planning report GLA/3809/02 30 April 2018 Templar House, 81-87 High Holborn in the London Borough of Camden planning application no. 2015/4407/P Strategic planning application stage II referral Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008. The proposal Demolition of existing building and construction of a 14 storey building comprising 607 sq.m. of retail floorspace, 17,306 sq.m. of office floorspace and 48 residential units. The applicant The applicant is Northwood Investors, and the architect is Astudio Architects. Key dates Stage 1 report: 22 December 2015 Camden Council Committee meeting: 22 March 2018 Strategic issues Camden Council has resolved to refuse permission for this application. The Mayor is entitled to consider whether the application warrants a direction that he is to be the local planning authority for the purpose of determining the application under Article 7 of the Mayor of London Order 2008. Having regard to the details of the application, the matters set out in committee report and the Council’s draft decision notice there are no sound reasons for the Mayor to intervene in this particular case and therefore no basis to issue a direction under Article 7 of the Order 2008. Should the scheme be considered at appeal or a revised application submitted the applicant must address outstanding matters relating to affordable housing, design, heritage, inclusive design, climate change, energy and transport. The Council’s decision In this instance Camden Council has resolved to refuse planning permission. Recommendation That Camden Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct that he is to be the local planning authority. page 1 Context 1 On 24 November 2015 the Mayor of London received documents from Camden Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. This was referred to the Mayor under Categories 1B and 1C of the Schedule to the Order 2008: • 1B: Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings - inside Central London and with a total floorspace of more than 20,000 square metres. • 1C: Development which comprises or includes the erection of a building of more than 30 metres high and outside the City of London. 2 On 22 December 2015 the former Mayor considered planning report GLA/4809/01, and subsequently advised Camden Council that the application did not comply with the London Plan, for the reasons set out in paragraph 97 of the above-mentioned report; but that the possible remedies set out in that paragraph could address those deficiencies. 3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. 4 Following consideration at planning committee on 22 March 2018 Camden Council resolved to refuse planning permission, against officer recommendation. The Council advised the Mayor of this decision on 17 April 2018. Under the provisions of Article 5 of the Town and Country Planning (Mayor of London) Order 2008, the Mayor may allow the draft decision to proceed unchanged, or issue a direction to the Council under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application. The Mayor has until the 30 April 2018 to notify the Council of his decision and to issue any direction. 5 The Mayor’s decision on this case, and the reasons, will be made available on the GLA’s website www.london.gov.uk. Consultation stage issues summary 6 At the consultation stage, the Camden Council was advised that the application did not comply with the London Plan for the reasons set out below. The Council was advised that the resolution of these issues could lead to the application becoming compliant with the London Plan. • Principle of development: the principle of a mixed-use development within the Central Activities Zone is supported. • Housing: The housing choice and density are generally supported; however, further work is needed to address design and residential quality issues. • Affordable housing: there are some strategic concerns regarding the affordable housing provision. Currently it is not possible to determine if the application accords with London Plan Policies. Further information should be supplied to GLA officers regarding affordable housing provision prior to the application being referred back to the Mayor. • Heritage: GLA officers have requested a design option which retains the High Holborn facade as the building is considered to be a positive contributor to the conservation area. page 2 • Design: The appearance of the building will need to be of outstanding quality. Whilst the residential quality is somewhat compromised, given the sites context and central location this may be considered acceptable subject to detailed issues being addressed. • Inclusive access: In order to comply with the London Plan and draft interim Housing SPG the applicant is required to provide an additional wheelchair accessible unit to meet the 10% requirement. • Climate change: Further information and discussion required before the proposal can be considered acceptable and carbon dioxide savings verified. Conditions requiring climate change adaptation must be secured. • Transport: further information regarding transport matters required for assessment prior to the application being referred back to the Mayor. Strategic planning policy and guidance update 7 The following policy and guidance are now material considerations: • London Plan 2016 (consolidated with alterations since 2011) • Camden Local Plan 2017 • Housing Supplementary Planning Guidance • Central Activities Zone Supplementary Planning Guidance • Affordable Housing and Viability Supplementary Planning Guidance • Draft London Plan 2017, which should be taken into account on the basis explained in the NPPF. • On 5 March 2018, the Government published the draft revised National Planning Policy Framework for consultation (until 10 May 2018). This should be taken into account appropriately in accordance with its early stage of preparation. Revisions to the proposal 8 The proposal has been revised since consultation stage. The key changes comprise: • Reduction in the massing of the proposed office building at levels 9-11 and removal of level 12 • Revisions to the principle High Holborn facade • Internal reconfiguration between the residential and office elements of the development • Revisions to the western and eastern facades of the residential block • Affordable housing offer revised from 6 intermediate rented units to 4 affordable rented units • Revisions to residential mix and reconfiguration of residential core and layouts • Reduction in size of the basement 9 The impact of these revisions on the strategic issues raised at consultation stage is considered within the sections below. Council’s reasons for refusal 10 The Council’s draft decision notice includes the following reasons for refusal: page 3 1 ‘The proposed development, by reason of its excessive height and bulk in relation to its surroundings and the loss of the existing front facade which makes a positive contribution to the surrounding Bloomsbury Conservation Area, would cause harm to the character and appearance of the Conservation Area contrary to Policies D1 (Design) and D2 (Heritage) of the Camden Local Plan’. 2 ‘The proposed building height and density, by reason of excessive loss of daylight and sunlight to neighbouring residential occupiers, is considered to result in an overdevelopment of the site contrary to policies A1 (Managing the impact of development), D1 (Design) of the Camden Local Plan 2017.’ 3 The proposed development, in the absence of a legal agreement to secure an appropriate contribution to affordable housing including onsite provision and a deferred affordable housing contribution should viability improve, would fail to contribute to the borough's affordable housing needs, contrary to policies H1 (Maximising housing supply) and H4 (Maximising the supply of affordable housing) of the London Borough of Camden Local Plan 2017 4 The proposed development, in the absence of a legal agreement securing a local employment and training package including an appropriate financial contribution, would be likely to lead to the exacerbation of local skill shortages and lack of training opportunities and would fail to contribute to the regeneration of the area, contrary to policies G1 (Delivery and location of growth), E1 (Economic development) and DM1 (Delivery and monitoring) of the London Borough of Camden Local Plan 2017. 5 The proposed development, in the absence of a legal agreement to secure a construction and demolition management plan and an appropriate financial contribution towards implementation support, would be likely to give rise to conflicts with other road users and be detrimental to the amenities of the area generally, contrary to policies G1 (Delivery and location of growth), A1 (Managing the impact of development), T3 (Transport Infrastructure), T4 (Sustainable movement of goods and materials), DM1 (Delivery and monitoring),