wheelchair housing standards. The level of detail provided is welcomed.

59 Over 10% of units would be provided as wheelchair accessible, with all of the extra care units being provided as such. Details are provided on the number of units in each building that would be wheelchair accessible, which cover a range of unit sizes and are not clustered together. Typical flat layouts are also provided for these units, which is welcomed although there are some areas where room sizes do not meet Habinteg requirements. These details should be secured by way of condition.

60 There is some level change across the site, falling by 900mm from the north west corner to the south east corner and the applicant has sought to address this with step free access and acceptable gradients of less than 1:20. Wherever possible, level changes should be designed out of the scheme. There are some shared surfaces proposed – to Chicheley Street and Belvedere Road, and concerns have been raised to date about conflict between large number of pedestrians, and traffic volumes. As such, careful design at build out stage will be required to ensue segregation and crossing points in accordance with the Department for Transport’s ‘Guidance on the use of tactile paving surface’. Further discussion on this aspect would be welcomed, with a specific condition requiring details to be agreed in full. This extends to the landscaping within the site, where play facilities, resting and quiet spaces, bollard and guard rails would be expected to incorporate inclusive design principles at detailed approval stage.

61 Each of the buildings would be provided with level and step free access. There have been concerns raised to date about the provision of revolving doors with side pass doors. As advised, in terms of providing a fully inclusive environment, consideration should be given to sliding drum doors for instance. It is acknowledged that wind conditions may prevent a range of solutions, but further consideration of this point would be welcomed.

62 There are some other aspects such as providing for storage for wheelchairs, scooters and, tenant fit out of retail units, for which further details should be secured by way of condition. Parking arrangements should also been confirmed, in particular the location and size of the bays. Confirmation should be provided that taxi drop off and pick up locations are less

page 11 than 50 metres from each residential entrance should be confirmed, and that there is sufficient allowance for Dial-a-Ride and other services, noting the extra care units provided. There is also an aspiration to provide lift access to the London Underground in this location, noting the elongated route via the Jubilee Line entrance. The applicant should demonstrate the extent to which it has investigated this, and confirmation of discussions with LUL. More detailed comments have been provided to the Council and applicant regarding inclusive design and these matters would be expected to be resolved as the application progresses.

63 The connectivity and routes through the site are currently poor, given the nature of the use and security measures imposed by Shell to date. The high level walkway which crosses York Road from Elizabeth House and through the site is proposed to be removed as part of the Elizabeth House proposals, and the applicant’s commitment to create level, step-free public realm and open spaces across the site, in acknowledgement of its role in linking Waterloo Station and the South Bank is welcomed and strongly supported.

Climate change mitigation

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

65 The applicant has identified the planned South Bank district heating network (DHN) as a future point of connectivity. The energy strategy indicates that it would not be possible, as local air quality requirements have restricted the exhaust emissions allowed on site to serve the South Bank DHN from the Shell Centre site at this time. Nevertheless, the applicant should continue to prioritise connecting to the South Bank network and should investigate measures to overcome the air quality restraints and allow the energy centre to host the South Bank DHN energy plant. Evidence of exploration of this opportunity should be provided. In the meantime, the applicant has provided a commitment to ensuring that the development is designed to allow future connection to district heating networks should one become available. Climate change adaptation

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

67 The documents set out a number of techniques proposed to reduce energy consumption and cut carbon emission, using high performance building fabric, shading systems, low energy lighting, energy efficient appliances, metering, high levels of insulation, and by maximising natural sunlight and solar gain. Sustainable urban drainage is proposed in the form of greywater/rainwater harvesting and surface water attenuation tanks, and 3,360 sq.m. of green/brown roofs would also be provided, which together with the planting proposed would contribute towards urban greening in the CAZ which has otherwise been absent in this vicinity for many years. These commitments should be secured by way of condition.

page 12 Transport

Trip generation

68 The trip generation methodology was agreed with TfL at the pre-application stage and is therefore acceptable. However, as requested in the pre-application letter, the baseline scenario for the impact assessment should not take into account the existing wing buildings as they are not currently occupied and the transport network does not therefore currently cater for these trips.

Highways and Access

69 It is proposed that vehicular access for both private and servicing vehicles will be taken from Chicheley Street. The existing access from York Road will be closed, and this is welcomed. Given the relatively low forecast increase in traffic, TfL is satisfied that there will be no significant impact on the TLRN as a result of trips generated by the development. However, there is likely to be a need for further discussion on the potential impact of the double crossing on York Road and how this will affect overall performance of the network. It should also be noted that VISSIM modelling is likely to be required at the Section 278 stage in order to adequately assess the interaction with the IMAX roundabout.

Public Realm Improvements

70 The proposed layout of the development would significantly increase pedestrian permeability and linkages through the site, which is welcomed. A new link south of the viaduct at the northern end of the site would be opened up, along with new at-grade links between York Road, Belvedere Road and Jubilee Gardens and the creation of a new public square. These routes and spaces will provide new links between Waterloo station and the river, and in conjunction with the Elizabeth House proposals will significantly enhance public realm in the Waterloo area.

71 As noted elsewhere, a key area in terms of public realm is York Road, and particularly the relationship between the Shell Centre and Elizabeth House proposed developments and links to Waterloo station. Two options are proposed for York Road, depending on whether or not the Elizabeth House site is redeveloped. If Elizabeth House remains in its current form, the footbridge over York Road would be retained and the stairs re-orientated, and the existing 10 metre wide crossing at Sutton Walk would be retained. If the Elizabeth House development is implemented and the footbridge is removed, the York Road crossing would be widened in conjunction with the Victory Arch Square proposals in order to increase pedestrian capacity and cater better for desire lines. Whilst the provision of additional capacity is supported in principle, further detailed discussions are required to ensure that this technically feasible.

72 The junction of York Road and Chicheley Street would be remodelled under both scenarios to improve facilities for pedestrians, including localised re-profiling of the carriageway and widening of the pedestrian crossings to accommodate additional pedestrian demand. This is welcomed, although the exact layout of the junction and pedestrian crossings will be subject to further detailed discussions as part of the Section 278 agreement. The proposed tree planting in the central reservation on York Road is also acceptable, although further discussions will be required to agree the details of how this will be achieved.

73 The construction of a new office building at the corner of York Road and Chicheley Street would result in the loss of public realm space and is likely to increase the number of pedestrians using Chicheley Street. In order to accommodate the forecast increase in pedestrians, the footways along the northern side of Chicheley Street will be widened to between 9.5 and 12.7 metres. Belvedere Road would be redesigned to create a shared surface, providing improvements

page 13 for pedestrians. The existing parking and stopping provision on both roads will also be revised and further comments on the specific modes are provided below.

Car Parking

74 A total of 320 car parking spaces are currently provided on the site. As previously requested, details of existing car park occupancy has been sought but not provided to date. The applicant is proposing a total of 270 spaces on the site, of which 30 to 40 will be allocated to the office use, 229 to 239 for the residential use (depending on the option chosen for Building 3) and one accessible space for the retail use.

75 Given the high public transport accessibility of the site and the congested nature of the surrounding highway network, TfL’s view is that the development should be car free except for disabled provision. Whilst accepting that the redevelopment of the site would result in a reduction from the existing number of spaces on the site, no justification is given for the proposed provision and as such, the scheme is considered to be contrary to London Plan policy 6.13

76 The applicant proposes to provide electric vehicle charging points (EVCP) for 20% of car parking spaces, with 20% to have passive provision for future conversion. A car park management strategy for both commercial and residential uses is also proposed. These measures are welcomed and should be secured by planning condition. The applicant’s intention to provide two car club spaces on Belvedere Road, which should be secured through the s106 agreement. Appropriate measures to promote the car club should be included in the travel plan.

London Underground

77 As part of the redevelopment proposals, improvements would be made to the existing ticket hall located within the Shell building. Following discussions with the applicants, London Underground is satisfied that there is a workable basis for agreeing a solution, but there are a number of issues that need to be resolved before the application can be fully supported. In particular, the proposed layout for the ticket hall as shown in the documents does not reflect more recent discussions with the applicant. The ticket hall is also proposed to be rebuilt and not ‘refurbished’ as detailed in 9.3.23 of the transport assessment.

78 Of concern is that the proposed layout indicated does not represent an improvement over the existing layout and TfL has previously highlighted to the applicants a number of key reasons as to why this layout is not acceptable in operational terms. These include substandard clearance at the top of the escalators, issues with access and maintenance, a worsening of cross passenger flows due to the split gateline arrangement, and a lack of space for ticketing facilities. TfL are committed to working collaboratively with the applicants to undertake further design development of the internal layout of the new remodelled ticket hall and would require resolution/agreement of the following key issues:

 Develop an optimal layout that meets standards, improves operations, retail offering and in line with LU current day policy. This may require provision of additional ticketing facilities and escalators.

 Enter into an agreement to access LU land to undertake the works which will include, but without limitation, provisions for the protection of LU infrastructure, assets during the construction period.

 Underwrite all LU costs and liabilities arising from, including but not limited to:

page 14 1. The temporary loss of use of the York Road station entrance (including, for example, the cost of removing / relocating and storing off-site existing assets; increased staff costs to manage passenger flows during the works, temporary signage, performance abatements and so on); 2. Undertaking the design, construction, fit out and delivery into service of the York Road new ticket hall to LU requirements.

79 The applicants are also required to investigate and develop the structural design of building B3 with a view to removing or minimising the effect of structural columns within the LU space, in particular to improve passenger flows and sightline. The mezzanine level would also be expected to be made available for LU to use if this would improve the ticket hall layout.

80 The transport assessment assumes future demand growth of 1% per year on RODS 2011 (9.3.3) and concludes that there is sufficient capacity on LU lines and therefore no further mitigation is required (9.3.19). LU consider this percentage uplift too low given the likely impact of Network Rail’s planned 10-car and 14-car upgrade which will be implemented after the redevelopment is completed. In recent discussions with the applicants, LU has sent guidance on rate of growth to be used and notes that these have not been adopted.

81 Of more significant concern to LU is the management of the two years requested closure of the York Road ticket hall, especially in the event of an emergency and should the Network Rail concourse have to close as a result. This will leave LU with just the Jubilee (Colonnade) ticket hall as evacuation capacity and an evacuation appraisal will therefore need to be undertaken to ensure the station can be managed safely during the closure. The applicants were advised that the capacity of the peak hour subway and WIT terminal may have to be secured as a mitigation measure. Therefore in conclusion, TfL be unable to support a planning application without agreement to the points outlined above.

National Rail

82 TfL is satisfied that the overall net increase in rail trips can be accommodated on the services from Waterloo and Waterloo East stations, given that there are a large number of services. As the transport assessment states, some trains that serve Waterloo will be lengthened to ten cars in the next few years, which will provide extra capacity on some services.

Buses

83 Due to the central location and proximity of the development to a high number of bus routes, TfL is satisfied that no mitigation is required from a bus capacity perspective. There is no objection to the relocation of the RV1 stop (stop Z) from Chicheley Street to Belvedere Road as long as the two stops remain in close proximity to each other as shown in the drawings. The provision of a bus boarder is supported and should be designed in compliance with the principles developed in the bus stop accessibility guidance. The proposed layout drawings do not include the existing bus stops on York Road. These will need to be retained and upgraded as part of the section 278 agreement.

Cycle Parking

84 Depending on the option selected for Building 3, a total of between 1,664 and 1,707 cycle parking spaces are proposed (895 to 938 spaces for the residential use, 718 for office and 51 for retail). The level and allocation of cycle parking overall is considered acceptable and in line with London Plan standards. It is welcomed that lifts and cycle stairs are provided for cyclists and that showering and changing facilities will be provided for both office and retail staff. A condition or

page 15 section 106 obligation should be added to ensure all of the cycle parking is delivered prior to the occupation of any part of the development.

Cycle Hire

85 The proposals include the relocation of the existing Jubilee Gardens docking station to the opposite side of Belvedere Road. This location is acceptable in principle except that the proposed site has at least 2 street lights and 3 street trees, all of which would have to be relocated in order to fit the 30 docking points in. Removal of green space/trees is contrary to Cycle Hire Site Identification requirements. This part of Belvedere Road is public highway so it would be up to the developer to undertake the infrastructure removal and for Lambeth to agree relocation of the street trees. Agreement in writing from all relevant parties would be expected before agreeing to remove the existing docking station; this must be agreed before the application goes to Lambeth’s planning committee.

86 Furthermore, all costs associated with the relocation will be the responsibility of the developer. Jubilee Gardens capacity is critical to the Waterloo operational area and so there cannot be any loss of capacity during construction. The new docking station will need to be designed, consented, constructed and operational before the existing one can be decommissioned. This should be a section 106 obligation.

87 As raised in the pre-application response, the additional uplift in users based at the site (i.e. residents and office workers) will require additional cycle hire capacity over and above the existing local provision, as the local docking stations cannot absorb any additional demand. This could potentially be provided as an expansion of an existing docking station, a separate station, or a combination of both. Concerns were raised by the applicants at the pre-application meeting about the potential for any new docking points to be used mainly by commuters from Waterloo station. Whilst satisfied that alternatives that are away from the main commuter path could be pursued, it still needs to be: a) publicly accessible at all times, and b) reasonably accessible to TfL’s redistribution vehicles. Further discussions are required and a suitable location and contribution will need to be secured through the section 106 agreement.

Taxis

88 Reference is made to a two space taxi rank being provided but this is not sufficient to meet the demand for taxi services and a larger taxi rank should be provided. The final design and layout of the taxi rank must be agreed with TfL – London Taxi and Private Hire and the taxi rank must be located in a position where taxis are visible and easily accessible for people coming from the London Eye. Any new taxi rank should also include a TfL taxi pole to help people locate the taxi rank. The provision of a larger taxi rank will help reduce congestion and taxis waiting in other areas and will also reduce the number of taxis driving around waiting to be hired and so help reduce harmful vehicle emissions.

89 Additional space for other vehicles, including private hire vehicles, to pick up and drop off passengers should also be provided. The taxi and private hire pick up and drop off areas should be designed to avoid conflicts with cyclists, pedestrians and all other road users. As stated the routes to and from all drop off and pick up areas should be accessible and step free.

90 Where bollards or other hostile vehicle mitigation (HVM) measures are installed these must not impede the use of the accessibility features (e.g. wheelchair ramp, etc.) on taxis. It is important that the measures are not placed too close to the kerb to stop a taxi door being fully opened and not too close together to stop the taxi wheelchair ramp being fully extended. When installing these

page 16 measures the provisions of the Equality Act 2010 must be taken into account, this is particularly important as 10% of the residential units are to be wheelchair adaptable and accessible.

Coaches

91 The TA states that the applicants have commenced consultation and engagement with key stakeholders, including Lambeth Council, London Eye and South Bank Employers Group regarding coach parking and the opportunity to potentially reduce the parking provision on Belvedere Road. From a TfL perspective, of most significance is the need to retain and expand the coach parking (usually pick up set down only when busy) provision for the London Eye and associated Merlin Entertainment venues as these are some of London’s biggest coach traffic generators. As this coach facility is managed it currently works extremely well. Additionally, if the London Duck Tours stand is to be relocated away from Chicheley Street, it is important that a suitable alternative location is agreed between all relevant parties.

Legible London

92 Legible London is TfL’s preferred pedestrian wayfinding scheme and is already established in the area. The opportunity to include further mapping posts in the area / around the building, would benefit greatly the efficient movement of people through the new areas of public realm and orientate them to the new crossings. The TA states that new Legible London signs will be incorporated into the design where possible. A wayfinding strategy should be adopted and funding for new signs should be secured through the section 106 agreement.

Travel plan

93 TfL welcomes the provision of residential and framework travel plans, which include objectives and measures to promote sustainable transport and have passed the Attribute assessment. In order to ensure that the application complies with London Plan policy 6.1 and 6.3 the final travel plan(s) would need to be secured through the section 106 agreement. Specific measures such as car club membership and cycle vouchers should also be secured through the section 106 agreement.

Freight and servicing

94 A basement service yard is proposed to accommodate all servicing requirements. This will ensure that no servicing or refuse collection is undertaken from the highway and is welcomed by TfL. TfL also welcomes the provision of an off-carriageway waiting area for servicing vehicles, which will help to prevent traffic blocking back to the junction with Chicheley Street. However, this area will need to be carefully managed in order to avoid conflict between vehicles and pedestrians, particularly during peak periods.

95 The inclusion of a delivery and servicing plan (DSP) is welcomed. The commitments to reduce peak hour servicing, delivery booking systems, information sheets and a responsible procurement process is considered to be acceptable. The DSP should be secured through the section 106 agreement and linked to the Travel Plan.

96 The provision of a construction logistics plan (CLP) is also welcomed. Due to the complex nature of the build, discussions on construction arrangements should be undertaken as early as possible, although it is acknowledged that a limited level of detail is available at this stage. The CLP states that an alternative temporary construction access may be required on York Road. There would need to be strong justification to enable access to be provided on the TLRN.

page 17 97 In order to ensure compliance with London Plan policy 6.14, both the servicing and construction management plans must be secured by appropriate planning conditions or through the section 106 agreement.

Mitigation

98 As detailed above, the proposed transport improvements currently include:

 Public realm and highway improvements to York Road, including tree planting;  Public realm and highway improvements to Chicheley Street and Belvedere Road;  Improvements to the South Bank Underground ticket hall;  The provision of a new public space and new at-grade pedestrian links within the site.

99 Further discussions are required with regard to the details of the public realm improvements and operation of York Road, the LU station design, provision of additional cycle hire docking points and Legible London signage. All public realm and highway works on the TLRN (York Road) should be secured through a section 278 agreement with TfL and all other improvements will need to be secured through the section 106 agreement. Given the complex nature of the construction and potential impact on London Underground infrastructure, TfL will need to be a signatory to the section 106 agreement and all legal fees incurred by TfL should be reimbursed by the applicant.

Crossrail and CIL

100 In line with the currently adopted Mayor’s Crossrail s106 SPG, Waterloo is excluded from the Crossrail charging area on the basis that a similar level of contribution will be sought for strategic transport in the Waterloo Opportunity Area. This reflects the desire to encourage Waterloo’s regeneration, and the need for strategic scale transport infrastructure to be provided in and around the station. However, the draft Crossrail and CIL SPG does not include a requirement to contribute towards strategic transport at Waterloo and the requirement for a payment under this policy will therefore depend on whether the revised SPG has been adopted at that time.

101 In accordance with London Plan policy 8.9, the Mayor has agreed his CIL charging schedule. The levy will apply to developments consented on or after 1 April 2012, and will be collected by London boroughs once development commences. This application is liable to pay a CIL charge, the cost of which in Lambeth is £35 per square metre. This is in addition to the other mitigation measures discussed above.

Traffic Management Act

102 Should this application be granted planning permission, the developer and their representatives are reminded that this does not discharge the requirements under the Traffic Management Act 2004. Formal notifications and approval may be needed for both the permanent highway scheme and any temporary highway works required during the construction phase of the development. Local planning authority’s position

103 Lambeth Council has been involved in extensive pre-application discussions over the scheme, and supports it in principle. It is due for consideration by its planning committee in April 2013.

page 18 Legal considerations

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

105 There are no financial considerations at this stage. Conclusion

106 This is a very major development of a key site and location in Central London and within the Waterloo Opportunity Area. If delivered, the development will have significant regenerative, visual and economic impacts on the area, as well as provide significant new housing and affordable housing. The application is broadly acceptable in strategic policy terms however, further information and/or clarification as detailed below is required before it can be confirmed that the proposal is in full accordance complies with the London Plan:

 Principle of use: The principle of a mixed use scheme in this central London location is accordance with London Plan policies 2.10, 2.11, 2.13, 2.3 and 4.2.  Housing: The principle of housing on this site is acceptable however, the affordable housing offer is still the subject of negotiation and verification in order to ensure the maximum reasonable amount is being proposed in accordance with London Plan policy 3.12. The scheme proposes a range of units in accordance with London Plan policies 3.8, which is subject to verification from the Council that the scheme meets local housing needs. The residential quality is generally in accordance with the London Housing Design Guide and play space is provided in accordance with the Mayor’s SPG. The density exceeds London Plan guidelines, but optimises development on the site in accordance with London Plan policy 3.4.  Tall buildings / views / heritage: The proposed development would be visible in a number of strategic views set out in the London View Management Framework but the proposed building would not detrimentally affect these views or the setting of the Westminster World Heritage Site.

 Urban design and public realm: The design is of a high standard and would provide a positive contribution to the Waterloo area and London’s skyline. There are some detailed design aspects, with respect to Building 4A and 4B ground floor elevations where further discussion is required.

 Inclusive design and access: The applicant’s commitment towards creating an inclusive environment is welcomed and would meet Lifetime Homes standards, together with the provision of 10% wheelchair adaptable units. Further information is required

page 19 however, in order to be satisfied that the scheme fully accords with London Plan policies 3.8 and 7.2.

 Climate change: The applicant has broadly followed the energy hierarchy to reduce CO2 emissions. Sufficient information has been provided to understand the proposals as a whole and the carbon savings exceed London Plan standards. Sustainability measures are proposed and should be secured by way of condition.

 Transport: The overall quality and content of the transport assessment and related documents is broadly acceptable and the public realm proposals are welcomed. However, further detailed discussions on a number of issues, and in particular the London Underground entrance, are required before it can be considered that the application is in compliance with the transport policies of the London Plan.

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] Samantha Wells, Case Officer 020 7983 4266 email [email protected]

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