1 Site address 186 Park Road and 18A-20 Stannary Street

Ward Princes

Proposal Demolition of the existing buildings at 186 Road and part demolition of 18A Stannary Street, and erection of a new part single, three and four storey building to provide new offices together with alterations to 184 Kennington Park Road and 18A - 20 Stannary Street.

Application type Major Offices

Application ref(s) 14/03889/FUL

Validation date 15 August 2014

Case officer details Name: Rozina Vrlic Tel: 020 7926 1195 Email: [email protected]

Applicant Health and Care Professions Council

Agent Susanna Dobson 141 Kennington Park Road London SE11 4JJ

Considerations/constraints Kennington Conservation Area Flood Zone 2/3

Approved plans 111PD031 Rev B received 28/07/14, 111PD032 Rec C received 08/12/14, 111PD033 Rev C, received 08/12/14, 111PD034 Rev C, received 08/12/14,111PD035 Rev B, received 28/07/14, 111PD036 Rev B, received 28/07/14, Design, Access and Heritage Statement, prepared by Studio Callaghan, dated July 2014, received 25/07/14, Daylight and Sunlight Study, prepared by Right of Light Consulting, dated 25 July 2014, received 25/07/14, Flood Risk Assessment & Sustainable Drainage 120759/T Noble Rev 1.1, prepared by Conisbee, dated 23 July 2014, received 25/07/14, Office Development Acoustic Report, A9786-R01A-CFC, prepared by Bickerdike Allen Partners, dated 25 July 2014, received 25/07/14, Waste and Servicing Management Plan, received 25/07/14, Outline Energy Assessment for Planning 14371Rev B, prepared by Couchperrywilkes, dated 25/07/14 received 25/07/14,

2 BREEAM 2011 Pre-assessment Report Rev A, prepared by HOARE LEA BREEAM, dated 18 July 2014, received 25/07/14, Travel Plan, U1411223L (Version 2 –TP), Dated January 2015, prepared by ML Traffic Engineers, Transport Statement, U141123L (Version 2 – TS), dated January 2015, prepared by ML Traffic Engineers, Site Investigation Report ref. C13117, dated July 2014, prepared by Ground Engineering.

Recommendation (s) Grant planning permission subject to conditions

Consultation

Department(s) or Organisation(s) Consulted? Date response Comments (y/n) received summarised in report? (y/n) Internal Conservation and Design Y 17/12/14 Y Transport/Highways Officer Y 29/09/14 Y Climate Consulting Y 05/01/15 Y Regulatory Services – Noise Pollution Y 02/10/14 Y Regulatory Services – Land Y 20/10/14 Y Contamination Neighbourhoods and Investment Y 11/11/14 Y Planning Policy Y No Response N Parks Project Officer Y 06/10/14 Y Streetcare Y No response N

External Environment Agency Y 28/10/14 Y Transport for London Y 15/10/14 Heart of Kennington Residents Y No Response N Association Kennington Cross Neighbourhood Y No Response N Association Waterloo Quarter Bid Y No Response N 9 Albert Embankment Residents Y No Response N Association. The Society Y No Response N Vauxhall One Business Improvement Y No Response N District Association of waterloo Groups Y No Response N

3 1 Summary of Main Issues

1.1 The main planning consideration in the determination of this application are:

 The principle of intensification of the use of the land for office purposes (Use Class B1)  The design of the new building and impact upon the character and appearance of the Kennington Conservation Area;  Impact on the amenity of neighbouring residents;  Transport implications of the proposal;  Sustainability of the proposed development;  Flood Risk;  Land Contamination;  Crime prevention and community safety considerations and;  Community Infrastructure Levy/Planning Obligations.

2 Description of Site and Surrounding Area

2.1 The A3 Kennington Park Road is an arterial route; a wide straight road, which has a ‘boulevard’ quality. The buildings in the area are mainly late 18th and early 19th Century three/four storey buildings with residential properties towards the north and commercial premises towards the south; this is representative of the historical development of the area. This part of Kennington Park Road backs onto Stannary Street, which is characterised by a mix of commercial and light industrial style buildings (mostly two storeys in height).

2.2 The application site, 184-186 Kennington Park Road, lies on the western side of Kennington Park Road and faces directly onto Kennington Park. 186 Kennington Park Road is a1960s red brick three storey building with a contemporary mansard roof extension forming the fourth storey. It is loosely Italianate in design style with narrow red brick and stucco pilasters and cornicing. The building is set back from the road with a forecourt to the front and, is situated within a terrace of properties in use for commercial and residential purposes.

2.3 18A-20 Stannary Street is located on the eastern side of the street, and is set within a terrace of commercial buildings. 18A Stannary Street is a former mid/late C19th two storey residential building, which has been converted to commercial use; however it retains much of its residential character. No. 18 Stannary Street is adjacent to No.18A which is a purpose-built commercial building (B Use Class).

2.4 The two buildings are linked by a single storey rear extension to the Stannary Street building and by a three storey pitched roof building to the Kennington Park Road building. This is one of several other developments in this area, which fully connect Kennington Park Road and Stannary Street; the gaps between the rear building lines of the properties in Stannary Street and Kennington Park Road in this area have been largely closed by contemporary extensions and new developments.

4 2.5 Beyond, to the north of the site, terraced residential properties there retain their original rear gardens, which afford a clear demarcation between the properties in Stannary Street and those in Kennington Park Road. Although the urban grain is ad-hoc, the separation between the buildings in the two roads is clearly discernible in the predominantly residential parts of the surrounding area.

2.6 The buildings adjoining the application site on Kennington Park Road consist of bank premises at 188 Kennington Park Road with residential accommodation at the rear ground, first, second and third floors of the building and to the north- east of 184 Kennington Park Road, are residential properties, No’s 180 and 182 Kennington Park Road.

2.7 The buildings adjoining the site in Stannary Street are in B1 (Business) and B2 (General Industrial) commercial use. To the south of the site is No 18 Stannary Street, the purpose-built commercial building and next to it is No.16 Stannary Street, a four storey building with ground and first floor units in commercial use with residential upper floors. To north of No’s.18A-20 Stannary Street are properties in the ownership of the applicant (Nos.22 to 26 Stannary Street) and, immediately adjoining them is a converted industrial building comprising live- work units and office units known as Whitacre Mews.

2.8 No’s 184 and 186 Kennington Park Road and 18A Stannary Street are identified as positive contributors to the character and appearance of the Kennington Conservation Area in which the site is located. The site is also located in proximity of two listed dwellings; No’s.180 and 182 Kennington Park Road.

2.9 No 186 Kennington Park Road and No 18A-20 Stannary Street are located within a designated Key Industrial Business Area (KIBA), however No 184 Kennington Park Road is outside this designated boundary. The site adjoins the boundary of the Kennington Park Road/Kennington Road Local Centre to the north-east. 2.10 The application site has a Public Transport Accessibility Level (PTAL) rating of 6a, which is categorised as ‘excellent’. The site lies within the Controlled Parking Zone (CPZ) Kennington ‘K’ which is in operation from Monday to Friday between 8.30am to 6.30pm. Kennington Park Road is a Red Route, which is part of the Transport for London Road Network (TLRN).

2.11 The application site does not form part of any protected or designated area of nature conservation, although it is opposite a Local Site of Importance for Nature Conservation (Local SINC) comprising Kennington Park, which is on the other side of Kennington Park Road.

2.12 The site lies within the Protected Vista from Primrose Hill Summit to the Palace of Westminster (LVMF 2010).

2.13 The site is located within Flood Zone 2/3 and is therefore considered by the Environment Agency to be vulnerable to flood risk.

5 3 Planning History

3.1 There is extensive planning history on both constituent parts of the site, dating back to the 1960’s. Those planning applications considered material to the current application are listed below:

3.2 Applications for change of use of land

 Planning permission ref. 94/01013/PLANAP was granted on the 07/04/1994 for change of use from storage and distribution (Use Class B8) with ancillary office to business use (Use Class B1) at No.20 Stannary Street.

 Planning permission ref. 10/03963/LDCE was granted on 02/03/2011 for a Certificate of Lawful Development (Existing) with respect to the use of the premises at No.186 Kennington Park Road and No.18A Stannary Street as office accommodation (Use Class B1).

3.3 Applications for alterations and extensions

 Planning permission ref. LA/375/186/TP was granted on 21st March 1962 for demolition and rebuilding of offices at 186 Kennington Park Road.

 Planning permission ref. DC/AC/JWP/MGC/5747 was granted on 8th March 1972 for the erection of a second floor extension and use of the second floor for offices and the ground floor as a warehouse/showroom at No.186 Kennington Park Road.

 Planning permission ref. DC/AC/SWP/MGG/5747 was granted on 1st November 1972 for alterations to the showroom elevations at No.186 Kennington Park Road.

 Planning permission ref. DC/AC/JWP/MCG/18808 was granted on the 08/01/74 for the rebuilding of the building at 184 Kennington Park Road to provide office accommodation. This permission appears not to have been implemented.

 Planning permission ref. 95/01546/PLANAP was granted on 09/02/1996 for the installation of air conditioning units at ground and third floor roof levels at No.184 Kennington Park Road.

 Planning permission ref. 99/01439/FUL was granted on 13/12/1999 for Erection of first floor link between the rear of the buildings at numbers 184 and 20 and installation of rooflights in number 20.

6  Planning permission ref. 03/01399/FUL was granted on the 08/07/2003 for the erection of railings over dwarf stone wall with additional pier and gates to front boundary and re-profiling of front lightwell to Kennington Park Road elevation of No.184 Kennington Park Road and replacement of double leaf door to Stannary Street elevation with single leaf fire escape door.

 Planning permission ref. 00/00526/FUL was granted on 23/02/2001 for the erection of a 4th storey to No. 184 Kennington Park Road) and the erection of a single storey rear extension to No.18 Stannary Streetand, the installation of roof lights to the front elevation.

 Planning permission ref. 10/03452/FUL was granted on 06/12/2010 for improvements to the external fabric of the pedestrian bridge linking the 184 Kennington Park Road building with 20 Stannary Street building, including the removal of the existing inside wall panels and their replacement with clear glazing, together with retrospective permission for the replacement of timber framed windows/doors with aluminium framed double glazed windows/doors at basement level of 184 Kennington Park Road.

 Planning permission ref. 11/03145/FUL was granted on 22/11/2011 for the replacement of the existing single glazed timber framed doors and windows with double glazed aluminium/timber framed doors and windows on the rear elevation at No.184 Kennington Park Road

 Planning permission ref. 13/05997/FUL was granted on 06/02/2014 for the replacement of existing timber framed windows to the rear of 20 Stannary Street with new composite aluminium/timber windows.

3.4 Other relevant planning history

16 Stannary Street

 Planning permission ref. 07/05042/FUL was granted on the 13/02/2008 for the redevelopment of site to provide a new building comprising ground and three upper floors with ground and first floor office/workshops and 2 x 2 bed apartments on second and third floor level.

 Prior approval ref. 14/00731/P3JPA was refused on the 25/03/2014 for the change of use of Use Class B1 (Offices) to provide residential units (Use Class C3) at first floor level.

 Planning permission ref. 14/00930/FUL was granted on the 16/04/2014 for the construction of roof access structure and glazed balustrades to create a roof terrace for the top floor flat.

190 Kennington Park Road (Beregaria Court)

7  Planning permission ref. 05/01101/FUL was granted on the 10/07/2006 for the redevelopment of site involving the erection of a five storey building comprising 28 self-contained flats (4 x studio flats, 13 x 1-bed, 10 x 2-bed and 1 x 3 bed) together with landscaping and boundary treatment and associated alterations.

Pre-Application Advice The applicant sought initial pre-application advice (ref. 12/04609/FUL) for replacement of existing buildings at 186 Kennington Park Road with new offices. Follow up advice was sought ref. 13/04453/PREAPP, and provided on 9th December 2013. Following this a revised set of drawings were submitted and discussed at a meeting on 14 January 2014. The the key issues that were required to be resolved included:

Resolution of the retention or replacement of the façade to 18A Stannary Street. If to be replaced, suitable justification should be provided in order for it to be accepted.  Further details of the proposed building too 186 Kennington Park Road including colour palette and design of architectural details such as window cills, canopy and balustrade etc.  The cycle parking on site, which should be provided to a room next to the 18A or 20 Stannary Street frontage.  Resolve the Council’s concern regarding the servicing across all buildings as part of HCPC.

No further follow-up advice was sought and a planning application was submitted in August 2014, which is the subject of this report.

4 Current Proposals

4.1 Planning permission is sought for the demolition of the existing buildings at 186 Kennington Park Road and part demolition of 18A Stannary Street (Street façade retained) and the erection of a new part single, part three and part four storey building to provide new offices (Use Class B1 (a)); and alterations to No’s 184 Kennington Park Road and 18A - 20 Stannary Street. The four storey block would be located on the Kennington Park Road frontage and the three storey block on the Stannary Street frontage with the single storey element linking the two.

4.2 Revised drawings were received on the 08/12/14 illustrating the following proposed amendments:

(i) The 18A Stannary Street facade retained. (ii) The height of the roof storey fronting Stannary Street reduced.

4.3 Revised Transport Statement and Travel Plan were received on 9/01/15

4.4 The proposed demolition works would include No.186 Kennington Park Road, the three storey building to the rear of No.186 Kennington Park Road, the bridge pedestrian link between the rear of the buildings at numbers 184 Kennington

8 Park Road and No. 20 Stannary and the single storey rear extension to Stannary Street. No.18A Stannary Street would be partially demolished with the front façade retained and refurbished.

4.5 The proposed replacement building (No. 186) fronting Kennington Park Road would be setback from the pavement by approximately 7m, retaining a forecourt to the street. The building would be approximately 8.6m in width, and would extend the full length of the site towards the rear at ground floor where it would join the retained Stannary Street façade. At first and second floor levels, this building would have a length of approximately 24.7m. At third floor level the front and rear elevations of the building would be set-in by approximately 1.7m and 1.3m respectively, and would incorporate a balcony to the front elevation.

4.6 The 4 storeys of the building would reach a height of approximately 14.1m above ground level. A plant enclosure (1.5m high X 8m wide) and lift overrun (900mm high X 2.5m wide) are proposed as well as solar photovoltaic panels (PVs) and Sedum roof areas over a flat roof.

4.7 The forecourt to Kennington Park Road frontage would be soft and hard landscaped with the existing vehicular crossover removed and the pavement re- instated

4.8 As noted above, the façade to 18A Stannary Street would be retained. At ground floor this block of the building would extend rearwards and join with No.186 Kennington Park Road. At first floor level, the building would extend rearwards for 17.5m and at the second floor level the building would be set-in from the front and rear elevation by approximately 1.6m and 0.9m, respectively. This three storey block would rise to a height of approximately 11m above ground level. A plant enclosure (1.5m high x 2.7m wide) and lift overrun (1.4m high X 2m wide) are proposed as well as solar photovoltaic panels (PVs) and Sedum roof areas over a flat roof.

4.9 The element linking No.186 Kennington Park Road and 18A Stannary Street would be single storey in height. It would occupy the width of the site with length of approximately 11.5m, rising to a height of approximately 4m above ground level. An external courtyard with timber decking is proposed over the flat roof of this section of the building.

4.10 External materials for No.186 Kennington Park Road building would comprise facing brickwork to elevations punctuated by aluminium framed windows, soffits and reveals. The top storey would be finished in zinc cladding with floor to ceiling glazed door/window openings in powder coated aluminium frames and a Sedum covering over a flat roof.

4.11 The Stannary Street façade is to be retained, including the existing rendered base plinth at ground floor and, it is proposed to lime-render (colour wash) the retained facade. The existing historic timber window openings would also be retained. The new first floor storey behind the retained façade would be finished in brickwork and the second storey façade would be finished in zinc cladding with floor to ceiling glazed door/window openings in powder coated aluminium

9 frames to both front and rear elevations.

4.12 Internal alterations are proposed at No. 184 Kennington Park Road and 20 Stannary Street to enable the linking of these buildings across all levels. Alterations are proposed at the basement level of No.184 Kennington Park Road, which would include the installation of a lift, WC and storerooms. Internal and external courtyards are proposed to the rear of this building.

4.13 The new building is designed to provide disabled and level access links to the adjoining building at 184 Kennington Park Road and 20 Stannary Street. Two separate lift cores are to be located on either street entrance. This would allow access to all floors of the building for wheelchair and ambulant disabled employees and visitors and provide wheelchair access to the first, second and third floors of existing buildings at No’s 184 Kennington Park Road and 20 Stannary Street.

4.14 Refuse and recycling storage would be located at No.20 Stannary Street, which would be accessed externally from Stannary Street as existing. An indicative location for a second refuse store is proposed to the rear of No.18A Stannary Street. A cycle store is proposed to the rear of No.18A Stannary Street for 9 cycle spaces.

4.15 The primary functions on each floor would be as follows:

 Ground Floor: reception, cloak room and lecture room. To the rear a plant room, employee reception, post room, male female and disabled WC’s;  First Floor: office space and;  Second and third floors: office space and meeting rooms.

4.16 It is estimated that the number of employees will increase from current levels of 219 across the entire site to 300 fulltime staff.

4.17 The proposed office operating hours are 07.00am to 22.00pm Monday to Friday and 08.00am to 16.00pm on Saturday.

4.18 The drawings below show the proposed plans, sections and elevations.

10 Fig 1.1 Existing Front Elevation – 186 Kennington Park Road

Fig 1.2 Proposed Front Elevation – 186 Kennington Park Road

11 Fig 1.3 Existing Rear Elevation (of building fronting Kennington Park Road) – 186 Kennington Park

Fig 1.4 Existing Rear Elevation (three storey building) – 186 Kennington Park Road

12 Fig 1.5 Proposed Rear Elevation – 186 Kennington Park Road

13 Fig 1.6 Existing Front Elevation – 18A Stannary Street

Fig 1.8 Proposed Front Elevation – 18A Stannary Street

14 Fig 1.9 Existing Rear Elevation – 18A Stannary Street

15 Fig 1.10 Proposed Rear Elevation – 18A Stannary Street

Fig 1.11 Existing Side Elevation viewed from 184 Kennington Park Road and 20 Stannary Street

16 Fig 1.12 Proposed Side Elevation viewed from 184 Kennington Park Road and 20 Stannary Street

Fig 1.13 Existing Side Elevation viewed from 188 Kennington park Road and 18 Stannary Street

Fig 1.14 Proposed Side Elevation viewed from 188 Kennington park Road and 18 Stannary Street

Fig 1.15 Existing Street View - Kennington Park Road

17 Fig 1.16 Proposed Street View - Kennington Park Road

Fig 1.17 Existing Street View – Stannary Street

Fig 1.18 Proposed Street View – Stannary Street

5 Consultations and Responses

18 5.1 Consultation letters were sent to occupiers of 76 neighbouring properties within Kennington Park Road, Stannary Street and Stannary Place in accordance with agreed procedures. Upon receipt of the revised drawings further consultation by way of letters were sent out to neighbours and amenity groups that had been previously consulted.

5.2 Two site notices were displayed in the vicinity of the site (Kennington Park Road and Stannary Street) on 23.09.14 and a press advert was published in the Weekender Press on 27.08.2014.

Internal consultations

5.3 Internal consultations were undertaken and the responses received are summarised as follows:

Conservation and Design Officers did not support the aspects of the design and scale of the scheme as originally submitted. Revised drawings were received on the 08/12/14 addressing officers concerns. Subject to further design/construction details to be secured by way of conditions, officers support the proposal.

Transport/Highways Officers raised no objection to the proposal subject to conditions requiring a construction management plan being submitted that includes vehicle trips at peak travel times on the adjacent highways

Climate Consulting Officers raised no objection subject to conditions requiring BREEAM certificates for design and post-construction stages and a Final Energy Statement to be submitted including evidence of compliance with the submitted energy strategy.

Planning Policy Officers raise no objection and consider that the application is policy compliant (Policies S3 of the Core Strategy and saved Policy 23 of the UDP).

Regulatory Services – Noise Pollution No objection to the proposal subject to a condition that the applicant follow the recommendations made in their consultant’s Noise report that accompanied the application.

Regulatory Services – Land Contamination No objection to the proposal; officers consider the site investigation report submitted by the applicant and the conclusion and recommendations made within the report to be sound.

Parks Project Officer – Biodiversity Officers have no objection to the proposal and consider that the proposed development would have no adverse impacts on the adjacent park and its biodiversity. Proposals to provide appropriate external landscaping would have visual and biodiversity benefits to the area.

19 Neighbourhoods and Investment No planning obligations are required for construction training/local labour and general employment and training.

Streetcare No response had been received at the time of writing this report.

External consultation

5.4 The following statutory consultees and amenity groups were consulted their responses are summarised as follows:

Environment Agency Raised no objection to this proposal.

Transport for London (TfL) Raised no objection to the proposal subject to conditions including a Construction Logistics Plan to be submitted for their review.

London Underground Infrastructure Raised no objection to the proposal subject to conditions.

Friends of Kennington Park Raised no objection to the proposal but would like some CIL money obtained from the development to benefit Kennington Park.

5.5 During the consultation process, 4 letters of objection were received. The issues raised in objection to the proposal are summarised in the Table below together with an officer response to the material planning issues raised.

No. of Letters No. of Objections No. in support Comments sent 76 4 1 0

Objections: Officer Response:

The scale and massing of the The proposed massing and scale to the Stannary proposed development with Street building would be larger than the existing, but particular regard to the Stannary buildings within this part of Stannary Street vary in Street building would have a depth and height. The existing façade to Stannary negative impact on the Street is to be retained and refurbished and it Kennington Conservation Area. noted that there is no distinct character to the rear of the site, which it would be desirable to preserve. The Council’s Conservation and Design officers have been involved in discussions with the

20 applicant and are satisfied that the proposed replacement building would not have an adverse impact on the character and appearance of the conservation area.

The proposed Stannary Street Within this part of Stannary Street and on the building would extend beyond the opposite side of Stannary Street, the buildings are rear elevations of the adjoining arranged in a haphazard manner with no clear rear buildings. It would not be in building line distinction between properties fronting keeping with the existing rear Stannary Street and those fronting Kenning Park building line within this row of Road. This is historic development of this Stannary Street and would harm commercial part of the area and is evidently unlike the spatial character of the area. the neighbouring residential streets to the north- east of the site for example in Ravensdon Street, Methley Street and Radcot Street where there clear building rear building lines with properties on adjoining streets separated by rear gardens albeit of varying depths and size.

This part of Stannary Street to the north-east of the site including No.28-32 Stannary Street and to the north-west up to the corner of Stannary Street and Kennington Road, and directly opposite the site is located within a commercial area that is described as a KIBA. It is not uncommon to have varying rear building lines within these areas unlike the more residential areas where the uniformity of rear building lines has been protected by planning policy.

Given the above it is not considered that this proposal would harm the spatial character of the area.

The proposed building fronting The two buildings to either street frontages are Stannary Street would encroach considered to be in keeping with the existing into the rear space between adjoining building in each street. Whilst they are of Stannary Street and Kennington a larger mass and scale than the existing building Park Road, combined with the they are to replace, they would maintain a clear gap increased massing of the between them, which in terms of size, would equate Kennington Park Road Building with the gap between the existing building. The would create a sense of removal of the existing 3 storey building in the enclosure for the occupants of middle of the site would improve the spatial aspects the neighbouring buildings. of neighbouring occupiers at best or otherwise have a minimal impact on their outlook. A detailed assessment of this spatial relationship is outlined in section 7 .3 of this report.

21 Contrary to Saved UDP Policy As set out in the main body of the report the 47, which seeks to ensure that proposed height and scale of the replacement alterations or extensions to buildings on Kennington Park Road and Stannary buildings in conservation areas Street comparable favourably to that of the should not alter the existing scale adjoining buildings including in particular the of buildings to the detriment or contemporary 4 storey development at 16 Stannary unity of the character of the Street and the contemporary 5 storey development conservation area. known as Beregaria Court at 190 Kennington Park Road .

The council’s Conservation and Design officer reviewed the original scheme as submitted and raised concerns over the height of the Stannary Street building and the loss of this building. The applicant addressed these concerns by reducing the height of the building so that it is now in keeping with neighbouring development and retaining the Stannary Street façade, which is a positive contributor to the conservation area.

The council’s Conservation Officers reviewed the application as amended and are satisfied that the proposed development would not harm the character of this part of the Kennington Conservation Area. . The neighbouring buildings to the The proposed massing and scale to the Stannary south and north of 18a (Stannary Street building would be larger than the existing. Street), are substantially smaller However it would not be out of place within this part in scale. The scale of the of Stannary Street. proposed top floor of the Stannary Street building is higher No.16 Stannary Street, a new building comprising and substantially larger in mass ground and three upper floors, has a rearward than neighbouring buildings projection of approximately 15.5m and an overall fronting Stannary Street. rear projection of 19.9m, albeit the rear of the building is stepped back from the flank elevation Increase in mass to the rear of, facing the subject site at each level to provide a The height of the building at No terrace. The proposed Stannary Street building 186 Kennington Park Road has would extend rearwards for approximately 17.5m. increased, the pitch roof over the No. 1- 28 Beregaria Court, is a five storey three storey rear building now development and extends from Kennington Park becomes a floor. This encroaches rear wards towards Stannary Street. Whiteacre beyond the building line into Mews in Stannary Street has been extended on the Stannary Street. upper floors and rearwards although the proposed building extends slightly beyond this.

The adjacent site at No.20 Stannary Street, which forms part of the application site, has a ground floor extension with a large crown roof that effectively makes this building one and half stories high and would project beyond the proposed building by 2m

22 approximately.

Furthermore, it is noted that this proposal reduces the rearward projection of No.186 Kennington Park Road to take account of the additional rearward projection at No.18A Stannary Street, while maintaining the same separation distance between the properties as existing, this being 11m approximately.

There is no distinct character to the rear of the site that is worth preserving. It is considered that in design terms the appearance of the proposed building when seen from neighbouring properties would not have an adverse impact on this part of Stannary Street.

Would not accord with emerging Policy Q22 (a) of the Emerging local Plan states Local Plan Policy, which requires that development proposal affecting conservation proposals for new development in areas will be permitted where they preserve or conservation areas to respect enhance the character or appearance of and reinforce the established conservation areas by: positive characteristics of the area. (i) Respecting and reinforcing the established, positive characteristics of the area in terms of the building line, siting, design, height, forms, materails joinery, window detailing etc. (ii) Protecting the setting (including views in and out of the area)

As stated above and discussed in more detail in section 7.2 of this report the design, massing, scale and appearance of the proposed building is considered appropriate for this site in the context of the established and emerging urban design

The proposal complies with adopted planning policy and would not run contrary to the aims and objectives of the emerging Local plan as set in Policy Q22 (a) above. In any case the Local plan has limited weight in the consideration and determination of the current application.

The proposal would impact on the Amenity impact on neighbouring occupiers is amenity of neighbouring discussed in detail in the assessment section of this occupants. It is recommended report with regards to daylight/sunlight, that the first and second floor of privacy/overlooking, loss of outlook and sense of the Stannary Street building be enclosure. While there may be some varying setback by 4-5m at the rear. degree of impact in some instances this would not

23 warrant refusal of the application. The immediate impact of the development would be primarily to the occupiers of the non-residential buildings who are not afforded the same protection as occupiers of residential buildings. The new building in Stannary Street is sufficiently removed form the immediately neighbouring residential dwellings at No. 16 Stannary Street

In creating a greater setback on Paragraph 3.23 Of the Kennington Conservation the top floor of the proposed Area Statement refers to massing of new buildings Stannary Street building, this and states that ‘buildings tend to have their largest would achieve a design more in part fronting the street with lesser returns to the keeping with the scale and Rear’. established pattern of existing development and would accord Whilst it is noted that the massing towards the rear with the Kenning Conservation of the building at No.18a Stannary Street would be Area Statement, with regards to increased, the building at No.186 Kennington Road massing. would be pulled back and a distance of 11m would be maintained between the two buildings. This is comparable to the relationship as existing and such the existing spatial relationship with neighbouring properties would not be diminished

Neighbouring resident works as a Construction noise is not a material planning train driver and works nightshift consideration and is controlled under separate and is concerned that building regulatory provisions. The applicant’s attention is works commencing at 8.00am drawn to the provisions of the Environmental Health would not allow the resident Act under which hours of construction and noise sufficient sleep to be allowed to and disturbance on construction sites are regulated. drive trains safely and recommends that building work does not commence until 10.00am.

6 Planning Policy Considerations

National Guidance

6.1 Central Government guidance is contained in the National Planning Policy Framework (NPPF), which was published on the 27th March 2012. This sets out the current Government’s planning policies for England and how these are expected to be applied. It reinforces the Development Plan led system and does not change the statutory status of the development plan as the starting point for decision making.

6.2 The NPPF must now be taken into account in the preparation of local and neighbourhood plans and is a material consideration in planning decisions.

24 Local Development Plan

6.3 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning decisions to be made in accordance with the development plan unless material considerations indicate otherwise. The development plan in Lambeth is the Lambeth Local Development Framework (LDF) Core Strategy (adopted 19 January 2011); and the remaining saved policies in the Lambeth Unitary Development Plan (UDP) 2007: Policies saved beyond 5 August 2010 and not superseded by the LDF Core Strategy January 2011); and the London Plan (adopted July 2011).

The London Plan 2011

6.4 The London Plan was published in July 2011 and replaced the previous versions, which were adopted in February 2004 and updated in February 2008. The London Plan is the Mayor’s development strategy for Greater London and provides strategic planning guidance for development and use of land and buildings within the London region. All Borough plan policies are required to be in general conformity with London Plan policies.

6.5 The key policies of the London Plan considered relevant in this case are:

 Policy 1.1 Delivering the strategic vision and objectives for London  Policy 4.1 Developing London's economy  Policy 4.2 Offices  Policy 4.4 Managing Industrial Land and Premises  Policy 4.7 Retail and town centre development  Policy 5.1 Climate Change Mitigation  Policy 5.2 Minimising carbon dioxide emissions  Policy 5.3 Sustainable Design and Construction  Policy 5.7 Renewable energy  Policy 5.12 Flood risk management  Policy 5.13 Sustainable Urban Drainage  Policy 5.14 Water Quality and Wastewater Infrastructure  Policy 5.15 Water Use and Supplies  Policy 5.17 Waste capacity  Policy 5.21 Contaminated Land  Policy 6.3 Assessing effect of Development on Transport Capacity  Policy 6.9 Cycling  Policy 6.13 Parking  Policy 7.1 Building London’s Neighbourhoods and Communities  Policy 7.2 An Inclusive Environment  Policy 7.3 Designing Out crime  Policy 7.4 Local Character

25  Policy 7.5 Public realm  Policy 7.6 Architecture  Policy 7.12 - Implementing the London View Management Framework  Policy 7.15 Reducing Noise and Enhancing Soundscapes  Policy 8.2 Planning Obligations  Policy 8.3 Community Infrastructure Levy

London Borough of Lambeth Unitary Development Plan (2007): ‘Policies saved beyond 5 August 2010 and not superseded by the LDF Core Strategy January 2011’

6.6 The following saved UDP policies are considered to be of relevance to the assessment of this application:

 Policy 7 Protection of Residential Amenity;  Policy 9 Transport Impact;  Policy 14 Parking and Traffic Restraint;  Policy 31 Streets, Character and Layout;  Policy 21 Location and Loss of Offices;  Policy 23 Protection and Location of other employment uses;  Policy 32 Community Safety/Designing out Crime;  Policy 33 Building Scale and Design;  Policy 35 Sustainable Design and Construction;  Policy 38 Design in Existing Residential/Mixed Use Areas; and  Policy 39 Streetscape, Landscape and Public Realm Design.  Policy 47 Conservation Areas

Lambeth Core Strategy (January 2011)

6.7 The following policies the Core Strategy are considered to be of relevance to the assessment of this application:

 Policy S1 Delivering the Vision and Objectives;  Policy S3 Economic Development  Policy S4 Transport;  Policy S7 Sustainable Design and Construction;  Policy S8 Sustainable Waste Management;  Policy S9 Quality of the Built Environment; and  Policy S10 Planning Obligations.

26 Supplementary Planning Documents (SPDs)

6.8 The following SPD’s and Conservation Area Statement are considered to be relevant to the assessment of this application.

 Kennington Conservation Area Statement (2012);  SPD: Guidance and Standards for Housing Development and House Conversions;  SPD: Safer Built Environments;  SPD: Sustainable Design and Construction;  SPD: S106 Planning Obligations;  Refuse and Recycling Storage Design Guide (2013);  Waste and recycling Storage and Collection Requirements (2006); and  The Council's 'Waste & Recycling Storage and Collection Requirements: Guidance for Architects and Developers' (2006)  Land for Industry and Transport’ Supplementary Planning Guidance 2012

7 Planning Considerations

7.1 The principle of intensification of the office use of the land

7.1.2 The existing buildings to be demolished are currently in office use as indicated in the planning history section of this report. A Lawful Development Certificate was granted in 2011 with respect to the use of the premises at No.186 Kennington Park Road and No.18A Stannary Street as office accommodation (Use Class B1).

7.1.3 A new building to replace the existing buildings is proposed at No.186 Kennington Park Road that would extend rearwards and link into the retained façade to No.18A Stannary street. The proposed building would also link in with the adjacent buildings at Nos. 184 Kennington Park Road and 20 Stannary Street. Alterations to Nos. 184 Kennington Park Road and 20 Stannary Street are proposed as part of this application to facilitate a more effective use and operation of the application site as one entity.

7.1.4 The new building would be used for Class B1 office purposes and as such the redevelopment of the site to provide additional office space is considered acceptable in principle. The matter for consideration is whether the intensification of use of the site for office purposes involving a planned increase in staff employed on the combined site from existing number of 219 staff to some 300 staff is acceptable in land use terms.

7.1.5 In consideration the acceptability of the intensification of the use of the site for office purposes, regard is paid to other material considerations including, in particular, the applicant’s stated need for additional and modern office accommodation, the Council’s local employment policy objectives, the location

27 of the site in a designated Key Industrial and Business Area (KIBA), the potential impacts on the amenity of occupiers of neighbouring buildings and, parking and traffic considerations including the safe and efficient operation of the local highway network. This report considers and assesses each of these planning matters.

The Need for New Office Space

7.1.6 The applicants, the Health and Care Professional Council (HCPC), in their Design and Access Statement have advised that they have been based at 184 Kennington Park Road and 20 Stannary Street (together known as Park House) since 1977. Due to growth in demand for office accommodation over the years they have expanded and now operate from neighbouring sites including Nos. 22 – 26 Stannary Street and 33 Stannary Street.

7.1.7 In support of their proposal they state that the services HCPC has to provide “have been, and are, rapidly growing due to increasing number of registrants, the number of professions it regulates and an increasing number of public tribunals. The need for extra office space to accommodate HCPC’s expanding requirements is critical. HCPC has purchased No.186 Kennington Park Road to fulfil its office expansion needs and to improve disabled access into and throughout their existing premises”.

7.1.8 Core Strategy Policy S3(a) states that the Council will safeguard "Key industrial and Business Areas (KIBAs) for business, industrial, storage and waste management uses, including green industries, and other compatible commercial uses, excluding large scale retail". No 186 Kennington Park Road and No 18A-20 Stannary Street are located within a designated KIBA. The new building would provide office accommodation (Use Class B1a), which is the same use as the existing buildings on the site at No’s 186 Kennington Park Road and 18A-20 Stannary Street. The proposal is therefore compliant with this policy.

7.1.9 Core Strategy Policy S3 (b) seeks to maintain a stock of other sites and premises (not in KIBA’s) in commercial use across the borough subject to the sustainability of the site and location. Policy S3 (f) supports the location of, investment in, major office development in sustainable locations. Saved UDP Policy 23(b) seeks to protect other employment uses outside KIBAs where land is or has been in employment use and in particular B1 business use floorspace. No 184 Kennington Park Road is located outside the designated KIBA boundary. The existing use of this building for office purposes would continue and as such this proposal would not run contrary to these objectives. The proposal to link the new building to the existing office buildings would not constitute a material change in the use of the land or buildings and as such is acceptable in planning policy terms.

7.1.8 The proposal seeks to provide additional and modern employment floorspace in response to the stated growing demand for it. The proposal would create 137.6sqm of additional office floorspace over and above the existing

28 2198.9sqm of office within existing buildings on site. It is estimated that the number of employees will increase from 219 to 300 full time staff. The proposal would be consistent with overarching objective of the Council’s local employment and economic development policies, which give priority to a diverse range of economically beneficial uses in appropriate locations.

7.1.9 In conclusion, the proposal to intensify and provide one integrated building for office accommodation for use by HCPC is considered acceptable in land use terms. The proposal would make a positive contribution to the Council’s stated aims of protecting existing employment uses and promoting new employment opportunities in appropriate locations across the borough. Other considerations, which are related to the intensification of the use of the site for office purposes are discussed in later sections of this report.

7.2 The design of the new building and impact upon the character and appearance of the Kennington Conservation Area

7.2.1 There are two main elements to the assessment of the conservation and design implications of the proposal:

I. The demolition of the existing buildings at 186 Kennington Park Road and part demolition of 18A Stannaryand; II. The design of the replacement building

Saved Policy 47 of the UDP states that development in Conservation Areas should preserve or enhance the character and appearance of the conservation area. Part (c) of this policy states that the Council will resist granting consent for the demolition of a building; or substantial part of a building that makes a positive contribution to a character or appearance of a conservation area.

7.2.2 The proposed demolition works would include No.186 Kennington Park Road, the three storey building to the rear of No.186 Kennington Park Road, the bridge walkway and the single storey rear extension to No.18A Stannary Street. No.18A Stannary Street would be partially demolished with the front façade retained and refurbished.

7.2.3 Both 186 Kennington Park Road and 18A Stannary Street are identified in the Kennington Area Conservation Statement as being positive contributors to the character and appearance of the Kennington Conservation Area. There is generally a presumption in favour of retaining buildings, which positively contribute to a conservation area. National legislation relating to conservation areas provides that where a proposed development will lead to substantial harm to or total loss of significance of a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the following apply:

- the nature of the heritage asset prevents all reasonable uses of the site; and - no viable use of the heritage asset itself can be found in the medium term through appropriate marketing that will enable its conservation; and

29 - conservation by grant-funding or some form of charitable or public ownership is demonstrably not possible; and - the harm or loss is outweighed by the benefit of bringing the site back into use.

7.2.4 The applicants have provided evidence that the Kennington Park Road building have been significantly altered by previous extensions and alterations brought about by consents granated by the Council as set out in section 3 of this report. . The conservation officer considers this evidence of significant alterations to the original building a robust justification for demolition of the building at No. 186 Kennington Park Road and, in officers’ opinion, the building is now considered to be a neutral contributor to the character and appearance of the conservation area. Accordingly the demolition of the buildings at No.186 Kennington Park Road is considered acceptable in principle.

7.2.5 The initial drawings submitted with the application proposed demolition of the Stannary Street building in its entirety. In support of the proposal to demolition this building, applicants have stated that substantial public benefits afforded by a contemporary replacement building would outweigh any harm or loss that arises from the demolition of the building. They contended that the new building would be well designed and would achieve an BREEAM excellent rating of very good, it comply with part M of the Building Regulations and that need for addional and modern office accommodation by HCPC, which is an important public body working for public good, out-weight the Council’s wish to retain the building.

7.2.6 They further refer to marketing survey (of the buildings) undertaken by property agents, Property Facets, which concluded that the existing building was unsuitable for use for office purposes in its current form and footprint. The property agents’ report stated as follows:

“It is self evident that the property is very narrow relative to its depth and, despite having entrances on both elevations, the means of escape requirements impede efficient use of the usable floor area. Furthermore, and this was possibly the critical aspect, the structurally divided nature of the accommodation no longer lends itself to modern collaborative working practices. It wasn’t a matter of price – it was made clear that any offer will be considered – but the limitations of the present building design that deterred buyers. Whilst the main façade may appeal, setting aside the recent mansard addition, the remainder of the building is no longer fit for modern use, irrespective of any refurbishment scheme, given its footprint.”

7.2.7 The Council’s Conservation and Design officer maintains that although previously modified, the Stannary Street façade retains it historic character and is a significant contributor to the character and appearance of this street. The benefits of part M compliant access and other improvements proposed could all be achieved by building behind a retained street façade with minimal alteration and repair to the existing façade. Consequently, applicant was advised that if

30 the Stannary Street façade were not retained, officers would not support the proposals.

7.2.8 The applicant submitted revised drawings on the 08/12/14, which propose the retention of the Stannary Street façade. The significance of this building is its historic façade and character.The Council’s Conservation and Design officers have agreed to demolition behind a retained façade to enable the applicants to achieve their objectives for extending and improving the office accommodation on site.

7.2.9 Given the above considerations and, having regard to the exceptions clause which permits demolition of a building of heritage importance, demolition of the buildings at No.186 Kennington Park Road and part demolition of 18A Stannary Street is considered acceptable. The matter for consideration is whether the proposed replacement building would make a positive contribution to the local distinctiveness of the area and whether it would enhance the character and appearance of this part of the conservation area.

II. The design of the replacement building/ impact on the Conservation Area.

7.2.10 Government guidance in the NPPF states that good design is a key aspect of sustainable development, is indivisible from good planning, and should contribute positively to making places better for people. The NPPF further states that although visual appearance and the architecture of individual buildings are very important factors, securing high quality and inclusive design goes beyond aesthetic considerations. Therefore, planning policies and decisions should address the connections between people and places and the integration of new development into the natural, built and historic environment.

7.2.11 Saved Policy 47 (a) of the UDP states that development proposals in a conservation area should preserve or enhance the character or appearance of the conservation area. It further states at Policy 47 (c) that replacement buildings should follow the provision contained within Policy 33 of the UDP and the opportunity to redevelop within a conservation area should be seen as a stimulus to imaginative, high quality design. Core Strategy Policy S9 seeks the highest quality of design in all new buildings and, in general requires new development to be of an appropriate height, scale and massing that is compatible with its context.

Layout and Siting

7.2.12 Saved Policy 31 of the UDP requires that new developments should, where possible, retain or contribute to a clear urban grain and follow appropriate block widths, gaps and spaces between buildings thereby helping to add to the connectivity of the street blocks. Individual buildings should address the street with frontages and entrances and, should create or enhance views and vistas.

7.2.13 The replacement building pays due regard, where possible, to the established urban grain and is considered to be successful in following the established building lines along Kennington Park Road and Stannary Street and, maintains appropriate gaps and spaces between it and existing buildings. On the

31 Kenningon Park Road frontage the building follows the building line of the existing building on site, which is similar to that of adjoining building at No. 184 Kennington Park Road and other buildings in this part of the street. The only exception to this common building line is the adjacent building at No. 188 Kennington Park Road, which has a single storey element that projects forward of the historic street building line. The Stannary Street façade is to be retained and therefore the building line along Stannary street would be maintained. It is considered that the proposal would successfully fit into the streetscenes.

7.2.14 Concerns have been raised by objectors with regards to the proposed rear building line particularly at first and second floor level of the proposed building fronting Stannary Street. The building at these levels would extend beyond the rear elevations of either of the adjoining buildings in both streets. There is therefore concern that the proposed building would disrupt established rear building lines and as such fail to follow the existing pattern of development in the area.

7.2.15 However, it is evident from the submitted OS Map and recent aerial photography that within this part of Stannary Street and Kennington Park Road, buildings are arranged in a haphazard manner with no clear rear building line distinction. Conversely the neighbouring residential streets to the north-east for example in Ravensdon Street, Methley Street and Radcot Street have clearly delineated and defined rear building lines, which describe the historic urban grain with gardens separating neighbouring properties in these adjoining streets.

7.2.16 Moreover, this part of Stannary Street (to the north-east of the site including Nos. 28-32 Stannary Street and to the north-west up to the corner of Stannary Street and Kennington Road, and directly opposite the site) is located within a commercial area that is designated as a KIBA. It is not uncommon to have varying rear building lines within such areas unlike in residential areas where planning policy seeks to protect the uniformity of historic rear building lines in the interests of both visual and residential amenity. In this case there is no clear rear building line which it would be desirable to preserve on visual amenity grounds.

7.2.17 The rear building line of the building fronting Stannary Street at the upper floors would be extending further rearwards than those of the adjoining commercial buildings. The rear building line of the building fronting Kennington Park Road at the upper floors would be setback from existing levels by approximately 11m, leaving an approximately 11m X 8.6m space between the two buildings. In spatial terms this is similar to the existing situation. As such the proposed layout of the building including its rearward projection into the site above ground level would not be out of keeping with the established urban grain and, would retain appropriate gaps between buildings on either street frontages and the existing buildings on either side of the site. The potential impact of breaching the existing building lines as a result of the layout and siting of the new building is discussed in the residential amenity section of this report.

Height, Scale and Massing

32 7.2.18 With regard to height, massing and scale, reference is made to Policy 33 of the UDP, which states that infill development should be compatible with the height, massing and scale of neighbouring buildings. The design approach that has been chosen is considered appropriate for this site. The proposed scheme would result in a building whose form, height, scale, massing and general design would integrate well within the streetscene in both Kennington Park Road and Stannary Street.

7.2.19 Concerns have been raised by objectors regarding the massing and scale of the proposed buildings; contending that the proposal would be out of keeping with neighbouring development and the Kennington Park Conservation Area.

7.2.20 The existing buildings along Kennington Park Road, within the vicinity of the site, vary in height, which increases towards the west of the site and decreases towards the east of the site. The proposal takes its design cue from the existing building heights in the immediate area. It is acknowledged that the height of the proposed building at186 Kennington Park Road would be slightly higher than the adjacent Park House (184 Kennington Park Road). However, given the evident mix of heights within this part of Kennington Park Road, the height of this part of the building would relate satisfactorily with neighbouring buildings in Kennington Park Road.

7.2.21 The proposed building at No.186 Kennington Park Road would a have shorter rearward projection compared to that of the existing building; it would be approximately 24m deep compared to the existing, which is approximately 31m deep including the 2 storey link bridge building and the 3 storey builing further to the rear. The reduction in the rearward projection of the building above ground floor level would be compensated by the increased overall height of this part of the building to 4 storeys. This increase in height and mass compares favourably with the neighbouring 5 storey residential development known as Beregaria Court at 190 Kennington Park Road.

7.2.22 It is considered that the massing and form of new building on this part of the site would be comparable to that of the adjacent building at No.184 Kennington Park Road. This neighbouring building terminates in a flat roof and rises to a height of four storeys. The proposed building would be of similar massing, height and form. When viewed from properties in Stannary Street, the replacement building would present similar massing, scale and form to the existing neighbouring building in Kennington Park Road.

7.2.23 A number of originally two storey properties on Stannary Street have had an additional storey added to them including the property adjoining the site at No.20 Stannary Street. No 16 Stannary street is a contemporary re- development of 3 storey height. Over half the properties on this side of Stannary Street have accommodation over 3 floors and as such an additional storey proposed to the Stannary Street frontage of the new building would not have an adverse impact on the streetscene.

7.2.24 The proposed massing and scale to the Stannary Street building would be

33 larger than the existing, but as discussed above, buildings within this part of Stannary Street vary in depth and height. When viewed from properties in Kennington Park Road, the replacement building would present similar massing, scale and form to the existing neighbouring building in Stannary Street.

7.2.25 In conclusion, the height, massing and scale of the proposed building on both frontages are considered appropriate in design terms. In the context of existing development in both streets, the proposed building would not be out of keeping with neighbouring development or harm the character and appearance of the Conservation Area.

Detailed Design and Materials

7.2.26 Saved Policy 33 (b) and Policy S9 of the Core Strategy require development to be of high quality design and contribute positively to its surrounding area and that infill development should be compatible with the colour, type, source, and texture of local materials. These objectives are supported by Saved Policy 47 of the UDP in relation to development in conservation areas, where redevelopment is expected to provide opportunity for imaginative, high-quality design.

7.2.27 The elevation on Kennington Park Road will be finished brickwork with floor-to- ceiling fenestration. The windows will have aluminium soffits and reveals, accommodated within a brick framework. The three bay window treatment of the new brick façade draws inference from the design of the existing frontage but with a simplified and contemporary treatment and without the stone embellishments except for the ground floor entrance canopy. The ground floor is recessed with a pre-cast concrete cement finish, punctured by a centred revolving door. Officer support the proposal subject to the imposition of appropriate conditions to control the construction details and materials.

7.2.28 The applicants have taken on board officers' concerns in relation to the replacement building on Stannary Street. Officers support the retention of the existing historic window openings and the reinstatement of the top hung sliding sashes. The proposed alterations to the existing door, which are intended to replicate the detailing of the adjoining window opening and the creation of a double door within the recessed area, are considered acceptable. Details of its construction to lend it an industrial aesthetic, which is considered to be appropriate for the period of the retained façade, are reserved by condition.

7.2.29 Lift shafts servicing entrance atriums on both the 186 Kenning Park Road and the 18A Stannary Street frontages would be located underneath Sedum flat roofs. The flat roofs would accommodate solar collectors or photovoltaic panels. A plant area is proposed to the roof of the building fronting Kennington Park Road to be located behind a parapet wall. Another plant area proposed to the roof of the building fronting Stannary Street would be located behind the lift shaft and therefore would not be readily visible within the street. Conditions to ensure that the PVs and proposed plant are appropriated located and screened in the interests of visual amenity are recommended.

34 Protected Vista

7.2.30 The site lies within the Protected Vista from Primrose Hill Summit to the Palace of Westminster (LVMF 2010), which requires development in the background of the Palace of Westminster to preserve or enhance a viewer’s ability to recognise and appreciate the Strategically Important Landmark.

7.2.31 As discussed above, the proposed building would have a similar layout to the existing. The height of the building at 186 Kennington Park Road would be comparable to the existing building’s height. Whilst the depth and height of the building at No 18A Stannary Street would exceed the depth and height of the existing building, additional storey height is considered appropriate in the context of the scale of the adjacent buildings within the street. In the circumstances, it is considered that the proposal would not adversely impact upon a viewer’s ability to recognise and appreciate the Strategically Important Landmark of Westminster Palace

Landscaping, Boundary Treatment and Biodiversity

7.2.32 Saved Policy 39 of the UDP encourages development to include landscape design that enhances the area and reflects the character of surrounding built environment. This objective is reiterated in Saved Policy 47 in relation to development within conservation areas.

7.2.33 The applicant has submitted drawings, which illustrate a proposed landscaping scheme including the treatment of the forecourt on the front of the building on Kennington Park Road; to a first floor level courtyard within the site and; for the two courtyards at basement level to the rear of No.184 Kennington Park Road. In addition, green Sedum roof are proposed to areas of flat roof on the two street frontage blocks of the building. Given the site is relatively constrained in terms of opportunities for external landscaping, the outline proposals are considered appropriate and would enhance the appearance of this part of the conservation area.If minded to grant planning permission further details of these aspects of should be secured as a condition of consent.

7.2.34 Stone setts on the forecourt of No.186 Kennington Park Road with railings to replace the existing bollards at the edge of pavement are proposed. Care will need to be taken with regards to the design of the railings and the proposed setts; they need to reflect the status of the buildings position on Kennington Park Road. Officers support the proposal subject to the imposition of appropriate conditions to any consent requiring details of all boundary treatment and hard landscaping to be submitted for further review.

7.2.35 In terms of biodiversity, the application site is not part of any protected or designated area of nature conservation, although it is opposite a Local Site of Importance for Nature Conservation (Local SINC) in the form of Kennington Park. The Council’s Parks and Open Space officer has advised that that the proposed development would not affect the ecological value of Kennington

35 Park as a local SINC.

7.2.36 There are no protected species known to exist on the application site. An informative is nevertheless recommended reminding the applicant of their obligations to have appropriate protocols and measures in place prior to any demolition works commencing so that should bat roosts be found measures can be instigated to protect them.

7.2.37 In conclusion, the principle of demolition is considered acceptable and the proposed new replacement building fronting No.186 Kennington Park Road and the replacement building behind the retained façade to Stannary Street would be appropriate within its context and would not cause harm to the character and appearance of this part of the Kennington Park Conservation Area. The proposal therefore complies with Saved Policies 33, 39 and 47 of the UDP and Policy S9 of the Core Strategy.

7.3 Impact on the amenity of neighbouring residents/occupiers

7.3.1 Saved Policies 7, 33 and 38 of the UDP and Policy S2 of the Core Strategy, deal with amenity and, seek to ensure that new development does not unacceptably harm the amenities (privacy, outlook, sunlight and daylight) of adjoining occupiers, create an unacceptable sense of enclosure or cause noise nuisance and disturbance.

Sunlight and Daylight

7.3.2 New buildings should be of a scale and design that protects the amenity of neighbouring residential properties by not adversely significantly affecting existing levels daylight and sunlight. The applicant has submitted a daylight and sunlight report prepared by Right of Light Consulting, dated 25 July 2014. The assessment has been carried out using the methodologies set out in BRE guide (BRE guidance 'Site Layout Planning for Daylight and Sunlight (2011)) and British Standard Guidelines.

7.3.3 The BRE Guide contains two tests, which measure diffuse daylight to windows. The first test is the Vertical Sky Component [VSC] (expressed as a percentage of the sky visible from the centre of a window). Diffuse daylight may be adversely affected if after a development the Vertical Sky Component is both less than 27% and less than 0.8 times its former value. The second test is daylight distribution, the BRE guide states that where room layouts are known, the impact on the daylighting distribution can be found by plotting the ‘no sky line’ in each of the main rooms. The no-sky line is a line which separates areas of the working plane that can and cannot have a direct view of the sky. Daylight may be adversely affected if after the development the area of the working plane in a room which can receive direct skylight is reduced to less than 0.8 times its former value. Daylight may be adversely affected if after the development the area of the working plane in a room which can receive direct skylight is reduced to less than 0.8 times its former value. A sunlight assessment only needs to be undertaken in relation to windows of a neighbouring property, which face within 90 degrees of due south. Sunlight may

36 be affected if after a development the centre of the window receives less than 25% of annual probable sunlight hours between 21 September and 21 March and receives less than 0.8 times its former sunlight hours during either period and has a reduction in sunlight received over the whole year greater than 4% of annual probable sunlight hours.

7.3.4 The impact on nearby residential dwellings at Nos.1-28 Beregaria Court and 16 Stannary Street located to the north-west of the site were assessed. These properties are separated from the application site by buildings and land at No.188 Kennington Park Road and No.18 Stannary Street, respectively. No 18 Stannary Street is in commercial use and contains no windows servicing rooms, which require natural lighting and therefore was not included in the assessment.

7.3.5 The impact on No. 182 Kennington Park Road, located to the north-east of the site has been assessed. This site is separated from No.186 Kennington Park Road by the building and land at No.184 Kennington Park Road. Although No.184 Kennington Park Road forms part of the application site, the works proposed to it do not include extensions and therefore would not affect natural light levels at the dwelling at No. 182 Kennington Park Road.

7.3.6 With regards to No.1-28 Beregaria Court, the report found that many of the habitable rooms with windows facing onto the application site currently receive natural light levels below BRE recommended values for daylight. However, the loss of daylight as a result of the proposed development would not be greater than 0.8 times than the existing values for the majority of the windows with the exception of windows annotated as Nos. 29, 30, 33 and 34 within that residential development. The rooms serviced by these windows would experience loss greater than 0.8 times their existing values and as such would fail the BRE test for daylight.

7.3.7 The report concludes that the light to these windows “is hampered by existing balconies and or/projecting wings” rather than by the proposed development. The BRE guide acknowledges that where a window has an overhang or projecting wing on one or both sides of it, a larger relative reduction in VSC may be unavoidable, as the building itself contributes to its poor daylighting.

7.3.8 In the circumstances, the consultants have carried out a further test, which has assessed what the daylight levels would have been without the balconies or projecting wings being in place. If the windows meet the BRE recommended values in this test the assessment would confirm that it is the balconies and projecting wings that prevent the BRE targets from being met as opposed to an unreasonable level of obstruction caused by the proposed development. The windows in question pass the alternative test and as such the proposed development would not be the cause of the existing poor lighting levels received within rooms serviced by the identified windows.

7.3.9 All windows, which face within 90 degrees of due south within 1-28 Beregaria Court have been tested for loss of sunlight in accordance with BRE guidelines. The report found that all windows passed both the total annual sunlight hours test and the winter sunlight hours test.

37 7.3.10 In relation to residential properties at No. 16 Stannary Street, the Daylight/Sunlight Assessment found that currently the majority of the windows servicing habitable rooms receive daylight levels below the recommended BRE values. However, the loss of daylight as a result of the proposed development would not be greater than 0.8 times for all these windows and as such proposal would not cause demonstrable or noticeable loss of daylight to these properties.

7.3.11 All windows, which face within 90 degrees of due south at 16 Stannary Street have been tested for loss of sunlight. The daylight and sunlight report found that all windows pass both the total annual sunlight hours test and the winter sunlight hours test.

7.3.12 In relation to No. 182 Kennington Park Road, the report found that currently the majority of the windows servicing habitable rooms receive daylight above the BRE guide recommended values with the exception of windows annotated as windows 67, 71 and 74. Nevertheless, the rooms serviced by these windows would not experience loss of daylight greater than 0.8 times existing values and as such the proposal would not cause demonstrable or noticeable loss of daylight to these properties.

7.3.13 All windows, which face within 90 degrees of due south at 182 Kennington Park Road have been tested for loss of sunlight. The report found that all windows pass both the total annual sunlight hours test and the winter sunlight hours test.

7.3.14 In relation to overshadowing of neighbouring gardens and open spaces, the consultants assessed the garden to the front of No. 1-28 Beregaria Court and the rear garden of No.182 Kennington Park Road. The report found that the proposed development would not lead to a noticeable overshadowing of these gardens as measured according to BRE guidelines.

7.3.15 The report has been reviewed by officers. Its interpretation of the BRE guidelines was found to be correct and its conclusions are considered sound. It is officers’ consideration that neighbouring residential buildings would not suffer a noticeable loss of sunlight or daylight as a result of the proposed development.

7.3.16 There are residential properties at rear ground, first, second and third floor levels of No.188 Kennington Park Road. This building is bank premises at ground floor level to the front. There are a number of windows located to the rear elevation of this building, which are approximately 4m away from the side boundary wall of No. 186 Kennington Park Road. All these windows are all north facing and it is noted that the proposed building would be of similar height and scale to the existing building on the application site, with its rear elevation projecting much less into the site than the existing buildings. In the circumstances, it is considered that the proposed development would not unduly impact upon the sunlight and daylight received into the rooms serviced by the rear windows of these residential properties.

38 Privacy and Overlooking

7.3.17 The proposed rear elevation of the replacement building at 186 Kennington Park Road would contain floor-to-ceiling windows at first, second and third floors levels. Views from these windows would be directed internally within the site towards the windows in rear elevation of the proposed replacement building fronting 18a Stannary Street. Views towards neighbouring buildings would be oblique and, with the exception of No. 16 Stannary Street, would be towards commercial buildings and in all case over separation distances of over 11m. It is considered that occupiers of these neighbouring commercial or residential buildings would not suffer undue loss privacy as a result of the proposed development.

7.3.18 No 16 Stannary Street is located diagonally opposite to the north east of the site and is separated from the subject site by 18 Stannary Street. The upper floors (2nd and 3rd) are in residential occupation and have terraces facing directly onto 188 Kennington Park Road. It is accepted that there could be some perceived lateral overlooking of the rear terraces of this property from the rear elevation windows of the proposed building. However, given the separation distances between the two buildings and the oblique views afforded from the new building, it is not considered that the proposal would cause an unacceptable loss of privacy and overlooking to the occupiers of these properties.

7.3.19 There are concerns over overlooking of residential properties at No 188 Kennington Park Road at and No.128 Beregaria Court (190 Kennington Park Road). Berigaria Court has balconies (which allow access to the units) facing onto application site. There is a separation distance of approximately 15m between the flank wall of Beregaria Court and the flank wall of the proposed building.

7.3.20 It is proposed to locate double width windows at second and third floors levels within the rear elevation of the proposed replacement building at 186 Kennington Park Road and a first floor level window within its flank elevation. There are currently a number of windows (3 windows at each first and second floor levels) located within the flank elevation of the three storey building to the rear of 186 Kennington Park Road. There are large glazed panels (three on each upper floor) within the two storey bridge link, which overlook No 188 Kennington Park Road and No.1 – 28 Beregaria Court. In the circumstances, and given the separation distance between application site and No.1-28 Beregaria Court, it is considered that there would not be a demonstrable loss of privacy to the occupiers of these neighbouring properties to a greater extent than the existing situation described above allows.

7.3.21 Notwithstanding the above spatial relationship, given that the rear of No.188 Kennington Park Road, the second and third floors of No. 16 Stannary Street and No. 1-28 Beregaria Court are all in residential use, it is recommended that a condition is imposed requiring the proposed facing windows within the flank elevation of the proposed replacement building at No.186 Kennington Park Road to be obscure glazed to a height of 1.7 metres above floor level.

39 7.3.22 A row of 5 small windows, adjacent to one another, are proposed in the flank wall of the proposed building at the first, second and third floor levels, which would face onto No.184 Kennington Park Road and No.182 Kennington Park Road and beyond. Although there are currently a number of windows located within the flank elevation of the existing four storey building, it is considered likely that occupiers of the adjacent residential property at 182 Kennington Road would be overlooked by the proposed facing windows. Window. It is recommended that a condition be included on any consent requiring these windows to be obscure glazed and unopenable to a height of 1.7m above finished floor level (FFL).

7.3.23 A large expanse of glazing is proposed to the flank elevation of the single storey link building facing No.184 Kennington Road (forms part of the application site). These windows overlook the proposed rear of courtyard (No.1) of No.184 Kennington Park Road and would face directly towards the flank boundary between No.184 Kennington Park Road and No. 182 Kennington Park Road. Given the proposed windows would face the courtyard within the application site itself, and is separated from No.182 Kennington Park Road by the existing boundary treatments, it is considered that the neighbouring property at 182 Kennington Park Road would not be overlooked.

7.3.24 The proposed rear elevation of the replacement building at No. 18A Stannary Street would have floor-to-ceiling fenestration at 1st and 2nd floor levels. Views from these openings would be directed internally within the site towards the replacement building fronting Kennington Park Road. Views towards the residential properties at 182 and 188 Kennington Park Road on either side of the application site would be oblique and from a distance of over 20m away and therefore occupiers of these properties are unlikely to be unduly overlooked via these window openings.

7.3.25 A landscaped courtyard (annotated as courtyard 2 on the submitted drawings) is proposed over the roof of the single storey link building in the centre of the site. This would allow unobstructed views towards neighbouring properties in Stannary Street and Kennington Park Road. In order to safeguard the privacy of the occupiers of these properties a condition is recommended requiring the provision of privacy screens to the sides of the courtyard. The hours of use of the courtyard would also be restricted by condition to prevent noise and general disturbance associated with its use during the evening/night-time. The other two courtyards within the development are at basement and ground floor levels to the rear of 184 Kennington Park Road and therefore raise no overlooking concerns.

Outlook and Sense of Enclosure

7.3.26 The front building line of the replacement building fronting onto Kennington Park Road would be in the same position as the existing building. Given this and its massing and height it is considered that the proposal would not have an impact on the windows within the front elevation of the adjoining properties in

40 Kennington Park Road in terms of outlook. The Stannary Street façade is to be retained and thus, this element of the building would not affect the outlook of its neighbours.

7.3.27 In relation to No.188 Kennington Park Road, the main consideration is the harm that the additional increase in height and the siting of the building closer to the boundary with this property would cause. As noted above, this property has several windows at ground and first floor levels, which are located approximately 4m away from the boundary with the application site. Outlook from these windows towards the application site is currently constrained by the existing four storey building, the two storey link building and the 3 storey building to the rear of 186 Kennington Park Road. Notwithstanding the increased height at the boundary, the outlook of occupiers of these properties would not be significantly affected by the proposal. The reduction in the rearward projection of the building on the application site from 31m to 17.5m would improve open aspects towards the site and beyond. Existing views to the rear of the site and to the north-east of the site would not be affected.

7.3.28 No.1-28 Beregaria Court has windows, doors and access balconies, which face towards the application site. However, this residential building is separated from the application site by No 188 Kennington Park Road over a gap of approximately 15m. In the circumstances, the outlook of these neighbours would not be adversely affected by the proposed development.

7.3.29 No.182 Kennington Park Road would be separated from the new replacement building by No. 184 Kennington Park Road. Given this separation between the two sites the new building would not affect the outlook for the occupiers of this neighbouring property nor would it create a sense of enclosure when viewed from its rear garden.

7.3.30 The other neighbouring properties, which stand to be affected by the proposed development, are those in Stannary Street comprising Nos. 16 and 18. No 18 Stannary Street is located to the south-west of No.18A Stannary Street. The proposed building would have an additional storey and the rear of the building would project beyond the elevation of No.18 by approximately 6m at first floor level and by approximately 6.5m at second floor level. Whilst occupiers of the building would suffer some loss of outlook towards the site, views to towards the neighbouring site at No. 16 Stannary Road would not be an affected. Given the commercial use of this building, it is not considered that the application can be refused on grounds of loss amenity resulting from this development proposal.

7.3.31 No 16 Stannary Street is separated from the application site by No. 18 Stannary Street, a distance of approximately 10m. It has 2 two bedroom flats at second and third floors levels over office accommodation at ground and first levels. The rear of the building is stepped back from the flank elevation facing the subject site at each level and from the rear elevation to provide inset terraces. There is a small window located on each floor within the flank elevation of the rear projection. This is only openable to allow ventilation into a bedroom. There no other window openings within the flank elevation of this

41 building; windows are located to the rear elevation facing directly onto No. 188 Kennington Park Road and 1-28 Beregaria Court and to the front facing onto Stannary Street.

7.3.32 The outlook towards the application site from the terraces and/or windows of these dwellings is oblique and over the plot occupied by the No. 18 Stannary Street. Given the separation distance between the two sites and the nature of outlook afforded to the occupiers of these properties, it is not considered that the proposal would cause an unacceptable loss of outlook or create a sense of enclosure to the occupiers of these neighbouring properties.

Noise and Disturbance

7.3.33 In assessing development proposals, local planning authorities are required to ensure that development does not cause unacceptable noise nuisance and/or general disturbance to existing residents. Where subsequent intensification or change of use may result in greater noise and/or general disturbance, planning policy recommends the use of appropriate conditions to mitigate the impact of a development proposal.

7.3.34 A plant area is proposed to the roof of the building fronting Kennington Park Road and another to the southern part of the roof of the building fronting Stannary Street.

7.3.35 The applicant has submitted a noise report, prepared by Bickerdike Allen Partners, dated 25th July 2014 which assesses the impact of the plant and associated equipment to be on the roofs of the building, on the amenities of surrounding occupiers. The Consultants concluded that noise issues can be adequately addressed in the scheme design and should therefore not impede any decision to grant planning permission.

7.3.36 The Consultants outline the mitigation measures in a detailed acoustic, which include a noise barrier to be installed between the plant area and the surrounding residences. The Council’s noise officer has reviewed the submission and raised no objection to the proposal subject to a condition requiring the applicant to follow the recommendation contained within the submitted noise assessment report. It is also recommended that a condition be imposed requiring details of the noise barrier together with a plant enclosure to be submitted to and approved by the local planning authority in the interests of visual amenity.

7.4 Transport implications of the proposal

7.4.1 Saved Policies 9 and 14 of the UDP and Policy S4 of the Core Strategy are relevant with respect to transport and highway matters. These policies seek to ensure that proposals for development have a limited impact on the performance and safety of the highway network and that sufficient and appropriate car parking and cycle storage is provided whilst meeting objectives to encourage sustainable transport and to reduce dependence on the private car.

42 7.4.2 Saved Policy 9 of the UDP states that planning applications will be assessed for their transport impact, including cumulative impact on highway safety, on the environment and road network and all transport modes including public transport. Any increase in traffic generated by development should not increase levels of traffic congestion, lead to a situation where the condition of highway safety is reduced, cause material harm to the speed and/or reliability of bus and other public transport services. If development would have an unacceptable transport impact, it should be refused in the absence of mitigation measures to make the development acceptable.

7.4.3 The site has a Public Transport Accessibility level (PTAL) rating of 6a, which is categorised as “Excellent”. The site is located within the Controlled Parking Zone (CPZ) ‘Kennington K’, which is in operation from Monday to Friday between 8.30am to 6.30pm.

7.4.4 No off street parking is proposed on the site, nor is there existing parking on- site. The site is within close proximity to trains (London Underground) and is well serviced by buses.

7.4.5 A revised Transport Statement and Travel Plan were submitted, which take into consideration the correct existing and anticipated staff numbers. The original statement and plan were based on existing staff numbers being 80 staff and anticipated to increase to 240. The revised statement and plan are based on existing staff being 219 increasing to 300 staff.

7.4.6 Based on the assessment presented in the revised Transport Statement, ML Engineers have concluded that the impact of the projected public transport trips associated with the additional staff numbers and visitors to the site can be conveniently accommodated by the local transport network given the site’s excellent PTAL rating. The revised Green Travel Plan illustrates how the applicant proposes to reduce the staff reliance on the motorcar.

7.4.7 The Council’s Transport Planner has reviewed the revised Transport Statement and Travel Plan. The officer considers the statement and plan acceptable but recommends that an ATTrBuTE analysis should be submitted with a Final Travel Plan to be approved by the local planning authority A condition to this effect is recommended.

7.4.8 There is an existing dropped kerb to the rear of No. 20 Stannary, which services an existing plant area. The plans have been annotated to indicate that this crossover would be reinstated as footway. A condition to secure this is recommended.

7.4.9 A cycle store is shown on the plans; located internally within the building at No.20 Stannary Street, which would be accessed via Stannary Street. The store would be able to provide accessible and adequate storage for 9 bicycles. The proposed number of cycles associated with the development is consistent with the requirements for cycle storage for new offices contained in the London Plan. A condition to requiring submission of details of the layout of the store is

43 recommended.

7.4.10 The site of the proposed development is on A3 Kennington Park Road, which forms part of the Transport for London Road Network (TLRN). There is also a cycle super highway running along the A3 Kennington Park Road directly outside the site. TfL is the highway authority for the TLRN. The application was referred to TfL who support a car free development on the site and consider the impact of the proposal on th public transport network acceptable.

7.4.11 To ensure that the development does not have a negative impact on the TLRN, TfL have requested that the applicant provides information on the delivery and servicing arrangements for the building. A condition to secure these details is recommended. In addition, TfL have requested that a Construction Logistics Plan (CLP), which identifies efficiency and sustainability measures to be undertaken while developments are being built is submitted to and approved by Lambeth in conjunction with TfL before construction work commences on site. The CLP would also need to outline measures to be undertaken to ensure that the functionality of the cycle super highway running along the A3 Kennington Road is not compromised during construction.

7.4.12 The application site is located in close proximity to London Underground tunnels and structure. The application was therefore referred to London Underground Infrastructure Protection department. London Underground Infrastructure Protection has raised no objection in principle to the planning application. However, there are a number of potential constraints on the redevelopment of a site because of its location close to London Underground tunnels. It will need to be demonstrated to the satisfaction of LUL engineers that:

 the development will not have any detrimental effect on London Underground tunnels and structures either in the short or long term and;  thedesign must be such that the loading imposed on London Underground tunnels or structures is not increased or removed.

7.4.13 London Underground Infrastructure Protection have requested that the grant of planning permission be subject to conditions that a detailed design and method statements (in consultation with London Underground) for all of the foundations, basement and ground floor structures, or for any other structures below ground level, including piling (temporary and permanent), be submitted to and approved in writing by the local planning authority in consultation with London Underground prior to the commencement of works.

Refuse and Recycling Storage

7.4.14 Policy S8 of the Local development Framework Core strategy seeks to ensure that adequate provision for refuse and recycling storage is incorporated within new developments. The council’s Guidance for ‘Waste and recycling storage and Collection requirements’ provides a more comprehensive guide to waste storage development.

44 7.4.15 There is an existing refuse/recycling store located at 20 Stannary Street which currently stores refuse/recycling materials for all of HCPC’s existing offices. The store is accessed externally from Stannary Street and has secure locks with the inward opening doors. It is estimated that in total approximately 30-40 bags of waste are produced each day and put into the refuse store, ready for collection. However no details have been provide regarding how the waste associated with the potential increase staff numbers and operations on the site would be managed. The applicant has indicated a possible location for an additional refuse store within the 18a Stannary Street building, however no details such as floor plans and its capacity have been provided.

7.4.16 In view of the above considerations, a condition is recommended requiring the submission of details of refuse and recycling provision including a Waste and Servicing Management Plan consistent with the council’s requirement for refuse collection for further assessment to ensure that the objectives of policy S8 of the Core Strategy are achieved.

7.5 Sustainability

7.5.1 Saved Policy 35 of the UDP sets out that all development proposals should show how they incorporate sustainable design and construction principles. The Council's SPD on Sustainable Design and Construction sets out that all non- residential developments (including commercial and industrial) should aspire to BREEAM “Excellent” and seeks “‘Very Good” as a minimum standards

7.5.2 The applicant has submitted an outline Energy Assessment, 14371 Rev B, prepared by Couchperrywilkes, dated 25/07/14 which has been reviewed by the Council’s Sustainability consultant.

7.5.3 The energy assessment provided follows the energy hierarchy and shows a reduction in CO2 of 42.5% exceeding the 35% reduction below Part L 2013 required, by using lean and green measures. However the Council’s Sustainability Consultant considers that that there are insufficient details provided to assess this. It is unclear if these calculations have used Part L 2013 or 2010. A condition requiring the submission of a formal Energy Statement is recommended.

7.5.4 The applicant has submitted a BREEAM 2011 Pre-assessment Report Rev A, prepared by HOARE LEA BREEAM, dated 18 July 2014.

The Council’s Sustainability Consultant has advised that the BREEAM pre- assessment which has been submitted is outdate and has been superseded byby BREEAM New Construction 2014. In addition, applicant has been advised to contact BRE to ascertain what scheme the development should be assessed under as BREEAM UK Refurbishment and Fit-Out 2014 is due to go live in October 2014 and is likely to be the most appropriate method of assessment. Regardless of the assessment method the applicant is expected to achieve a BREEAM Very Good rating. Condition to secure the approrprite pre- commencement, design stage and final stage BREEAM certifications are

45 recommended.

7.5.5 The Council’s Sustainability Consultant has raised no objection to the proposal subject to the imposition of the above conditions.

7.6 Flood Risk

7.6.1 . Policy S6(d) requires a Flood Risk Assessment (FRA) be submitted for all new development within Flood Zones 2, 3a and 3b. Policy S6(e) states that where development is permitted within flood risk areas, it must demonstrate that, where required, it will reduce fluvial, tidal and surface water flood risk and manage residual risks through appropriate flood risk measures.

7.6.2 The site is located within Flood Zone 2/3 and the applicant has submitted a Flood Risk Assessment & Sustainable Drainage report, 120759/T Noble Rev 1.1, prepared by Conisbee, dated 23 July 2014.. This along with the application was referred to the Environment Agency for review.

7.6.3 The Environment Agency has advised that the proposed development falls into a flood risk vulnerability category and flood zone that requires the exception test to be passed according to Tables 2 and 3 of the NPPG. However, they have no objection to this application in this instance for the reasons set out in the paragraphs below

7.6.4 The River Thames flood defences in this area defend the site to a 1 in 1000 year annual probability of river flooding in any year (<0.1%). Areas of residual flood risk can occur due to failure of the flood defences or a design flood event greater than that mentioned above. However according to the best information available the site lies outside the area of residual risk of flooding.

7.6.5 The Environment Agency recommends that the applicant speak with the local planning authority about producing or updating any existing flood evacuation plan for this site. Advice is available from the emergency services when producing an evacuation plan for a development. The environment agency consider it to be beneficial for the future occupants, to register with the Environment Agency’s flood warning service, ‘Flood Line’, so that the future occupants may prepare themselves in case of a flood event. This can be included as a note to the applicant at the end of the decision notice if minded to grant planning permission. It is recommended that this advise is included on any decision notice as an informative.

.

7.7 Land Contamination

7.7.1 The applicant has submitted a site investigation report, prepared by Ground Engineering Limited, dated July 2014. The consultant makes the following recommendation; that remediation of the soils beneath the site, in respect of the redevelopment is only considered necessary in relation to the creation of new areas of landscaping. In order to create landscaping on this site, as a

46 minimum it would be necessary to remove a sufficient thickness of the surface layers and replace them with imported topsoil.

7.7.2 The Council’s Environmental Health officer has reviewed the report and is satisfied with its recommendations..

7.8 Community Safety/Designing out Crime

7.8.1 Saved Policy 32 of the UDP requires that developments should enhance community safety. Development will not be permitted where opportunities for crime are created or where it results in an increased risk of public disorder. This requirement is contained within Section 17 of The Crime and Disorder Act 1998 which imposes an obligation on the local planning authority to consider crime and disorder reduction in the assessment of planning applications.

7.8.2 It is considered that the proposed development could meet the Design Principles and Minimum Physical Protection Measures as defined in the Secure By Design (SBD) accreditation scheme. Access control measures, external lighting, cycle storage and refuse storage are all included within the above standards. If minded to grant planning permission it is recommended that a condition be imposed to ensure that the development complies with the Secured by Design accreditation scheme.

7.9 Planning Obligations and Community Infrastructure Levy (CIL)

Planning Obligations

7.9.1 Contributions towards (a) construction training/local labour, and (b) general employment and training are based on schemes that create additional floorspace in excess of a 1,000sqm for commercial development. The existing and proposed floorspace of the development is as follows:

 Existing Gross Internal Floorspace – 2198.9sqm  Gross Internal Floorspace to be lost – 1116.8sqm  Total Gross new internal Floorspace – 1254.0 sqm  Net additional Gross Internal Floorspace – 137.6sqm

7.9.2 The net gain in floor space is only 137.6sqm for the development which falls beneath the 1000sqm threshold, and as such no planning obligations are required towards the employment and training planning obligations.

Community Infrastructure Levy (CIL)

7.9.3 If the application is approved and the development is implemented, a liability to pay the Lambeth Community Infrastructure Levy (CIL) will arise.

7.9.4 The Lambeth CIL contribution is estimated, on the basis of information supplied with the planning application. The proposal would be CIL liable but at NIL rate for this type of development, which is office space in Zone B of the charging schedule

47 7.9.5 Friends of Kennington Park commented they would like some CIL money obtained from the development to benefit Kennington Park. As noted above, given the location of the site in Zone B and its use for office purposes a NIL CIL rate applies. No CIL money would be forth coming from this development.

7.9.6 Allocation of CIL monies to particular infrastructure projects is not a matter for consideration in the determination of planning applications. Separate governance arrangements are being put in place for Borough Infrastructure needs, and locally through the Cooperative Local Investment Plan initiative.

7.9.7 The London Mayoral CIL would also be applicable and the estimated contribution would be £5508.29. The London Mayoral CIL will be applied towards the cost of Crossrail

8.0 Conclusions

8.1.1 The proposal to intensify and provide one integrated building for office accommodation for use by HCPC is considered acceptable in land use terms. The proposal would optimise the re-development potential of the site and make a positive contribution to the Councils stated aims of protecting and retaining employment uses across the borough.

8.1.2 The proposed redevelopment of the site is acceptable in that it would be of an appropriate design; it would not prejudice the amenity of neighbouring occupiers; it would not harm conditions of on-street parking or prejudice conditions for the free flow of traffic and highway safety; and would not unacceptably impact upon local infrastructure.

8.1.3 The proposed development is considered to be an appropriate response to the character of the site and surrounding area. It is considered that the proposal is comparable in scale, height and massing to development located within the surrounding area. The development would not unduly harm the character and appearance of the Kennington Conservation Area.

9.0 Recommendation

9.1.1 Grant Planning Permission subject to conditions

Summary of Reasons

In deciding to grant planning permission, the Council has had regard to the relevant policies of the development plan and all other relevant material considerations. Having weighed the merits of the proposal in the context of these issues, it is considered that planning permission should be granted subject to the conditions listed below. In reaching this decision the following policies were relevant:

London Plan 2011

48 Policy 5.2 Minimising carbon dioxide emissions Policy 5.3 Sustainable Design and Construction Policy 5.21 Contaminated Land Policy 7.15 Reducing Noise and Enhancing Soundscapes

UDP: Policies saved beyond 5th August 2010 and not superseded by the Local Development Framework Core Strategy January 2011:

Policy 7 Protection of Residential Amenity Policy 9 Transport Impact Policy 14 Parking and Traffic Restraint Policy 15 Additional Housing Policy 17 Flat Conversions Policy 31 Streets, Character and Layout Policy 32 Community Safety/Designing out Crime Policy 33 Building Scale and Design Policy 35 Sustainable Design and Construction Policy 38 Design in Existing Residential/Mixed Use Areas Policy 39 Streetscape, Landscape and Public Realm Design

Local Development Framework Core Strategy January 2011:

Policy S1 Delivering the Vision and Objectives; Policy S2 Housing; Policy S4 Transport; Policy S7 Sustainable Design and Construction; Policy S8 Sustainable Waste Management; Policy S9 Quality of the Built Environment; and Policy S10 Planning Obligations.

10 Conditions Planning Permission

Standard Conditions

1 The development to which this permission relates must be begun not later than the expiration of three years beginning from the date of this decision notice.

Reason: To comply with the provisions of Section 91(1) (a) of the Town and Country Planning Act 1990 and Section 51 of the Town and Country Planning Compulsory Purchase Act 2004.

2 The development hereby permitted shall be carried out in accordance with the approved plans listed in this notice.

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

Design and Conservation

3 Notwithstanding any indications as to these matters which have been given in

49 the application or approved plans, no development shall commence until detailed drawings, samples, and a schedule of all external materials to be used in the elevations and roofs within the scheme hereby permitted have been submitted to and approved in writing by the Local Planning Authority. The development shall thereafter be carried out solely in accordance with the approved details.

Reason: To ensure a high quality standard of development of the site in the interests of visual amenity and the character and appearance of the Conservation Area (Saved Policies 33, 38, 39 and 47 of the Unitary Development Plan: Policies saved beyond 5th August 2010 and not superseded by the Local Development Framework Core Strategy January 2011 and Policies S1 and S9 of the Local Development Framework Core Strategy (January 2011).

4 Notwithstanding any indications as to these matters which have been given in the application or approved plans, no development shall commence until drawings at a scale of 1:20 and samples and/or manufacturer’s specifications of the design and full construction details listed below have been submitted to and approved in writing by the Local Planning Authority The development shall thereafter be carried out solely in accordance with the approved details.

i) windows and doors (including the proposed timber industrial doors fronting Stannary Street) (including technical details, elevations, reveal depths, plans and cross sections); ii) Solar photovoltaic (PV) arrays to roofs (including elevational and sectional); iii) Noise barriers and plant enclosures and;

Reason: To ensure a high quality standard of development of the site in the interests of visual amenity and the character and appearance of the Conservation Area and in order to protect the residential amenity of the locality (Saved Policies 33, 38, 39 and 47 of the Unitary Development Plan: Policies saved beyond 5th August 2010 and not superseded by the Local Development Framework Core Strategy January 2011 and Policies S1 and S9 of the Local Development Framework Core Strategy (January 2011).

5 Notwithstanding any indications as to these matters which have been given in the application or approved plans, no development shall commence until full details of the existing and proposed windows on the Stannary Street elevation (to match the existing top hung timber sliding sashes in materials, design and dimensions) at a scale of 1:20 including cross sections to include how they sit within the window reveal (trickle vents and applied glazing bars will not be permitted) shall be submitted to and approved in writing by the Local Planning Authority. The development shall thereafter be carried out solely in accordance with the approved details.

Reason: To ensure a high quality standard of development of the site in the interests of visual amenity and the character and appearance of the Conservation Area (Saved Policies 33, 38 and 47 of the Unitary Development Plan: Policies saved beyond 5th August 2010 and not superseded by the Local

50 Development Framework Core Strategy January 2011 and Policies S1 and S9 of the Local Development Framework Core Strategy (January 2011).

6 Notwithstanding the approved drawings, no development shall commence until detailed drawings of the boundary treatments at 1:20, 1:5 and 1:1 scale where appropriate have been submitted to and approved in writing by the Local Planning Authority. The development shall thereafter be carried out solely in accordance with the approved details.

Reason: To ensure a high quality standard of development of the site in the interests of visual amenity and the character and appearance of the Conservation Area (Saved Policies 33, 38 and 47 of the Unitary Development Plan: Policies saved beyond 5th August 2010 and not superseded by the Local Development Framework Core Strategy January 2011 and Policies S1 and S9 of the Local Development Framework Core Strategy (January 2011).

Landscaping and Biodiversity

7 No development shall commence until a specification of all proposed soft and hard landscaping and tree planting scheme has been submitted to and approved in writing by the Local Planning Authority. The specification shall include details of the quantity, size, species, position of planting of all trees and shrubs to be planted, together with an indication of how they would integrate with the development in the long term with regard to their mature size and anticipated routine maintenance and protection. In addition all shrubs and hedges to be planted that are intended to achieve a significant size and presence in the landscape shall be similarly specified. All tree, shrub and hedge planting included within the above specification shall accord with BS3936:1992, BS4043:1989 and BS4428:1989 and current Arboricultural best practice. It

Reason: To ensure satisfactory landscaping of the site in the interests of visual amenity and the character and appearance of the Conservation Area in accordance with Policies 39 and 47 of the Lambeth Unitary Development Plan : Policies as saved beyond the 5th August 2010 and Policy S9 of the Local Development Framework Core Strategy (2011).

8 All planting, seeding or turfing comprised in the approved details of landscaping scheme shall be carried out in the first planting and seeding season following the occupation of the development hereby permitted or the substantial completion of the development, whichever is the sooner. Any trees, hedgerows or shrubs forming part of the approved landscaping scheme which within a period of five years from the occupation or substantial completion of the development die, are removed or become seriously damaged or diseased shall be replaced in the next planting season with others of similar size and species, unless the Local Planning Authority gives written consent to any variation.

Reason: To ensure satisfactory landscaping of the site in the interests of visual amenity and the character and appearance of the Conservation Area in accordance with Policies 39 and 47 of the Lambeth Unitary Development Plan : Policies as saved beyond the 5th August 2010 and Policy S9 of the Local Development Framework Core Strategy (2011).

51 Amenity

9 Notwithstanding the approved plans, all the proposed side elevation windows on the upper floors (1st, 2nd, 3rd) of the proposed replacement building at No.186 Kennington Park Road (facing No. 182 Kennington Park Road and No. 184 Kennington Park Road) shall be fitted with obscure glazing to a height of 1.7 metres above finished floor level and permanently retained as such for the duration of the development, unless otherwise approved in writing by the local planning authority.

Reason: To safeguard the privacy and amenities of adjoining occupiers. (Policies 7 and 33 of the Unitary Development Plan: Policies saved beyond 5th August 2010 and not superseded Local Development Framework Core Strategy January 2011), Policy S2 of the Local Development Framework Core Strategy and Policy 7.15 of the London Plan (2011).

10 Notwithstanding the approved plans, a privacy screen shall be erected for the full length (between the rear elevation of the building at No.186 Kennington Park Road and the rear elevation of the building at No 18A Stannary Street) of the flank boundary on either side of courtyard (annotated as courtyard 2 on the approved drawings) in accordance with details to be submitted and approved in writing by the Local Planning Authority which should therefore be permanently retained as such for the duration of the development, unless otherwise approved in writing by the local planning authority.

Reason: To safeguard the privacy and amenities of adjoining occupiers. (Policy 33 of the Unitary Development Plan: Policies saved beyond 5th August 2010 and not superseded Local Development Framework Core Strategy January 2011).

11 The operating hours of the office premises hereby approved shall be restricted to 07.00am – 10.00pm Monday to Friday, 08.00am – 4.00pm Saturday and shall not operate at any time on Sundays and Bank Holidays 10.00am-4.00pm Sunday and Public Holidays.

Reason: In order to protect the residential amenity of the locality in accordance with Policies 7 and 33 of the Unitary Development Plan: Policies saved beyond 5th August 2010, Policy S2 of the Local Development Framework Core Strategy and Policy 7.15 of the London Plan (2011).

12 The use of the courtyard (annotated as courtyard 2 on the approved drawings) shall be restricted to 07.00 am – 7.00pm Monday to Friday and 08.00am – 4.00pm Saturday.

Reason: In order to protect the residential amenity of the locality in accordance with Policies 7 and 33 of the Unitary Development Plan: Policies saved beyond 5th August 2010, Policy S2 of the Local Development Framework Core Strategy and Policy 7.15 of the London Plan (2011).

13 The recommended noise mitigation measures outlined in the applicant’s Office

52 Development Acoustic Report A9786-R01A-CFC, dated 25 July 2014, prepared by Bickerdike Allen Partners shall be incorporated into the development and implemented prior to the first occupation must be complied with for the duration of the development, unless otherwise approved in writing by the local planning authority

Reason: In order to protect the residential amenity of the locality in accordance with Policies 7 and 33 of the Unitary Development Plan: Policies saved beyond 5th August 2010, Policy S2 of the Local Development Framework Core Strategy and Policy 7.15 of the London Plan (2011).

Transport

14 Prior to the occupation of the development hereby permitted, the existing vehicular access (rear of No.20 Stannary Street) shall be stopped up by raising the existing dropped kerb and reinstating the footway verge and highway boundary to the same line, level and detail as the adjoining footway verge and highway boundary.

Reason: To minimise danger and inconvenience to highway users. (Policies 9 and 14 of the London Borough of Lambeth Unitary Development Plan (2007): Policies saved beyond 5 August 2010 and not superseded by the LDF Core Strategy January (2011) and Policy S4 of the Core Strategy (2011)

15 Notwithstanding the approved drawings, prior to the first occupation of the proposed building, detailed drawings of the cycle storage area including the layout and manufacturer's specification of the proposed cycle stands shall be submitted to and approved by the Local Planning Authority. The development shall thereafter be carried out solely in accordance with the approved details and retained as such for the duration of the use.

Reason: To ensure adequate cycle parking is available on site, to promote sustainable modes of transport and in the interest of the visual amenities of the area (Policies 9, 14, 33 and 39 of the Unitary Development Plan: Policies saved beyond 5th August 2010 and not superseded by the Local Development Framework Core Strategy January 2011 and Policies S4 and S9 of the Local Development Framework Core Strategy (January 2011)).

16 The development hereby approved shall not be occupied until there has been submitted to and approved in writing by the Local Planning Authority, full details including the layout of the refuse and recycling storage facilites (existing and a designated second area at No.18A Stannary Street) shall be submitted to and approved in writing by the Local Planning Authority. The details shall include the description and storage capacity of the facilities to be provided. The development shall thereafter be carried out solely in accordance with the approved details.

Reason: To ensure the adequate provision is made for the storage of refuse and recycling materials on the site, in the interests of the amenities of the area (Policies 9, 33, 39 and 47 of the Unitary Development Plan: Policies saved beyond 5th August 2010 and not superseded by the Local Development

53 Framework Core Strategy January 2011 and Policies S8 and S9 of the Local Development Framework Core Strategy (January 2011).

17 Notwithstanding the approved drawings and supporting information, prior to first occupation of the proposed building a Waste Management and Servicing Strategy outlining the operation and management of waste storage and collection and the delivery and servicing arrangements to the building has been submitted to and approved in writing by the Local Planning Authority in consultation with Transport for London (TfL). The development shall thereafter be carried out in accordance with the approved details.

Reason: To ensure adequate arrangements are put in place for the storage of refuse on the site, in the interests of the amenities of the area and the safe operation of the adjacent public highway (Policies 9, 33, 39 of the Unitary Development Plan: Policies saved beyond 5th August 2010 and not superseded by the Local Development Framework Core Strategy January 2011 and Policies S4, S8 and S9 of the Local Development Framework Core Strategy (January 2011).

18 No development shall commence until full details of the proposed construction methodology, in the form of a Method of Demolition and Construction Statement, have been submitted to and approved in writing by the Local Planning Authority in consultation with Transport for London (TfL). The Method of Demolition and Construction Statement shall include details and arrangements regarding:

o the notification of neighbours with regard to specific works; advance notification of road closures; o details regarding parking, deliveries and storage (including details of the routing if delivery vehicles to and from the site and the accommodation of all site operatives', visitors' and construction vehicles loading, off-loading, parking and turning within the site during the construction period); o details regarding dust mitigation; o details of measures to prevent the deposit of mud and debris on the public highway; and o other measures to mitigate the impact of construction upon the operation of the highway, cycle super highway and the amenity of the area.

The details of the approved Method of Demolition and Construction Statement must be implemented and complied with for the duration of the demolition and construction process.

Reason: To ensure minimal nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers and of the area generally, and avoid hazard and obstruction to the public highway. (Policies 7, 9, 31, and 33 of the Unitary Development Plan: Policies saved beyond 5th August 2010 and not superseded by the Local Development Framework Core Strategy January 2011 and Policy S4 of the Local Development Framework Core Strategy (January 2011).

19 A Final Travel Plan that includes an ATTrBute Analysis shall be submitted to

54 and approved in writing by the local planning authority prior to occupation of the office premises hereby approved. The measures in the revised Travel Plan shall be implemented upon shall be so maintained for the duration of the use, unless the prior written approval of the local planning authority is obtained to any variation.

Reason: To ensure that the travel and visitor arrangements are appropriate and to limit the effects of the increase in travel movements in accordance with Policy S4 of the Council's Core Strategy (2011).

20 The development hereby permitted shall not be commenced until detailed design and method statements (in consultation with London Underground) for all of the foundations, basement and ground floor structures, or for any other structures below ground level, including piling (temporary and permanent), have been submitted to and approved in writing by the local planning authority which:  provide details on all structures  accommodate the location of the existing London Underground structures and tunnels  accommodate ground movement arising from the construction thereof  and mitigate the effects of noise and vibration arising from the adjoining operations within the structures and tunnels. The development shall thereafter be carried out in all respects in accordance with the approved design and method statements, and all structures and works comprised within the development hereby permitted which are required by the approved design statements in order to procure the matters mentioned in paragraphs of this condition shall be completed, in their entirety, before any part of the building hereby permitted is occupied.

Reason: To ensure that the development does not impact on existing London Underground transport infrastructure, in accordance with London Plan 2011 Table 6.1 and ‘Land for Industry and Transport’ Supplementary Planning Guidance 2012’

Sustainability

21 No development shall take place until an appropriate BREEAM (or such equivalent standard that replaces this) pre-assessment estimator and correspondence with BRE confirming which version of BREEAM should be applied to the development has been submitted to and approved in writing by the Local Planning Authority demonstrating how an Very Good (minimum score 66) rating will be achieved.

Reason: To ensure that the development has an acceptable level of sustainability (Policy 35 of the London Borough of Lambeth Unitary Development Plan (2007): Policies saved beyond 5 August 2010 and not superseded by the LDF Core Strategy January 2011, and Policy S7 of the London Borough of Lambeth Core Strategy (January 2011)).

22 Within three months of work starting on site a BREEAM Design Stage certificate and summary score sheet (or such equivalent standard that replaces

55 this) must be submitted to and approved in writing by the Local Planning Authority to show that an Very Good (minimum score 66) rating will be achieved.

Reason: To ensure that the development has an acceptable level of sustainability (Policy 35 of the London Borough of Lambeth Unitary Development Plan (2007): Policies saved beyond 5 August 2010 and not superseded by the LDF Core Strategy January 2011, and Policy S7 of the London Borough of Lambeth Core Strategy (January 2011))

23 Prior to first occupation of the building(s) a BREEAM Post Construction Review certificate and summary score sheet (or such equivalent standard that replaces this) must be submitted to and approved in writing by the Local Planning Authority to show that an Very Good (minimum score 66) rating has been achieved.

Reason: To ensure that the development has an acceptable level of sustainability (Policy 35 of the London Borough of Lambeth Unitary Development Plan (2007): Policies saved beyond 5 August 2010 and not superseded by the LDF Core Strategy January 2011, and Policy S7 of the London Borough of Lambeth Core Strategy (January 2011)).

24 The development hereby permitted shall not commence until a finalised Energy Strategy, including full details demonstrating how the approved scheme has been designed to allow for the future connection to any neighbouring district heat network in accordance with the London Development Agency Document ‘Consumer Connection to a Large CHP District Heating System’ (or its successor), (demonstrating how the targets for carbon dioxide emissions reduction are to be met in line with the Mayor’s energy hierarchy) has been submitted to and approved in writing by the Local planning Authority.

Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with London Plan Policy 5.2 and Policy S7 of the London Borough of Lambeth Core Strategy (January 2011)).

25 The development shall be implemented in accordance with the approved Energy Strategy and shall not commence until full Design Stage calculations under the National Calculation Method have been submitted to and approved in writing by the Local planning Authority to show that the development will be constructed in accordance with the approved energy strategy.

Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with London Plan Policy 5.2 and Policy S7 of the London Borough of Lambeth Core Strategy (January 2011)).

26 Prior to first occupation of the building(s) evidence (e.g. photographs, installation contracts and as-built certificates under the National Calculation Method should be submitted to the Local Planning Authority and approved in writing to show that the development has been constructed in accordance with

56 approved energy strategy.

Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with London Plan Policy 5.2 and Policy S7 of the London Borough of Lambeth Core Strategy (January 2011)).

27 No development shall take place until there has been submitted to and approved in writing by the Local Planning Authority a detailed scheme for the construction, establishment and sustainable management of all areas of brown/green roof proposed for the site. This should clearly specify the total area of roof to be included, and details as to species composition, substrate type and depth, and measures to protect the roof and the rest of the building. The brown/green roofs shall thereafter be provided and retained and managed in accordance with the approved details.

Reason: To ensure that opportunities to maximise the biodiversity value of the site are maximised and to ensure promote rainwater attenuation and management to reduce potential for flooding in accordance with Policy 5.3 of the London Plan (July 2011) and Policy S5, S6, S7 of the Local Development Framework Core Strategy (January 2011)).

Land Contamination

28 The recommendations outlined in the applicant’s Site investigation Report ref. C13117, dated July 2014, prepared by Ground Engineering shall be incorporated into the development and implemented prior to the first occupation of the approved development and complied with for the duration of the development, unless otherwise approved in writing by the local planning authority

Reason: To ensure that the development does not result in significant harm to human health or the environment in the interest of the amenity of the future occupiers and the wider environment in accordance with Policy 5.21 of the London Plan (2011).

Crime Prevention/Community Safety

29 The development hereby permitted shall include the provision of physical protection measures (to include external lighting and access control measures) to meet Secured By Design minimum standards consistent with section 17 of the Crime and Disorder Act 2005 unless otherwise agreed in writing by the Local Planning Authority.

Reason: To ensure the safety and security of future occupiers and adjoining properties and prevent crime and disorder occurring within and in the immediate vicinity of the site, in the interest of public safety (Policy 32 of the of the London Borough of Lambeth Unitary Development Plan: (UDP) 2007: Policies saved beyond 5 August 2010 and not superseded by the LDF Core Strategy January 2011 and Policy S4 of the Local Development Framework

57 Core Strategy (2011).

Notes to Applicant

1 This decision letter does not convey an approval or consent which may be required under any enactment, by-law, order or regulation, other than Section 57 of the Town and Country Planning Act 1990.

2 Your attention is drawn to the provisions of the Building Regulations, and related legislation which must be complied with to the satisfaction of the Council's Building Control Officer.

3 Your attention is drawn to the need to comply with the requirements of the Control of Pollution Act 1974 concerning construction site noise and in this respect you are advised to contact the Council's Environmental Health Division.

4 You are advised of the necessity to consult the Council's Streetcare team within the Public Protection Division with regard to the provision of refuse storage and collection facilities. The London Borough of Lambeth’s Waste and Recycling Storage and Collection Requirements: Guidance for Architects and Developers’ (May 2006) and the Refuse & Recycling Storage Design Guide (July 2013) are available on the planning pages of the Council’s website: www.lambeth.gov.uk/planning

5 As soon as building work starts on the development, you must contact the Street Naming and Numbering Officer if you need to do the following:

- name a new street - name a new or existing building - apply new street numbers to a new or existing building - register new flats or new buildings with Royal Mail

This will ensure that any changes are agreed with Lambeth Council before use, in accordance with the London Buildings Acts (Amendment) Act 1939 and the Local Government Act 1985.

The correct street number or number and name must be displayed prominently on the premises in accordance with regulations made under Section 12 of the London Building Acts (Amendment) Act 1939.

Contact details are listed below. Tom Brown tel: 020 7926 2283 fax: 020 7926 0780 email: [email protected]

6 You are advised of the necessity to consult the Principal Highways Engineer of the Highways team on [email protected] in order to obtain necessary prior approval for undertaking any works within the Public Highway including Scaffold, Temporary/Permanent Crossovers, Oversailing/Undersailing of the

58 Highway, Drainage/Sewer Connections and Repairs on the Highways, Hoarding, Excavations, Temporary Full/Part Road Closures, Craneage Licenses etc. You are advised to contact the Highways team at the earliest possible opportunity.

7 No skips or construction materials shall be kept on the footway or carriageway on the TLRN at any time. Should the applicant wish to install scaffolding or a hoarding on the footway whilst undertaking this work, separate licences may be required with TfL, please see, https://www.tfl.gov.uk/info-for/urban-planning- and-construction/highway-licences

9 The footway and carriageway on the A3 Kennington Park Road must not be blocked during the redevelopment. Temporary obstructions during the redevelopment must be kept to a minimum and should not encroach on the clear space needed to provide safe passage for pedestrians or obstruct the flow of traffic on the A3 Kennington Park Road.

10 All vehicles associated with the development of 184 - 186 Kennington Park Road must only park / stop at permitted locations and within the time periods permitted by existing on-street restrictions.

11 The applicant is advised to contact London Underground Infrastructure Protection in advance of preparation of final design and associated method statements, in particular with regard to: demolition; drainage; excavation; construction methods; security; boundary treatment; safety barriers; landscaping and lighting

12 You are advised of the necessity to put in place a suitable protocol or procedures that, should bat or nesting bird activity be suspected or found, appropriate mitigation actions can be applied to prevent harm or disturbance to these protected species and to protect the applicant from legal liabilities.

13 The Environment Agency recommends that the applicant speak with the local planning authority about producing or updating any existing flood evacuation plan for this site. Advice is available from the emergency services when producing an evacuation plan for a development. Where warning and emergency response is fundamental to managing flood risk, we advise local planning authorities to formally consider the emergency planning and rescue implications of new development in making their decisions.

14 The Environment Agency consider it to be beneficial for the future occupants, to register with the Environment Agency’s flood warning service, ‘Flood Line’, so that the future occupants may prepare themselves in case of a flood event. This can be included as a note to the applicant at the end of the decision notice if minded to grant planning permission.

15 You are advised that the energy assessment provided follows the energy hierarchy and shows a reduction in CO2 of 42.5% exceeding the 35% reduction below Part L 2013 required, by using lean and green measures. However the Council’s Sustainability Consultant has advised that there are insufficient details provided to assess this. It is unclear if these calculations have used

59 Part L 2013 or 2010 unless submission to Building Control was made prior to 6th April 2014 the applicant should ensure that 2013 is used.

16 The Council’S Sustainability Consultant has advised that the BREEAM pre- assessment which has been submitted is for BREEAM New Construction 2011. This is now a superseded scheme, replaced by BREEAM New Construction 2014. In addition to this the applicant should contact BRE to ascertain what scheme the development should be assessed under as BREEAM UK Refurbishment and Fit-Out 2014 is due to go live in October 2014 and is likely to be the most appropriate method of assessment.

17 You are advised that all conditions which require further details to be submitted to and approved by the Local Planning Authority need to be accompanied by an application form and a fee. The application form and fee schedule can be found at www.lambeth.gov.uk/planning.

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