planning report PDU/2936/01 30 August 2012 Cremorne Wharf, 27 Lots Road, Chelsea in the Royal Borough of & Chelsea planning application no. PP/12/02224

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

The proposal Redevelopment of site for a mixed use development comprising a 9-storey building and a 2-storey building to provide 1,500 square metres of B1 office floorspace and 48 residential units with associated access, parking and landscaping.

The applicant The applicant is the Royal Borough of Kensington & Chelsea and the architect is Feilden Clegg Bradley.

Strategic issues The redevelopment of this safeguarded wharf, designated waste management site and identified Thames Tideway Tunnel construction site is contrary to the London Plan and unacceptable in principle.

Other strategic issues for consideration include contribution to the Blue Ribbon Network, affordable housing and housing mix, urban design, inclusive design, climate change mitigation and adaptation and transport.

Recommendation That Kensington & Chelsea Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 100 of this report.

Context

1 On 26 July 2012 the Mayor of London received documents from Kensington & Chelsea Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 5 September 2012 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Categories 1C and 4 of the Schedule to the Order 2008:

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1C: Development which comprises or includes the erection of a building in respect of which one or more of the following conditions is met – (a) the building is more than 25 metres high and is adjacent to the .

4: Development in respect of which the local planning authority is required to consult the Mayor by virtue of a direction given by the Secretary of State under article 10(3) of the GDPO, in this instance as a safeguarded wharf

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

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

5 The 0.39 hectare site is located between Lots Road and the River Thames, with the Lots Road site to the south west and Chelsea Wharf to the north east. It occupies approximately 40 metres of river frontage and has a jetty measuring 24 metres by 12 metres. The north west boundary of the site is shared with the rear of the grade II listed pumping station.

6 The site currently contains a double-height, corrugated metal clad depot building and ancillary staff accommodation. The previous use of the site was as a materials reclamation facility. It is now used by the Council as a local street cleaners’ depot and for storage of road salt and bulky items.

7 The area surrounding the site is predominantly residential in character, with some small scale business uses. The dominant form of development is 2 to 4-storey Victorian terraces. The adjacent site has planning permission for redevelopment for residential mixed use development including two 25 and 37 storey residential towers.

8 Bus stops served by three routes (328, C3 and N31) are within walking distance of the development site, defined as a five minute walk or 400 metres. Imperial Wharf station is within approximately eight minutes’ walk, providing access to and mainline rail services. Pier, offering access to River Bus services, is approximately 12 minutes’ walk from the site. Cremorne Road is on the Road Network (TLRN) approximately 160 metres to the north east of the development, and the A308 King’s Road is on the Strategic Road Network (SRN) approximately 360 metres from the development site. These factors generate a Public Transport Accessibility Level (PTAL) of 2-3 on a scale of 1 to 6, where 6 is the most accessible.

Details of the proposal

9 The development comprises a 9-storey building and a 2-storey building to provide a total of 1,543 square metres of B1 accommodation and 48 flats. The ground and first floors are proposed for use by small and medium sized enterprises (SME’s), with seven storeys of residential accommodation above. Additional commercial space is provided in the separate 2-storey building along the north east boundary of the site. Two basement levels will provide car parking, bin storage and plant space. A total of 27 parking spaces are proposed, of which 26 are provided in connection with the residential accommodation and one for the commercial accommodation.

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Case history

10 A pre-planning application meeting was held on 13 April 2012 and an advice note was issued on 27 April 2012. Strategic planning issues and relevant policies and guidance

11 The relevant issues and corresponding policies are as follows:

 Mix of uses London Plan  Safeguarded wharves London Plan; London Plan Implementation Report “Safeguarded Wharves on the River Thames”; Safeguarded Wharves review  Waste London Plan; the Municipal and Business Waste Management Strategies; PPS10  Blue Ribbon Network London Plan  Housing London Plan; Housing SPG; Interim Housing SPG; draft Housing SPG; Housing Strategy; draft Revised Housing Strategy; Providing for Children and Young People’s Play and Informal Recreation SPG; draft Providing for Children and Young People’s Play and Informal Recreation SPG;  Affordable housing London Plan; Housing SPG; Interim Housing SPG; draft Housing SPG; draft Affordable Housing SPG; Housing Strategy; draft Revised Housing Strategy  Density London Plan; Housing SPG; Interim Housing SPG; draft Housing SPG  Urban design London Plan;  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Transport London Plan; the Mayor’s Transport Strategy;  Crossrail London Plan; Mayoral Community Infrastructure Levy  Parking London Plan; the Mayor’s Transport Strategy  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy

12 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the Kensington & Chelsea Core Strategy 2010, the saved policies of the Kensington & Chelsea Unitary Development Plan 2002 and the 2011 London Plan.

13 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework  The draft Revised Early Minor Alteration to the London Plan

Principle of development

14 The site is subject to several strategic and local policy designations, which are outlined below.

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Safeguarded wharves

15 The site is designated as a safeguarded wharf in the London Plan Safeguarded Wharves Implementation Report 2005 and is subject to a Secretary of State safeguarding direction. The Safeguarded Wharves Review 2011/12 (consultation draft October 2011 and further consultation draft July 2012) proposes the continued safeguarding of Cremorne Wharf, on the basis of its potential to contribute to the identified shortfall in wharf capacity in , and that Cremorne Wharf is one of only a small number of wharves capable of making up the shortfall in capacity. London Plan policies 7.26 seeks to increase use of the Blue Ribbon Network to transport freight. It states that safeguarded wharves should only be used for waterborne freight handling use and that the redevelopment of safeguarded wharves for other land uses “should only be accepted if the wharf is no longer capable of being made viable for waterborne freight handling,” which should be assessed against the criteria set out in paragraph 7.77 of the London Plan.

16 The redevelopment of the wharf for mixed B1 and residential purposes conflicts with London Plan policy 7.26. In support of the application, the applicant has provided a “Safeguarded Wharf Status and Environmental Assessment Report” and has re-submitted detailed representations originally made to the GLA on behalf of the Council, in response the consultation draft Safeguarded Wharves Review (October 2011). These seek to address the criteria set out in paragraph 7.77 of the London Plan and to demonstrate that Cremorne Wharf is no longer viable, or capable of being made viable, for waterborne freight handling use and should be removed from safeguarding.

17 Following detailed consideration of all responses to the Safeguarded Wharves Review consultation draft, published in Oct 2011, including the applicant's submission, a further consultation document was published in July 2012. This confirms the recommendation for continued safeguarding of Cremorne Wharf and includes a Statement of Consultation with responses to all consultation comments. The GLA’s response to the applicant’s representations is set out in Appendix One to this report.

18 The information provided by the applicant is principally concerned with the environmental impact of using the site for waterborne freight handling, with reference to transport and access issues, noise and vibration and lighting. Many of the assumptions are considered flawed and the report’s conclusions are not accepted. Furthermore, the applicant has provided no evidence to demonstrate that they have undertaken market testing of the site or sought the views of any cargo handling operators. The GLA is aware of several aggregate operators who have indicated their interest in the site.

19 The applicant’s case for removing the wharf from safeguarding is predicated on its land use context and potential for environmental conflicts with surrounding uses, site conditions and operational constraints. The information provided in support of the planning application raises no new issues or evidence that has not been considered as part of the Safeguarded Wharves Review. As such, having regard to the criteria set out in paragraph 7.77 of the London Plan, officers remain of the view that Cremorne Wharf is capable of being made viable for waterborne freight handling uses and that its redevelopment for alternative uses is contrary to London Plan policy 7.26.

Waste

20 The site is allocated in the Kensington and Chelsea Core Strategy for waste management purposes. Policy CE3 Waste seeks to maximise its use for waste management, water transport and cargo-handling purposes. Whilst use of the site as a materials recycling facility has now ceased, its designation for waste management use remains live. London Plan policy 5.17 states that boroughs must allocate sufficient land and identify waste management facilities to provide capacity to manage the tonnages of waste apportioned in the Plan. Part G of the policy seeks to protect and

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facilitate the maximum use of existing waste sites, including safeguarded wharves with an existing or future potential for waste management. Part H states that if, for any reason, an existing waste management site is lost to non-waste use, an additional compensatory site provision will be required that normally meets the maximum throughput that the site could have achieved.

21 Cremorne Wharf is the only allocated waste management site in the borough of Kensington and Chelsea. In producing its Core Strategy, the Council was unable to identify sufficient land to meet its allocated waste apportionment of 309,000 tonnes per annum by 2020, which has been superseded by the revised target of 284,000 tonnes per annum by 2031 in the London Plan. In order to address the shortfall in capacity, the Council committed to produce a separate Waste DPD to demonstrate how it will meet its apportionment. This is enshrined in policy CE3 and was secured in the most recent iteration of the Council’s Local Development Scheme (March 2010).

22 The applicant’s case in seeking to justify the redevelopment of the site for non-waste uses is predicated on it not being required by the Western Riverside Waste Authority (WRWA), the statutory waste disposal authority for the boroughs of Kensington & Chelsea, & , and Lambeth; there being sufficient available capacity offered by waste transfer stations at Smugglers Way and Cringle Dock to handle existing and projected waste arisings; and the intention of the local authority to enter into a Joint Waste Agreement with Hammersmith & Fulham Council to secure use of spare capacity at to manage Kensington & Chelsea’s apportionment of waste up to 2031. Whilst the principle of apportionment pooling between boroughs is accepted by virtue of paragraph 5.80 of the London Plan, an agreement between the two boroughs has yet to be formalised.

23 Notwithstanding the ‘in principle’ acceptability of apportionment pooling between the boroughs, the identification of spare capacity at existing waste facilities elsewhere does not satisfy the requirement of London Plan policy 5.17 for additional compensatory site provision to be made when an existing waste management site is lost to non-waste use. In advance of the Joint Waste agreement between the boroughs being completed, and in the absence of compensatory site provision, the redevelopment of the wharf for non-waste uses is contrary to London Plan policy 5.17.

Local Employment Zone

24 The site falls within the Lots Road employment zone, as identified on the Core Strategy Proposals Map. London Plan policy 4.4 provides the strategic framework for managing industrial land and premises and advocates a plan, monitor, manage approach to the release of surplus industrial land. Kensington & Chelsea is in the category of restricted transfer of industrial land to other uses, and as such are encouraged to adopt a more restrictive approach to transfer. As a locally significant industrial site, the appropriateness of the proposed uses are principally a matter for the local planning authority.

25 Core Strategy policy CF5 seeks to protect and promote employment zones for a range of small and medium business activities which directly support the function and character of the zone. It also seeks to protect light industrial uses, requires there to be no net loss of business floorspace unless to uses which directly support the function and character of the zone, and resists residential uses.

26 Chapter 18 of the Core Strategy (Lots Road/World’s End) recognises that this area is undergoing significant change and will continue to change in the future due to the Chelsea Academy and Lots Road Power Station development. Paragraph 18.3.14 identifies that the Lots Road Employment Zone has less of an industrial feel to the area than the other two employment zones within the borough, but that the Employment Zone will continue to cater for small business and light industry.

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27 The development includes 1,543 sq.m. of class B1 employment space. Using an employment density ratio of 14.7 square metres1 of B1 floorspace per employee, the applicant estimates that the scheme has the potential to provide around 105 jobs. If the current site was redeveloped for more intensive B2 (general industrial) or B8 (storage and distribution) use, it is estimated to be capable of supporting around 90 jobs.

28 The methodology used by the applicant to calculate the employment generating potential of the site appears sound. Subject to the local planning authority’s assessment of the scheme against Core Strategy policy CF5, and notwithstanding the in principle objection to the redevelopment of the site for non-wharf and non-waste uses, the employment generating element of the scheme could be considered compatible with its local employment zone designation.

Thames Tunnel

29 London Plan policy 5.14 supports the development of the Thames Tideway Sewer Tunnels to address London’s combined sewer overflows. In accordance with London Plan policy 7.26B(a), temporary uses of safeguarded wharves, including for construction of the Thames Tunnel, should only be allowed where they do not preclude the wharf being reused for waterborne freight handling purposes.

30 Thames Water has identified Cremorne Wharf as its preferred site to intercept the existing Lots Road pumping station CSO and connect it to the main Thames Tunnel. The project has undergone two rounds of consultation following the Government's instruction to Thames Water in 2007 and its identification in the National Policy Statement on Waste Water as a Nationally Significant Infrastructure Project. The project is due to be submitted to the Major Infrastructure Planning Unit in early 2013, where it will be examined in detail.

31 Thames Water's proposals involve the use of the site for several years for construction of the Thames Tideway Tunnel, and thereafter to accommodate permanent structures required to access and maintain the Tunnel. Plans released as part of the current Section 48 publicity period demonstrate Thames Water’s intention to reinstate a depot building on the site, following completion of the Tunnel. The GLA fully expects that the site will be restored for use as a safeguarded wharf and waste management site and is working with Thames Water to ensure that permanent above and below ground infrastructure and access/maintenance requirements are designed accordingly.

32 The application seeks to demonstrate that the scheme has been designed to be compatible with Thames Water’s permanent requirements for access to and maintenance of the tunnel. Similarly, the applicant is seeking a minimum 12-year planning permission, in order to allow the Tunnel works to be completed prior to implementation of the mixed use redevelopment scheme. Whilst the applicant’s efforts in this regard are appreciated, the proposed development could lead to additional costs being incurred by the Tunnel project and as such could prejudice the implementation of London Plan policy 5.14.

Blue ribbon network

1 Based on Kensington & Chelsea’s Employment Land Review Update (October 2009); this compares to the London Plan assumption of 12 sq.m. of B1 office floorspace per employee

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33 London Plan policies 7.24 to 7.28 collectively seek to capitalise on the water as an asset and enhance the Blue Ribbon Network in order to improve the quality of life for Londoners. Policies 7.25, 7.26 and 7.27 seek to increase the use of the Blue Ribbon Network for passengers and tourism, freight transport and recreational use. Policy 7.27 also states that development proposals should protect and improve access points to or alongside the Blue Ribbon Network.

34 The site currently provides no public access to or alongside the river. The proposed development incorporates a six metre wide river walk which safeguards the ability to achieve continuous public access from Lots Road via the riverside and through to the Lots Road Power Station site. This is welcomed in line with London Plan policy 7.27.

35 The applicant has submitted a structural survey of the existing jetty, which is in a state of disrepair and requires replacement to handle cargo. The jetty overlies the Lots Road Pumping Station combined sewer overflow (CSO) and associated brick channel, which is understood will remain in situ following construction of the Thames Tunnel. The purpose of the survey was to provide structural advice in respect of the extent of any upgrade works necessary for its proposed use for public access, and enable associated costs to be estimated. The scope of the survey was somewhat limited, being restricted to a visual inspection above the water line from the jetty platform and quayside. The survey report concludes that parts of the jetty structure are in poor condition, but that the basic structure can be retained and repaired in order to enable it to be used as a public amenity.

Figure 1: existing jetty and combined sewer overflow channel

36 The application proposes to incorporate the existing jetty as part of the wider Thames Path public realm offer. No physical interventions to the structure are required to enable its use as public realm with only aesthetic surface improvements proposed. The applicant states that due to the location of the existing CSO, it is neither practical nor desirable to provide access to the River Thames from the site for sport or leisure purposes.

37 Insufficient evidence has been provided to demonstrate that re-use of the jetty for river transport uses is not possible within the scope of the proposed development. As such, the application fails to enhance the use of the Blue Ribbon Network and cannot be considered compliant with London Plan policies 7.25, 7.26 or 7.27.

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Housing

38 The application proposes 48 residential units, broken down by size and tenure as follows:

Private Intermediate Affordable rent Total

1-bed 10 0 0 10 (21%)

2-bed 15 0 5 20 (42%)

3-bed 7 2 8 17 (35%)

4-bed 1 0 0 1 (2%)

Total 33 2 13 737 (100%)

Table 1: mix of units by tenure

Affordable housing

39 London Plan Policy 3.12 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mixed-use schemes. In doing so each council should have regard to its own overall target for the amount of affordable housing provision. This target should take account of the requirements of London Plan Policy 3.11, which include the strategic target that 60% of new affordable housing should be for social rent and 40% for intermediate rent or sale. The Mayor has published an early minor alteration to the London Plan to address the introduction of affordable rent, with further guidance set out in a draft Affordable Rent SPG. With regard to tenure split the Mayor’s position is that both social rent and affordable rent should be included within the 60%.

40 While the Mayor has set a strategic investment benchmark that across the affordable rent programme as a whole rents should average 65% of market rents, this is an average investment output benchmark for this spending round and not a planning policy target to be applied to negotiations on individual schemes.

41 Policy 3.12 is supported by paragraph 3.71, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit or other recognised appraisal methodology is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified. Paragraph 3.75 highlights the potential need for re-appraising the viability of schemes prior to implementation.

42 The affordable housing offer as set out in table 1 represents 30% affordable housing calculated by floorspace and 31% calculated by unit. The applicant has submitted a financial viability assessment which seeks to demonstrate that the amount of affordable housing proposed is the maximum reasonable amount. Officers are in the process of assessing the information provided and may require the results of the appraisal to be independently verified in order to ensure compliance with London Plan policy 3.12.

Housing choice

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43 London Plan Policy 3.8 and the associated supplementary planning guidance promote housing choice and seek a balanced mix of unit sizes in new developments. The London Housing Strategy sets out strategic housing requirements and Policy 1.1C of the Strategy includes a target for 42% of social rented homes to have three or more bedrooms.

44 The development provides a good range of units with one to four bedrooms. The provision of affordable family-sized units, in line with the Housing Strategy target, is particularly welcomed. The proposed mix of units complies with London Plan policy 3.8.

Residential density

45 London Plan policy 3.4 seeks to optimise the housing potential of sites, having regard to local context and character, design principles and public transport accessibility. The site has a public transport accessibility level of 2-3. The nearest district centre is King’s Road (West), which is within 800 metres walking distance. For the purposes of assessment against the London Plan density matrix, the site is considered to have an urban setting. The density matrix suggests a residential density of 200-450 residential units per hectare.

46 The applicant has calculated the gross residential density of the proposed development to be 423 habitable rooms per hectare, based on 165 habitable rooms and a site area of 0.39 hectares. The applicant is requested to provide density information based on net residential site area, calculated in accordance with the guidance set out in paragraph 3.35 of the Interim Housing SPG. Notwithstanding the need for this information, the scheme is well designed and provides a high standard of residential accommodation with adequate amenity space. The density of development appears compatible with the local context and character, in line with London Plan policy 3.4.

Children’s play space

47 Policy 3.6 of the London Plan sets out that “development proposals that include housing should make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” The Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ states a benchmark of 10 sq.m. of useable child play space to be provided on-site, with under-5’s play space to be provided on site, as a minimum.

48 The applicant has provided as assessment of the child play space requirements of the scheme. This is based on an earlier iteration of the scheme which included 77 residential units. This assessment indicated that the development would have a child yield of 27, and that the subsequent play space requirement was 270 square metres. The application scheme provides 434 sq.m. of play space, which exceeds the guidance in the SPG; this is welcomed. Urban design

49 Good design is central to all objectives of the London Plan, in particular the objective to create a city of diverse, strong, secure and accessible neighbourhoods to which Londoners feel attached whatever their origin, background, age or status. Policies contained within chapter seven specifically look to promote development that reinforces or enhances the character, legibility, permeability and accessibility of neighbourhoods. It sets out a series of overarching principles and specific design policies related to site layout, scale, height and massing, internal layout and visual impact as ways of achieving this.

50 The proposed development has been commented on at pre-application stage. This set out that the scheme is generally well designed, overcoming the significant constraints associated with

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the Thames Tunnel, providing a good mix of uses and improving the permeability and legibility of the area. The following comments re-iterate many of the comments already set out in the pre- application note and add to them where appropriate.

Site layout

51 The site is located between Lots Road and the River Thames, and between the Lots Road Power Station site and the existing Chelsea Wharf development. The historic building of the former water pumping station (grade II listed) sits between the site and Lots Road.

52 The scheme is located adjacent to the river and provides a six metre wide river walk to one side and a new public space and access route to the other. Both these spaces are welcomed and make a significant contribution to the public realm network in the area. Whilst a wider river walk would be preferable, the constrained nature of the site makes this difficult to achieve and the space provided is sufficient for it to be well used and perform the function for which it is intended.

53 The success of the courtyard space will be subject to the quality of the development surrounding it, of which the applicant can only influence two out of its four edges. Whilst the designers are commended on the amount of active frontages and front entrances facing the space from their own development, there is concern as to how the adjacent development on the Lots Road Power Station site will relate to it.

54 Whilst the semi-public nature of this space will enable it to be secured if necessary, consideration needs to be given to how the public route to the river will be flanked when this space is closed off. It will be important to maintain a visual connection between the route to the river and the ground floor units facing the semi-public space.

55 The continuation of Ashburnham Road through the site to the river front is also particularly welcomed. This creates views of the river and the proposed new spaces from Lots Road, increasing their prominence and visibility from the surrounding area and encouraging their use by the rest of the community, which is welcomed. The provision of a separate commercial building along this route means it will be flanked by active uses on both sides. However, as set out above, any boundary treatment between the semi-public courtyard and the public route to the river should not impede on overlooking from commercial units on to this route.

Scale, height and massing

56 The scale, height and massing of a development will have an impact on the legibility, character and adaptability of its surrounding urban area. London Plan Policy 7.4B sets out a requirement for buildings to provide a contemporary architectural response to the site whilst having regard to the pattern and grain of development in the wider area and being human in scale. London Plan Policy 7.6B sets out the requirement for development to be of a proportion, composition, scale and orientation that enhances activates and appropriately encloses the public realm. London Plan Policy 7.7 sets out additional design requirements for tall and large-scale buildings, which are defined as buildings that are significantly taller than their surroundings and/or have a significant impact on the skyline. The policy includes requirements for buildings to emphasise points of civic or visual significance and have ground floor activities that provide a positive relationship to surrounding streets and to incorporate the highest standards of architecture.

57 The nine storey height of the development is appropriate considering the height of existing and proposed developments around the site. This provides a good level of enclosure to surrounding spaces and creates an appropriate density of development without being overbearing. Its massing is simple and legible with no unnecessary articulation, which is welcomed.

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58 The bottom two storeys form a podium that is shaped to provide good enclosure and definition over the surrounding spaces. Seven storeys of residential accommodation are located in a linear block running parallel to the river above this. The top two storeys of the residential element are set back, reducing the apparent height of the building by creating an overall shoulder height of seven storeys, which is also supported.

Appearance

59 The elevations of the proposed development are characterised by a brick skin covering a corten steel core. Glimpses of the corten steel are provided from different sides, and the corten core extends past the brick skin on the top two storeys. Balconies are located so that four separate bays are created, between which entrances to either the circulation cores or the commercial units are located on the ground level. The scheme provides an interesting and attractive elevation to the river, but as set out previously its success will be subject to the quality of materials used and detailing.

Residential layout

60 London Plan policy 3.5 states that housing developments should be of the highest quality internally, externally and in relation to the wider environment. Part C of the policy states that new dwellings should generally conform with the dwelling space standards set out in Table 3.3, have adequately sized rooms and convenient and efficient room layouts. Part E of the policy states that the Mayor will provide guidance on implementation of this policy including on housing design for all tenures. The reasoned justification provides further guidance and explanation. In particular, paragraph 3.32 makes clear that “Securing new housing of the highest quality and protecting and enhancing residential neighbourhoods are key Mayoral priorities”. The Mayor’s draft Housing Design Guide (July 2009) and the draft replacement Housing SPG (December 2011), provides further guidance on the implementation of these policies.

61 The overall layout of the residential elements of the development is of a high quality and in line with the aspirations set out in the Housing Design Guide and the London Plan. The designers are particularly commended on the provision of two vertical circulation cores, each accessed directly from the public realm, and the limited number of units served by these cores per floor. The number of single aspect units has also been minimised and there are no north facing single aspect apartments, which is welcomed. The applicant has also assured officers that all units are above the minimum space standards set out in the London Plan, which is also welcomed. Inclusive design

62 London Plan policy 7.2 An Inclusive Environment seek the highest standards of accessibility and inclusion (not just the minimum) in new developments. Policy 7.1 stresses the importance of extending these inclusive design principles to the neighbourhood level by meeting Lifetime Neighbourhood criteria. This can help to ensure that the public realm, parking areas, routes to the site and links to adjacent public transport and local services and facilities are accessible, safe and convenient for everyone, particularly disabled and older people. This concept can also help to meet the specific needs of older people (see the CLG report ‘Lifetime Homes, Lifetime Neighbourhoods, A National Strategy for Housing in an Ageing Society’).

63 The Design and Access Statement describes how the scheme responds to the sixteen Lifetime Homes criteria and demonstrates that all units will meet Lifetime Homes standards; this is welcomed in line with London Plan policy 3.8. The planning statement suggests that 83% of units will be wheelchair accessible; whilst this is welcomed, annotated large scale plans of typical flat layouts should be provided to demonstrate how wheelchair standards have been incorporated into

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the design of units, in accordance with the Mayor’s Wheelchair Accessible Housing Best Practice Guidance.

64 The basement layout plans indicate five parking residential parking spaces for blue badge holders, plus one at grade commercial blue badge space. The basement car parks are, however, accessed via two car lifts. The applicant should demonstrate how the car lifts will be designed to ensure that they are accessible and convenient for use by wheelchair users whose vehicles are adapted. Climate change

65 The London Plan climate change policies as set out in chapter 5 collectively require developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures, prioritising decentralised energy supply, and incorporating renewable energy. The policies set out ways in which developers must address mitigation of, and adaptation to, the effects of climate change.

Climate change mitigation

66 London Plan policies 5.2, 5.6 and 5.7 focus on mitigation of climate change and require a reduction in a development’s carbon dioxide emissions through the use of passive design, energy efficiency and renewable energy measures. The London Plan requires developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures and prioritising decentralised energy, including renewables.

Be lean

67 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved substantially beyond the minimum backstop values required by building regulations. Other features include fabric design (facade engineering) and mechanical ventilation heat recovery (MVHR). The demand for cooling will be minimised through solar control glazing and opening louvres in the wintergardens feature.

68 The development is estimated to achieve a reduction of 28 tonnes per annum (10%) in regulated CO2 emissions compared to a 2010 Building Regulations compliant development.

Be clean

69 The applicant has carried out an investigation and there are no existing or planned district heating networks within the vicinity of the proposed development. The applicant has, however, provided a commitment to ensuring that the development is designed to allow future connection to a district heating network should one become available and has committed to installing capped sleeves beyond the basement walls so that future connection is possible; this is welcomed.

70 The applicant is proposing to install a site heat network. The applicant has confirmed that all apartments and non-domestic building uses will be connected to the site heat network. A drawing showing the route of the heat network linking all buildings on the site should be provided. The site heat network will be supplied from a single energy centre located at basement level one, with a floor area of 193 sq.m.

71 The applicant should provide details (output in kWe) of the proposed CHP unit(s) to be installed in the energy centre serving the development and confirm that it will be the lead heat

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source for the site heat network providing domestic hot water load, as well as a proportion of the space heating.

72 A reduction in regulated CO2 emissions of 55 tonnes per annum (50%) will be achieved through this second part of the energy hierarchy.

Be green

73 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install 170 sq.m. of solar photovoltaic (PV) panels on the roof. A roof plan showing the proposed layout of the panels has been provided. The applicant should provide calculations supporting the projected savings in regulated CO2 emissions.

74 A reduction in regulated CO2