Committee STRATEGIC PLANNING COMMITTEE Report Title Marine Wharf East, Plough Way, SE16 Ward Evelyn Contributors Michael Forrester Class PART 1 Date: 9th June 2015

Reg. Nos. DC/15/91087

Application dated 26.02.2015

Applicant Metropolis Planning and Design on behalf of Quickdrop Ltd

Proposal Demolition of existing office building and redevelopment to provide 225 residential dwellings (comprising 102 x 1 bed, 79 x 2 bed, 40 x 3 bed and 4 x 4 bed) and 1,045 sqm of flexible commercial floor space (Use Classes A1, A2, A3, B1 and D2) in buildings up to 10 storeys with access onto Plough Way, 86 car parking spaces, 285 cycle spaces, landscaping and public realm improvements at Marine Wharf East, Plough Way, SE16.

Applicant’s Plan Nos. 102, 103, 104, 105, 106, 107, 108, 109, 110, 200, 201, 202, 203, 204, 220, 221, 222, 223, 300, 301, 302, 303, 304, 305, 320, 321, 322, 323, 324, PL 001, PL 002, Pl 003, PL 400, PL 401, PL 402, PL 403, PL 404, PL 405, PL 406, PL 407, PL 408, PL 409, PL 410, PL 411, PL 412, PL 413, PL 414, PL 415, PL416, PL 417, PL 418, PL 419, PL 420, PL 412, PL 422, PL 423, PL 424, PL 425, Pl 426, PL 427, PL 428, PL 429, PL 430, PL 431, PL 432, PL433, PL 434, PL 435, PL 436, PL 437, PL 438, PL 439, PL 440, PL 441, PL 442, PL 443, PL 444, PL 445, PL 446, PL 447, PL 448, PL 448, PL 450

Design and Access Statement, Homes Landscape Illustrative Material 5165.LIM.006, Arboricultural Statement 5165 FE AS 01 Rev A, Landscape Management Plan, Construction Environmental Management Plan Revision 03, Ecological Appraisal of Land at Plough Way, Outline Construction Logistics Plan February 2015, Planning Statement, Travel Plan February 2015, Transport Assessment February 2015, Statement of Community Involvement, Sustainability Statement, Energy Strategy, Update to Economic Regeneration Statement, Environmental Statement Volume 1 Non-Technical Summary,

Environmental Statement Volume 2 Main Report, Environmental statement Volume 3 Townscape and Visual Impact Assessment, Environmental statement Volume 4 Technical Appendices Part 1, Environmental Statement Volume 4 Technical Appendices Part 2

100 A, 101 A received 22nd May 2015.

Background Papers (1) Case File DE/153/C/TP(2) Local Development Framework Documents(3) The London Plan

Designation Area of Archaeological Priority, PTAL 1/2b, Mixed Use Employment Location, Local Open Space Deficiency, Flood Risk Zone 2/3, Thames Policy Area

Screening The development is considered to fall within Schedule 2, Category 10b (urban development project) of the EIA Regulations. Consequently an EIA is required.

A Scoping Opinion pursuant to Regulation 13 of the Regulations was issued in September 2014.

This application is accompanied by an Environmental Statement.

1.0 Introduction

1.1 The submission of this application follows extensive pre application discussions (September 2015 - February 2015) between the Council and the applicant regarding development opportunities for this site. As part of pre-application discussions the proposal was considered by the Lewisham Design Review Panel on two occasions.

1.2 On 26th February 2015 the Council received an application for full planning permission made by Metropolis Planning on behalf of Quickdrop Ltd for the redevelopment of the site comprising demolition of the existing office building and erection of two new buildings (up to 10 storeys high) which would accommodate 225 residential dwellings and 1,045sqm of flexible commercial floorspace (A1, A2, A3, B1 and D2 Use Classes).

1.3 This application is a further submission on the site, following the grant of planning permission in 2014 for two buildings up to 8 storeys in height with 183 residential dwellings and 1,045 sqm of flexible commercial space. The proposals are submitted as a completely fresh application and not an amendment to an existing permission. It is proposed to retain the same layout and landscaping arrangements as previously approved, however, the buildings on Plough Way would increase in height by 1-2 storeys and on the central tower by 2 storeys. The revised proposals include 42 additional residential dwellings.

1.4 In response to issues raised by the Council and Statutory Consultees during the consultation period, the proposed development was subsequently amended. The amendments included:

An addendum to the Environmental Statement (Daylight and Sunlight Chapters); Clarification of living roof detailed planting specification; Revised plans to provide a London Plan policy complaint level of cycle parking at

ground floor in blocks A and B.

1.5 The amendments were of a minor nature and the additional information submitted was not considered to be significant enough to warrant a re-consultation. Although the daylight and sunlight information submitted for the ES was amended and clarified.

1.6 This report considers the proposals (as amended) in light of relevant planning policy and guidance, representations received and other material considerations, and makes recommendations on the determination of the application.

1.7 For the reasons set out in this report the proposal is considered to be an acceptable form of development and Officers recommend that subject to the necessary conditions to control the development in detail and the planning obligations required to mitigate the impact of the development, planning permission should be approved.

2.0 Application Site and Surroundings

Application Site

2.1 The site, known as Marine Wharf East, is a 0.87 hectare site located in Deptford, in the north of the Borough. The site is located on the south side of Plough Way at its junction with Grove Street. The site is bound by Plough Way to the north, Grove Street to the East, Hockett Close open space to the south and the Marine Wharf West site to the west.

2.1.2 The site is currently occupied by a 2 storey data recovery centre (approximately 4,645 sqm of B1 floorspace) and associated car parking areas for 140 cars accessed from Plough Way. The recovery centre is still in use. It is understood that the recovery centre has a lease for the premises until Autumn 2015.

2.1.3 There is a vehicular access point on Grove Street but it is understood that this is used for servicing only.

2.1.4 There is a significant change in ground level across the site. A topographical survey undertaken by the applicant revealed that there is a 2.8m level difference from the lowest to highest point of the site, going northeast to southwest.

Figure 1: Existing site plan

Surroundings

2.2 This site lies on the Borough boundary with Southwark. The boundary runs down the centre of Plough Way so that the properties on the north side of Plough Way reside in Southwark whilst those on the south side fall within the Lewisham boundary.

2.2.1 This part of Deptford is mixed in character, including local authority estates, private housing, new mixed use developments and industrial uses.

2.2.2 The area immediately surrounding the site contains predominantly residential buildings of various heights. There are 2-3 storey residential buildings on Plough Way and Dunnage Crescent (to the north), 2-3 storey residential buildings on Grove Street and Capstan Road (to the east), an area of public open space and electricity substation immediately to the south with 2-3 storey residential buildings beyond (Hockett Close and Kempthorne Road).

2.2.3 The Berkeley’s scheme (Marine Wharf West) adjoins the site to the west and has been designed with perimeter style blocks with internal courtyards, a central access route running through the site from Plough Way and commercial uses fronting Plough Way to provide active frontage. The heights range from 1-8 storey’s. The final phase of the scheme (Blocks J and K) would be constructed adjacent to the shared boundary with this site and linked at first floor podium level.

2.2.4 To the east of Marine Wharf West lies the Cannon Wharf site which has been designed with buildings ranging between 1 – 8 storeys with two taller towers (20 and 23 storey’s).

2.2.5 Baltic Quay is an existing significantly taller building located to the north east of the site.

2.2.6 The River Thames is located in close proximity to the north and east of the site although access to the Thames is rather restricted at the present time.

2.2.7 The largest existing areas of public open space within 1km of the application site are Deptford Park, Upper and Lower Pepys Park and Southwark Park. In addition, there are smaller green spaces within the Pepys Estate.

2.2.8 The first phase of the new linear park within the Marine Wharf West site is complete with the second phase anticipated to be complete in summer 2015.

2.2.9 The site is served by the 199 bus (and N1 night bus) along Plough Way and Grove Street. Other bus routes (47, 188 and N47) can be accessed on Evelyn Street which is a short walk from the site. The nearest London Overground station is Surrey Quays with underground services further away at Canada Water on the Jubilee Line, and the nearest railway stations are at South Bermondsey and Deptford providing connections to south and central London and Kent. Commuter river services are available from Greenland Pier, to the north of the application site, providing connections as far as the London Eye Millennium Pier to the west, and Woolwich Arsenal to the east.

2.2.10 The majority of the site and surrounding area has a Public Transport Accessibility Level (PTAL) rating of 2, where 1 is poor and 6 is excellent. The nearest cycle route forming part of the Lewisham Cycle Network, runs along the bank of the River Thames via Deptford Wharf and Deptford Strand to the east of the site.

2.2.11 Plough Way and Grove Street are secondary roads . Both routes connect to Evelyn Street and Lower Road (A200). The vehicular access routes through Carteret Way and Kempthorn Road are private roads that fall within the management of Lewisham Homes.

2.2.12 The nearest district centre within the Borough is Deptford, however the Surrey Quays Shopping Centre (to the northwest of the site) is closer.

2.2.13 The site does not lie within a protected viewing corridor, is not within a conservation area and does not contain any listed buildings.

3.0 Planning History

3.1 The existing data collection centre was built in the mid 1990’s.

3.2 DC/08/68907: Demolition of the existing buildings at Marine Wharf, Plough Way SE16 and construction of 7 single to five storey buildings, comprising 10,892sq.m of Use Class B1 floor space (office), cafe (271sq.m), crèche (270sq.m) and gym (389sq.m), together with associated landscaping, provision of service areas, refuse stores, 100 cycle spaces and 19 car parking spaces. This application remains undetermined.

3.3 DC/13/85917: Demolition of the existing office building and redevelopment to provide 183 residential dwellings (88 x 1 bed, 55 x 2 bed, 36 x 3 bed and 4 x 4 bed) and 1,053 sqm of flexible commercial floorspace (A1,A2,A3,B1 and D2 Use Classes) in buildings up to 8 storeys, together with access onto Plough Way, 83 car parking spaces, 233 cycle parking spaces, landscaping and public realm improvements at Marine Wharf East, Plough Way, Deptford, SE16 – Granted, but not implemented.

3.4 History for relevant surrounding sites is set out below.

3.5 This site forms part of the Plough Way Strategic Site which is allocated for mixed use development. The strategic site includes Cannon Wharf, Marine Wharf West, Yeoman Street and Croft Street. As part of the Marine Wharf West application, in order to meet policy requirements, a masterplan was prepared for the strategic site. This covered the majority of the strategic site, though excluding the operational Earl Pumping Station. The masterplan set out development principles for the strategic site in terms of site layout and linkages across the area, on the location of commercial uses and on scale and massing of development across the site.

3.6 Although a masterplan was prepared, two of the sites that form part of the strategic site allocation (Marine Wharf West , Berkeley Homes and Cannon Wharf, Barratt London) are being developed separately.

3.7 The Marine Wharf West site is currently being redeveloped for a mixed used scheme comprising the construction of new buildings between 1 and 8 storeys in height to accommodate 4,126 square metres of commercial floorspace (Use Classes A1/A2/A3/B1/B1c), 532 residential units (including 78 units provided as an "Extra Care" facility), car parking, pedestrian and vehicular access, landscaping, new public open space along the route of the former Grand Surrey Canal, and other associated works. The development of the site will be undertaken in 7 phases. Development commenced in January 2011 and is anticipated to be completed by April 2016. Phase 7, Block K of this development has recently been granted planning permission for an additional 34 residential units under application reference DC/14/89436.

3.8 This brings the total number of dwellings within the Marine Wharf West scheme to 566 units.

3.9 Further to the west, on the opposite side of the former route of the Grand Surrey Canal, is the Cannon Wharf site. Planning permission exists for redevelopment of the site comprising 679 residential units and 6,588m2 of commercial space, with 401 car parking spaces and 749 cycle parking spaces. The approved buildings range in height from 3 storey houses to 8 storey perimeter blocks and two tall buildings (20 and 23 storeys).

Development has commenced on site in connection with the redevelopment. All buildings except the Cannon Business Centre have been demolished and the site has been divided into two sections. The northern section has been separated from the southern section which accommodates the Business Centre to enable the Business Centre to continue to operate whilst construction is taking place. The development of the site will be undertaken in 7 phases. Development commenced in May 2013 and Phase 1 is now fully occupied, construction is anticipated to be completed by September 2018.

3.10 Industrial Sites in Yeoman Street form the remainder of the Plough Way Strategic Site. These sites are currently open storage including a builder’s yard/depot contained within dilapidated open sided buildings at 19 Yeoman Street and an office/warehouse and vehicle storage/maintenance opposite (also fronting Croft Street). Both of these sites are subject to discussions regarding redevelopment opportunities although no planning permission has been granted at this time.

3.11 The final piece of the Plough Way site is 7-17 Yeoman Street, located at the northern tip of the allocated site on the eastern side of Yeoman Street. Planning, where a five storey building with 33 residential units has recently been constructed.

Proposed Thames Tunnel

3.12 Thames Water is currently developing proposals for a new Thames Tunnel (sewer) between Hammersmith and Abbey Mills or Beckton, and related surface development. Thames Water have identified part of the Plough Way Strategic Site – the Earl Pumping Station and adjacent land between Croft Street and Yeoman Street as the preferred site for construction work and permanent structures associated with the new tunnel. Thames Water’s proposals are that land immediately to the south of the existing Earl Pumping Station (36-38 Yeoman Street) is used as a permanent interceptor site for the storm overflow into the Thames to the east. Current proposals show an oval-shaped structure approximately 3-5m in height (depending on the final design) to accommodate the new plant and control equipment with the remaining land either left as open space or redeveloped.

3.13 A planning application was submitted for the Thames Tunnel in March 2013 and has been approved.

3.14 As part of Thames Water’s proposals a new tunnel would pass beneath part of the Plough Way Strategic Site (Cannon Wharf) but would not directly affect Marine Wharf East. However, if the Thames Tunnel development does go ahead the construction could coincide with the redevelopment of the Marine Wharf East site. Consequently this has been taken into account when considering cumulative effects as part of the Environmental Statement. This would also need to be addressed in the Construction and Environmental Management Plan.

4.0 Current Planning Applications

The Proposals

4.1 Planning permission is sought for redevelopment of the site for mixed use purposes. The existing building would be demolished entirely to make way for the erection of two new buildings that would accommodate commercial floorspace on the ground floors and 225 residential units on the upper floors.

4.2 The redevelopment would provide 1045 sqm Gross External Area (GEA) of commercial floorspace. It is proposed to provide units that can be used for a range of uses falling within Use Classes A1/A2/A3/B1 and D2. The uses would be laid out as follows:-

Unit 1 – 478.57 sqm (D2 or B1 Use Classes only) Unit 2 – 139.09 sqm Unit 3 – 223.0 sqm Unit 4 – 203.5 sqm

Flexible Use Classes A1/A2/A3/B1/D2

4.3 Residential development is proposed in the form of 225 residential units comprising 102 x one beds, 79 x two beds, 40 x three beds and 4 x four beds. 22 wheelchair units would be provided with a tenure split (20 private and 2 affordable).

4.4 The application was initially submitted with 34 affordable units (18 rented and 16 intermediate), however, during application negotiations this has been increased to 40 units (24 rented and 16 intermediate). The affordable units are located in both Blocks A and B, with the additional affordable units negotiated during the planning application at the ground floor of A and B, with their own front doors onto either the home zone or POS. The intermediate units previously proposed in these locations have been relocated to the private cores within the development.

Site Layout

4.5 It is proposed to separate the site into two halves by way of a Homezone route running through the centre of the site from Plough Way to Kempthorne Road. The proposal comprises two main development blocks, rising to a maximum height of ten-storeys, surrounding two podium courtyards, and located either side of the Homezone route proposed through the site. Block A, located in the eastern section of the site forms a complete perimeter block with frontages onto Plough Way, Grove Street, Hockett Close Public Open Space (POS), and the proposed Homezone. Block B, located to the west of Block A would complete the perimeter block of the adjacent development site fronting the proposed Homezone.

4.5.1 Block A has been designed with internal podium level courtyard. Block A buildings on the Plough Way and Grove Street frontage would screen the ground floor car park which would be accessed from the internal road. Duplex units with their own private accesses would be provided on the Grove Street frontage. The ground floor flats in the southern block facing the Hockett Close POS would also have their own private accesses. Commercial units and communal access cores would be provided on the Plough Way frontage and access to the residential tower would be provided from within the Homezone.

4.5.2 Heights in Block A would comprise 5 storeys on the Grove Street frontage, 4 storey’s on the Hockett Close frontage, 6 storey’s (commercial height ground floor + 5 floors above) on the Plough Way corner, 6 storeys (commercial height ground floor + 5 floors above) for the western end of Plough Way and 10 storey taller building on the western side facing the internal route.

4.5.3 The building on the western side of the Homezone (Block B) would be constructed as a ‘reversed C shaped’ structure reflecting the position of the site boundary. The section on the Plough Way frontage would be constructed onto the party wall with Marine Wharf West (known as Blocks J and K). The buildings would wrap around the ground floor car park with a podium level internal courtyard above. The podium would be sited adjacent to the podium on the adjoining site. Commercial uses and one access core would be located along the Plough Way frontage and communal residential uses would front onto the internal Homezone route. Heights in this block would comprise 6 storey’s (commercial height ground floor + 5 residential floors above.

4.5.4 The new site layout would provide 88 car parking spaces, 20 of which would be DDA spaces for the wheelchair units, 1 DDA space for the commercial units together with 6 motorbike parking spaces, 1 on-street loading bay and 271 cycle parking spaces for residents with a further 7 cycle stands in the home zone.

Figure 2: Proposed Site Plan.

4.5.5 The new blocks would be constructed predominantly of brick with the use of metal cladding, timber and reglit style glazing to add articulation and interest to the facades. Powder coated aluminium fenestration would be utilised throughout as well as metal railings for projecting and inset balconies. Both blocks would have extensive living roofs and photovoltaic panels.

4.5.6 The buildings would be set back into the site boundary to facilitate the provision of wider footpaths to Grove Street and Plough Way.

Supporting Documents

4.6 Design and Access Statement (prepared by BUJ Architects)

4.7.1 This document provides a comprehensive description of the site, outlines the site conditions that have influenced the scheme from that previously consented, sets out to describe the design principles behind the proposed development and explains the rationale for the scheme. The document covers site context, design principles, connectivity and permeability, height and massing, architectural appearance and materials, land use and amount of development, unit types, daylight, sunlight, open space and landscaping as well as access, refuse and recycling arrangements and servicing.

4.7 Landscape Illustrative Material and Management Plan (prepared by First Environment Ltd)

4.8.1 This document sets out the landscaping proposals for the development including the communal courtyards for both blocks, the Homezone, street frontage treatment and potential improvements to the Hockett Close POS. The document contains full details of hard scape materials, street furniture, lighting and soft landscaping details including planting species and numbers. The document also contains full specification of the proposed living roofs.

4.8.2 The 5 year management plan covers detailed management and maintenance for all landscaped areas as well as arrangements for the living roofs. An annual maintenance schedule for the first 12 months is provided (defect period) and then a second schedule for the period after the 12 months defect period is provided. The management plan includes detailed planting specifications.

4.9 Ecological Appraisal (prepared by First Environment Ltd)

4.9.1 This report sets out the findings of the protected species and habitats survey undertaken in June 2013. The report covers badgers, bats, birds, reptiles and habitats. The report concludes that the site has limited ecological value and the proposal would have limited, or no impact on wildlife or habitats.

4.10 Arboricultural Statement (prepared by First Environment Ltd)

4.10.1 The report confirms that the site and proposed development have been assessed in accordance with the relevant British Standard, BS 5837:2012.

4.10.2 A total of 33 individual trees were recorded during the survey. These trees fall within the site boundary and the adjacent public open space. None of the trees are covered by a Preservation Order or Conservation Area Consent. The report notes that many of the trees are self seeded and whilst visible in the public realm they are of low quality and limited value. It is proposed to remove all trees as part of the redevelopment.

4.11 Economic Regeneration Statement and Addendum (prepared by Peter Brett Associates)

4.11.1 This document sets out the social and economic profile of the Borough and Evelyn ward. The report discusses employment statistics and trends, existing employment space within the Borough, potential for new employment space within this area, existing retail, leisure and community facilities and current social infrastructure provision and requirements. The report considers demographic projections based on GLA data and seeks to assess the economic and social benefits of the proposed development.

4.11.2 The report seeks to justify the amount and type of commercial development proposed and concludes that this development could reasonably accommodate circa 1000 sqm of commercial floorspace across a range of flexible uses. The report states that it is necessary to consider a variety of delivery mechanisms available to encourage take up of the commercial space.

4.11.3 The Addendum report deals specifically with retail impact. The report sets out national and development plan policies relating to the provision of new retail, considers the cumulative retail impact of the Plough Way Strategic site and seeks to justify the amount of retail proposed as part of this mixed use development.

4.12 Planning Statement (prepared by Metropolis Planning and Design)

4.12.1 This statement describes the site context, history and relevant planning policy. A brief assessment of planning considerations is provided (principle, commercial floorspace, housing, urban design, residential amenity, highways, energy, sustainability and environmental considerations). Finally the statement addresses planning obligations and affordable housing.

4.13 Statement of Community Involvement (prepared by Metropolis Planning and Design)

4.13.1 This statement sets out the consultation that was undertaken by the applicant as part of the pre application process. The results of the consultation are discussed together with an explanation of how the consultation has informed the proposals. Copies of the exhibition letter, newspaper advertisements, feedback forms, design workshop invitations and exhibition material are included as appendices.

4.14 Energy Statement (prepared by Metropolis Green)

4.14.1 This report has been prepared in line with the Mayors energy hierarchy: Be Lean, Be Clean, Be Green. The report describes how the proposed development meets policy requirements by setting out the energy modelling, measures to address energy efficiency, overheating and cooling, communal heating and combined heat and power and renewable energy. The report concludes that the development would achieve 51.7% carbon emission reductions of which 14.9% would be from the use of photovoltaic panels, The residential units would also meet Code for Sustainable Homes Level 4.

4.15. Sustainability Statement (prepared by Metropolis Green)

4.15.1 This report has been prepared to show how the development will respond to London Plan and Core Strategy sustainability policies. The report includes Pre Assessments to show how the development would obtain Code for Sustainable Home and BREEAM credits. It is proposed that the residential units would achieve CfSH Level 4, the commercial units would achieve BREEAM ‘Very Good’ rating.

4.15.2 The report states that the development has targeted sustainability throughout the lifetime of the buildings. In particular energy and water efficiency measures are integral to the design and specification of the buildings and passive design measures have been used to

prevent overheating and excessive mechanical cooling. Through the design the applicant is seeking to reduce the reliance on technology to meet sustainability principles.

4.16 Transport Statement and Addendum and Strategic Level Full Residential Travel Plan (prepared by Paul Mews)

4.16.1 The Transport Assessment and Addendum sets out the existing site conditions including surveys undertaken to establish trip generation from the existing site, vehicular movements in Plough Way and Grove Street and parking capacity for the surrounding streets. Modelling has been undertaken to demonstrate the trip generation impact from the proposed development both in terms of vehicles and pedestrians.

4.16.2 The report seeks to justify the low level of car parking proposed as the development would be reliant upon sustainable transport modes. Proposed parking, site layout and servicing is discussed. The report concludes that subject to appropriate mitigation the development would not have an adverse impact on the surrounding highway network, would not give rise to excessive on street parking and would make a positive contribution to transport and public realm in the vicinity of the site.

5.0 Consultation

5.1 This section outlines the consultation carried out by the applicant prior to submission of the application as well as the consultation undertaken by the Council following the submission of the application, and summarises the responses received. The Council’s consultation exceeded the minimum statutory requirements and those required by the Council’s adopted Statement of Community Involvement.

Pre Application Consultation

5.2 The applicants engaged in discussions with local residents prior to the submission of this application. A public exhibition was held on the 18th February 2015. Details of the exhibition are provided in the applicants Statement of Community Involvement.

5.3 In addition the applicant team had pre-application discussions with the GLA as well as engaging in extensive pre application discussions with LBL Officers.

Council Consultation

5.4 The application was advertised as EIA development and a departure from adopted planning policy in the press on 11th March 2015.

5.5 Various site notices were displayed in the vicinity of the site on 11th March 2015

5.6 Letters were sent to 307 neighbouring residents and businesses on 2nd March 2015.

5.7 Local Evelyn ward Councillors were also notified.

5.8 Natural England, Metropolitan Police, Thames Water, Environment Agency, English Heritage, the GLA, Southwark Council and Transport for London were consulted.

5.9 Due to the number of representations received, in accordance with the Council’s Statement of Community Involvement a Local Meeting was held on the 29th April 2015 at the Surrey Water sports Centre on Rope Street. A copy of the minutes from that meeting is appended to this report.

Written Responses received from Local Residents and Organisations

5.10 At the time of writing 17 letters of objection/ comments had been received from the occupiers of 6D, 6F, 7B Dunnage Crescent, 191 Plough Way, 12, 24, 29, 50, 57, 66, 68, 69, 70 Sirius House (Marine Wharf West), 15, 53, 60 Cadmus Court (Marine Wharf West), An objection from the owner of 62 Sirius House, 36 and 38 Cadmus Court was also received, along with the owner of Cherfold Petworth Road, Chiddingford. The following points were raised:-

Concern about the height of buildings, which are already 8 storeys high. Why is the developer allowed to go to 10 storeys.

Any height should be consistent with Marine Wharf West, the scheme is out of keeping with the area.

Buildings should be set back in line with the existing office building.

Concern about noise

What provision has been made for public transport

The existing office use should be retained

The road network will not be able to accommodate the capacity of this development unless there is an overhaul of the road conditions.

There is already a capacity issue with the bus services in this area. The 199 bus is over subscribed and difficult to get on during peak times

This will lead to more parking on the street where there are already parking problems

The construction will cause disturbance. With the developments taking place in this area construction disturbance will go on for at least 10 years

The new buildings will cause a loss of privacy to residents in Hockett Close

The proposal does not meet Core Strategy Policies as it does not respect the character of the surroundings along Plough Way and Grove Street. Why is the height located on Plough Way and not elsewhere?

The provision of more flats does not meet the need for a mix of dwelling types as set out in Core Strategy Policy.

Are any of the units really affordable?

Is this development subject to s106 or CIL?

Has a proper assessment been made in respect of daylight/sunlight, will there be right to light issues for properties in Plough Way?

There is concern that the commercial properties will attract late night and/or anti-social behaviour if fast food premises, gambling or drinking establishments are allowed

The commercial uses will generate noise, litter and pollution for neighbouring occupiers. There is no commercial parking, Tesco at Marine Wharf West causes problems at present.

There will be increased overlooking and loss of privacy for properties on the opposite side of Plough Way

What measures are in place to control dust, vibration, noise and traffic issues arising during construction?

What arrangements are in place for deliveries to the site?

There could be a conflict between the bus stops and site access points.

There needs to be joined up thinking with Southwark Council.

5.13 Written Responses received from Statutory Agencies

5.14 Natural England

No response received

5.15 GLA including Transport for London

Housing

5.15.1 London Plan Policy 3.8 requires different sizes and types of dwellings to met different needs. The proposed unit mix compared with the consented unit mix is set out below:

Unit Type Consented Proposed

1 bed 88 (48%) 102 (45%)

2 bed 55 (30%) 79 (35%)

3 bed 36 (20%) 40 (18%)

4 bed 4 (2%) 4 (2%)

Total 183 225

5.15.2 The proposed unit mix is broadly similar to the consented development, although with fewer one bed and fewer three bed units. The Council should confirm that the proposed housing mix is in line with local needs.

Density

5.15.3 The site is urban in character with a PTAL of 2, and therefore the density guideline set out in table 3.2 of the London Plan is 200-450 habitable rooms per hectare. The consented development had a density of 587 habitable rooms per hectare and therefore the principle of higher density development has been established on the site. In addition, the high residential quality and provision of amenity space reinforces that the density of the proposals is appropriate. The applicant should however, provide the residential density figure for the site, in line with paragraph 1.3.47 of the Mayors Housing SPG. This should be provided in both units and habitable rooms per hectare.

Residential quality

5.15.4 The quality of the residential units is high. All of the proposed units would meet or exceed the space standards set out in the London Plan and the Mayors Housing SOPG. The god

core to the unit ratio would ensure that the majority of units would be dual aspect, and none of the single aspect units would be north facing. All of the units would have private amenity space.

5.15.5 All new homes would be built to ‘Lifetime Homes’ standards and 22 (10%) would be wheelchair accessible, as asset out in the accommodation schedule provided.

Children’s playspace and amenity space

5.15.6 As set out above each of the residential units would have private amenity space. In addition, there would be three areas of shared amenity space. The home zone, between the block A and block B buildings, would be 1,360 sq.m; the podium within block A buildings would be 1,377 sq.m; and the podium within the block B buildings would be 581 sq.m (although this would be shared with Marine Wharf West). The proposals therefore include a generous level of both private and communal amenity space.

5.15.7 The design and access statement includes the playspace requirement calculated in line with the Mayor’s ‘Shaping Neighbourhoods: Informal Play and Recreation SPG’. The proposals would generate a requirement for 520 sq.m of playspace, with 201 sq.m for children under five years old. The landscaping strategy indicates that areas for informal play would be incorporated within the block A podium courtyard, for example, through stepping stones within the lawn. While this approach is welcomed, the Council should require details of the playspace by condition to ensure that an appropriate amount of space with genuine opportunities for play is provided.

5.15.8 The design and access statement demonstrates that there are a number of play areas within the vicinity of the proposed development. The Council should confirm whether any contributions are required towards these spaces as a result of the proposals.

Affordable Housing

5.15.9 The accommodation schedule sets out the following affordable housing mix::

5.15.10 The affordable housing set out above equates to 15% of the total number of units, in a ratio of 53:47 affordable rented to intermediate, which is broadly similar to the consented scheme. London Plan policy sets out that affordable housing should be provided at a ratio of 60:40 social rent to intermediate housing, although the Council’s preference is a 70:30 split. The Council should confirm whether the proposed affordable housing split complies with local needs. The emphasis on family affordable accommodation is supported in line with London Plan Policy 3.11.

5.15.11 While the proposed affordable housing provision is greater than the consented scheme, which provided 11% affordable housing, a viability assessment is required to demonstrate that the maximum reasonable amount of affordable housing has been provided, in line with Policies 3.11 and 3.12. The planning statement sets out that the application is to be supported by an affordable housing/ viability statement which demonstrates that the maximum reasonable amount of affordable housing would be delivered on site.

5.15.12 The viability assessment will need to be independently verified by the Council or an appointed consultant, and supplied to the GLA prior to Stage II referral, together with a copy of the Council’s independent report. GLA officers will expect the independent assessment to scrutinise the development finances to understand the financial constraints inputted into the toolkit and how this has impacted on affordable housing provision. If the assessment demonstrates that the scheme has afford to deliver a greater amount of affordable housing, any additional affordable homes should be provided on site, in line with London Plan Policy 3.12C.

Transport

5.15.13 The changes to the current planning application from the consented scheme on this site, amount to an additional 42 residential units, are not significant in terms of strategic transport.

5.15.14 Car parking numbers have increased slightly, but overall provision of 0.38 spaces per units is a reduction from the permitted scheme (0.4 spaces per unit). There would be one disabled parking space for each wheelchair unit, which is in line with London Plan standards, and electric vehicle charging points are proposed to be provided in accordance with the London Plan and these should be secured b y condition. A car club space would also be provided. A car parking management plan should be secured through the section 106 agreement, covering the same elements identified in the previous section 106 agreement (July 2014).

5.15.15 The permitted scheme secured funding within the section 106 agreement for an extension of a controlled parking zone to the area and this should be replicated for this application.

5.15.16 Cycle parking does not accord with the London Plan standards for the residential units, there is a shortfall of 63 spaces. It is acknowledged that the application was finalised in February this year, prior to the adoption of the updated London Plan in March, however, by that stage the changes to the standards were well known (post EIP Inspectors Report) and, as such, the applicant should consider how the latest standards can be met. The location of the site, in a relatively low PTAL area, yet congested (both road and public transport) area of inner London and close to the proposed cycle Superhighway 4 and waterloo-Greenwich pilot Quietway, should lend itself to relatively high model shares for cycling, so limited cycle parking should not be a constraint.

5.15.17 The section 106 agreement for the permitted scheme contained a contribution towards bus service enhancments (£180,000) and a requirement to provide real time transport information in a communal area and this should be replicated here. Similarly, the travel plan and car club membership funding, site specific transport and public realm contribution, section 278 highway works and construction logistics plan should be secured through Section 106 agreement/ condition.

Climate change mitigation

Energy efficiency standards

5.15.18 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 would be improved beyond the minimum backstop values required by building regulations. Other features include low energy lighting throughout and mechanical ventilation with heat recovery in the commercial spaces.

5.15.19 The applicant is proposing a natural ventilation strategy for the dwellings and mechanical cooling for the commercial unit. The demand for cooling would be minimised through openable windows and the inclusion of green roofs. The applicant has stated that the preliminary Part L analysis shows that the samples nits would be within the required temperature limit. Part L compliance data sheets of the sample dwellings should be provided to demonstrate that there is only a slight risk of high summer temperatures. If the modelling outputs show a medium risk, further passive measures in line with London Plan Policy 5.9 should be intergraded to reduce the risk of overheating.

5.15.20 The applicant should note that the ASHP is considered a renewable technology and should not be included in this part of the energy hierarchy and the applicant should update the figures to reflect this.

5.15.21 The development is estimated to achieve a carbon reduction of eleven tonnes per annum (4%) in regulated CO2 emissions compared to a 2013 Building Regulations compliant

development. Sample SAP worksheets (both TER and DER) for energy efficiency measures only should be provided to support the savings claimed.

District heating

5.15.22 The applicant has carried out an investigation and has identified that the SELCHP network is within the vicinity of the development. The applicant has contacted SELCHP to discuss the potential for connection, however, SELCHP has stated that an extension to the development is not considered feasible. Evidence of the correspondence has been provided. The applicant has provided a commitment to ensuring that the development is designed to allow future connections to a district heating network should one become available.

5.15.23 The applicant is proposing to install site heat network. However, the applicant should confirm that all apartments and non-domestic building uses would 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.

5.15.24 The site heat network would be supplied from a single energy centre. Further information on the floor area and location of the energy centre should be provided.

Combined Heat and Power

5.15.25 The applicant is proposing to install a 48KW, gas fired CHP unit as the lead heat source of the site heat network. The CHP is sized to provide the domestic hot water load, as well as a proportion of the space heating. A reduction in regulated CO2 emissions of 93 tonnes per annum (32%) would be achieved through this second part of the energy hierarchy.

Renewable energy technologies

5.15.26 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install 367m2 of Photovoltaic (PV) panels on the roof of the development. A roof layout plan has been provided detailing the location of the PV panels. A reduction in regulated CO2 emissions of eleven tonnes per annum (5%) would be achieved through this third element of the energy hierarchy.

Overall carbon savings

5.15.27 A reduction of 115 tonnes of CO2 per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected, equivalent to an overall saving of 38%. The carbon dioxide savings exceed the targets set within Policy 5.2 of the London Plan, however, the comments above should be addressed before compliance with the London Plan energy policy can be verified.

Flood Risk

5.15.28 The site is within Flood Zone 3. A Flood Risk Assessment (FRA) has been provided with the application which confirms that the site is protected to a high level by the Thames tidal flood defences and has considered the implications of a potential breach in the flood defences.

5.15.29 The FRA has considered a range of mitigation measures to address the residual flood risk to the site. These involve:

5.15.30 Taken together these measures represent an appropriate consideration of residual flood risk and should be secured via an appropriate planning condition. With such a condition,

the principle of the proposals is acceptable in principle in terms of London Plan Policy 5.12.

Sustainable Drainage

5.15.31 The FRA states that surface water discharge will be limited to 5l/s by the use of green roofs, oversized pipe connections and underground storage crates. Given the nature and location of the proposals this is considered an acceptable approach to London Plan Policy 5.13 and should be secured via an appropriate planning condition to be discharged via consultation with the Council’s drainage team.

London Borough of Southwark

5.17 No comments received.

Greater London Archaeological Advisory Service

5.17.1 It is noted that an archaeological desk-based assessment report prepared by Mr Hawkins of CgMS Consulting Ltd dated July 2013 has been submitted as part of the current planning application under Appendix 8.2 of the ES report dated December 2013. Having considered the submitted document I am happy to recommend its approval.

5.17.2 It is noted paragraph 8.69 of the ES report states that any potential mitigation that may be requested could be secured by condition but with out appearing to suggest the form of such a mitigation. It is noted that the archaeological potential is likely to be ‘low’ but it appears not to have fully considered the potential for cultural material to be associated with the upper and lower horizon of peat that has been recorded on site. It is recommended that the archaeological interest and/or practical constraints are such that I consider a condition could provide an acceptable safeguard.

5.17.3 A condition is therefore recommended to require a two-stage process of archaeological investigation comprising: first, evaluation to clarify the nature and extent of surviving remains, followed, if necessary, by a mitigation strategy.

5.17.4 It is further recommended, as alluded to in the recommended condition that the archaeological interest can be progressed by an assessment of the geotechnical data by the preparation of suitable deposit models and transects. The result of this assessment will determine the potential of undertaking any limited geoarchaeological borehole site work and then if a mitigation strategy is required in relation to the actual development impacts.

5.17.5 Any planned geotechnical site work will need to respect the archaeological interest and be therefore a part of the archaeological specification.

5.18 English Heritage

5.18.1 English Heritage do not wish to comment on this application which should be determined in accordance with national and local policy guidance, and on the basis of your specialist conservation advice.

5.19 Thames Water

5.19.1 It is not recommended to assume that the sewerage undertaker has accounted for the proposed increase in the foul water flows due to a development, it should be verified in all cases. Based on the occupancy details supplied and a gravity connection to the public sewer system, Thames Water believes that the net change in flow from this site will not have an adverse effect on the public sewerage system and no infrastructure upgrades are anticipated. If the developer wishes to connect foul water flows to the public sewer

system via a pumping station, this would need to be agreed with Thames Water as part of a drainage strategy and submitted to the Local Planning Authority in advance of the development commencing.

5.19.2 It is important to note that the proposed construction of the Thames Tideway Tunnel will NOT increase the capacity of the public sewer system.

5.19.3 Conditions and Informatives are recommended in respect of waste, water and piling.

5.20 Environment Agency

5.20.1 Planning permission should be granted only if the recommended conditions relating to flood risk management, ground water protection and contaminated land are imposed.

5.21 Secure by Design

5.21.1 I have met with the applicant to discuss the proposal. I am concerned with the open nature of the Homezone. In my opinion this may need a boundary with access control to protect the vulnerable rear and communal spaces of the residential element.

5.21.2 I would recommend a condition requiring the units to meet Secure by Design accreditation on the completion of the build.

5.22 Lewisham Design Panel

5.22.1 The Panel collectively agreed that since the last review, the amendments were an improvement to the scheme and were welcomed, nevertheless there remain a number of issues which require further development before in our view the project would be entirely acceptable.

5.22 The Panel felt that the presentation material and the 3D physical models in particular were very helpful in aiding their understanding of the options proposed and complemented the design team on the clarity of the presentation. The Panel set out their comments below:

5.23 Scale and Massing and Architectural Strategy

5.24 As expressed at first review, the Panel noted that its principal difficulty in advising on this scheme is that the two adjacent developers Berkeley & Galliard are not working in a coordinated manner. Any proposals to expand the consented scheme should be tested in the context of a masterplan which covers and coordinates both schemes, Marine Wharves East and West, as a singular piece of townscape despite the duality of ownership, and that this should form an integral part of any planning application that may follow.

5.25 The models presented at second review were helpful in that regard, but were noted as indicative at least in part, since the two adjacent sites were still not being fully brought forward in unison.

5.26 As noted at first review, the Panel felt that the prevailing height of the buildings constructed within the Marine Wharf West development of approximately 6/7 storeys appears appropriate and the Panel could not see a case for exceeding that general scale. The Panel remained of the clear opinion that, excluding the consented tower element which exists within the Marine Wharf East scheme only, both Marine Wharves East and West should be the same height, including both parapet and overall scales.

5.27 The Panel members supported the proposal of two extra floors to the tower, noting however that the overall increase is in the order of 4-5m, but subject to further refinement

of the architecture and high quality detailing of the form and facades. Panel members expressed various views but generally supported the approach to increase density and agreed that the height and design approach along Plough Way should follow that of the increase in height of Marine Wharf West, which has been recently submitted for planning for a change in use and revisions to the massing.

5.28 Any increased height along Grove Street needs to reflect the change in character with the closer and narrower low rise buildings that line this street. The distance between buildings on Plough Way was stated at the review as in the order of 21m, and along Grove Street in the order of 18-19m. The buildings along Grove Street are generally lower at two storeys in height. Plough Way is a wider highway and the buildings opposite larger in scale, and the Panel felt that this street therefore can more readily accommodate further increases in height.

5.29 The Panel debated the merits of the two options. Option A is the preferred proposal among the majority of the panel. However Option B could be considered but only if supported by satisfactory daylight/sunlight studies. The Panel were broadly supportive of an additional floor along Plough Way subject to convincing articulation at the top floor.

5.30 The Panel supported the architects’ view that no additional height should be added to the Parkside building, which forms the southern terrace of the development to prevent further overshadowing to the courtyard.

5.31 Elevational Treatment

5.32 The Panel entered into considerable discussion on the merits of the tower height increase and the architectural solutions proposed. Overall, the Panel felt that the emerging elevational articulation of the tower penthouse levels was promising and may well be acceptable subject to appropriate design development.

5.33 The Panel were broadly supportive of the elevational approach being developed for

5.34 Option A. However, in the Panel’s view, a clearer architectural articulation between top, middle and bottom of buildings was needed. The set back metal/slate covered rectilinear mansard facing Grove Street received criticism and the Panel were disappointed that the architecture at this important skyline level was not of a higher order. This the Panel felt, did not help the case for an increase in height along this section of the proposals, but left open the possibility that subject to a greater level of architectural resolution and issues of daylight/sunlight notwithstanding, a high quality new level could be contemplated in this location.

5.35 Daylight, Sunlight & Shadow Cast

5.36 The Panel were clear that any increase in development should be tested through developed daylight/sunlight studies/shadow analysis including dynamic modelling to evaluate the impact of the proposals on the amenity spaces and existing residential properties, and the effect on those contained within the consented schemes.

5.37 Securing Quality Of The Project : Materials + Detail

5.38 The proposals being schematic, materials were not discussed in any substantive detail. The applicants should note that considerable material detail and demonstration of high quality articulation of the design at a detailed level will be required to demonstrate that a high quality development will be delivered.

5.39 At planning application stage the quality of the detailing will need to be demonstrated through large scale drawings 1:20 and 1:5 of key elements of the building and landscape,

podium deck and should be accompanied by material panels and samples, which should be secured as part of any planning approval.

5.40 Amenity Space

5.41 The need to adequately provide for public and private amenity space at the appropriate quantum and location will need to be demonstrated within the revised proposals.

5.42 Parking & Transport

5.43 The applicants will need to demonstrate to the satisfaction of the LPA that the increase in development proposed will be supportable in parking and public transport terms.

5.44 Sustainability

5.45 The scheme will need to satisfy the LPA sustainability policy of a minimum standard of Code 4 for Sustainable Homes and BREEAM Excellent for other uses.

5.46 Conclusion

5.47 As indicated above, the Panel suggested that, subject to high quality design development, the set back penthouse of one or two storeys maximum on the tower form is generally supportable. The Panel were also generally supportive of an additional level being added, laid out across the lower blocks effectively tying together the buildings to form a consistent roof level along Plough Way. The above comments are entirely dependent upon a high quality detailed design coming forward to be accompanied by a convincing highly developed urban and architectural case, 3D physical models, elevational, materiality proposals and plan layouts and adequate daylight/sunlight/shadow impact studies being conducted.

5.48 The Panel would not support any further increase in height to the buildings facing the public open green space to the south or a scheme that left large parts of the amenity space in shadow for much of the day.

5.49 The Panel might support an increase in height to Grove Street subject to satisfactory articulation and satisfactory analysis of daylight/sunlight and shadow cast impact.

5.50 The Panel felt very strongly, as recorded at first review, that the project should be brought forward within a single coordinated masterplan by the two developers covering both Marine Wharves East and West and that the piecemeal approach currently being pursued was not helpful in assessing the overall quality of the project proposals.

5.23 Strategic Housing

5.23.1 A good mix of housing sizes for the affordable provision is proposed but there is a concern that the level of family sized housing overall is rather low (3 + beds – 22% overall and 33% for the affordable).

5.23.2 The percentage of affordable housing is below policy compliance (50%). This should be tested by way of a viability assessment and a review mechanism should be secured.

5.23.3 The tenure split proposed is 55:45 rent to intermediate. The policy requirement is 70:30. However, it is acknowledged that the site is in an area of above average social rented housing which allows for a different mix.

5.23.4 The provision of wheelchair units is acceptable.

5.23.5 Ideally the family units should not have open plan living/dining/kitchens.

5.24 Sustainability Manager

5.24.1 The proposals meet development plan requirements in relation to delivering a minimum of a 40% reduction in CO2 emissions and Code Level 4. The Energy Strategy is accepted but more detail should be provided to demonstrate the future-proof connection to SELCHP.

5.24.2 However the application proposes BREEAM ‘Very Good’ rather than ‘Excellent’ for the non-domestic floorspace which is not acceptable.

5.25 Highways and Transportation

5.25.1 The Transport Assessment and subsequent Addendum sufficiently demonstrates that the proposal will not have a demonstrable impact on the highway network providing sufficient control is maintained during construction through the provision of a Construction Logistics Plan and Construction Environmental Management Plan.

5.25.2 The level of parking is appropriate but should be controlled via a Car Park Management Plan. It will be necessary to secure the following via conditions/s106 to ensure that when operational the development does not have an unacceptable impact on the highway network:-

Provision of cycle parking as proposed

Retention of car parking spaces including disabled spaces for the wheelchair units and commercial uses

Contribution towards a future CPZ

Future residents would not be eligible for parking permits if a CPZ is introduced

Travel plans for the commercial and residential uses

Delivery and servicing plans

Provision of car club facilities

Provision of electric vehicle charging points

5.25.3 In order to mitigate the impact of the development it is necessary to secure s278/s38 improvements to the footways and highways surrounding the site and a financial contribution towards transport and public realm improvements.

5.26 Environmental Health

5.26.1 Pollution Control: In connection with the noise and dust from reviewing the details of the ES and also considering the draft Construction Environmental Management Plan, the main impact with regards noise and dust will be in connection with the demolition and the ground works. Good practice measures to be adopted during the demolition, ground works and piling have been identified in the ES.

5.26.2 The Council will need to condition for a CEMP which will need to include the measures in the ES. Requirements for noise monitoring will need to incorporated within the CEMP.

5.26.3 A Construction Logistics Plan should be secured by condition. As part of this it would be important to clarify the lorry movements to and from the site.

5.26.4 A contribution of £10,000 should be secured towards reporting and reviewing noise measurements and liaison with developers and the community.

5.26.5 Air Quality: An Air Quality statement should be secured by condition.

5.26.6 Land Contamination: Subject to the mitigation measures identified in the ES being incorporated into the CEMP which should include provisions for dealing with potential gas and odour emissions, should they occur during initial enabling works/demolition, there should not be any adverse effects. The standard land contamination condition should be secured.

5.27 Ecologist

5.27.1 The amount and specification of living roofs is acceptable.

6.0 Policy Context

Introduction

6.1 Section 70(2) of the Town and Country Planning Act 1990 (as amended) sets out that in considering and determining applications for planning permission the local planning authority must have regard to:-

(a) the provisions of the development plan, so far as material to the application,(b) any local finance considerations, so far as material to the application, and(c) any other material considerations.

A local finance consideration means:

(a) a grant or other financial assistance that has been, or will or could be, provided to a relevant authority by a Minister of the Crown, or

(b) sums that a relevant authority has received, or will or could receive, in payment of Community Infrastructure Levy (CIL)

6.2 Section 38 (6) of the Planning and Compulsory Purchase Act (2004) makes it clear that any determination under the planning acts must be made in accordance with the development plan unless material considerations indicate otherwise. The development plan for Lewisham comprises the Core Strategy, the Development Management Local Plan, the Site Allocations Local Plan and the Lewisham Town Centre Local Plan, and the London Plan. The NPPF does not change the legal status of the development plan.

National Planning Policy Framework

6.3 The NPPF was published on 27th March 2012 and is a material consideration in the determination of planning applications. It contains at paragraph 14 a ‘presumption in favour of sustainable development’. Annex 1 of the NPPF provides guidance on implementation of the NPPF. In summary this states that (paragraph 211), policies in the development plan should not be considered out of date just because they were adopted prior to the publication of the NPPF. At paragraphs 214 and 215 guidance is given on the weight to be given to policies in the development plan. As the NPPF is now more than 12 months old paragraph 215 comes into effect. This states in part that ‘…due weight should be given to relevant policies in existing plans according to their degree of consistency with this framework (the closer the policies in the plan to the policies in the Framework, the greater the weight that may be given)’..

6.4 Officers have reviewed the Core Strategy for consistency with the NPPF and consider there is no issue of significant conflict. As such, full weight can be given to these policies in the decision making process in accordance with paragraphs 211, and 215 of the NPPF.

Other National Guidance

6.5 The other relevant national guidance is:

By Design: Urban Design in the Planning System - Towards Better Practice (CABE/DETR 2000)Planning and Access for Disabled People: A Good Practice Guide (ODPM, March 2003)Safer Places: The Planning System and Crime Prevention (ODPM, April 2004)Guidance on Tall Buildings (English Heritage/CABE, July 2007)Code for Sustainable Homes Technical Guide (DCLG/BRE, November 2010)

London Plan (March 2015)

6.6 On the 10th March 2015 the London Plan (consolidated with alterations sine 2011) was adopted. The policies relevant t this application are:

Policy 1.1 Delivering the strategic vision and objectives for LondonPolicy 2.1 London in its global, European and United Kingdom contextPolicy 2.2 London and the wider metropolitan areaPolicy 2.3 Growth areas and coordination corridorsPolicy 2.9 Inner LondonPolicy 2.13 Opportunity areas and intensification areasPolicy 2.14 Areas for regenerationPolicy 2.18 Green infrastructure: the network of open and green spacesPolicy 3.1 Ensuring equal life chances for allPolicy 3.2 Improving health and addressing health inequalitiesPolicy 3.3 Increasing housing supplyPolicy 3.4 Optimising housing potentialPolicy 3.5 Quality and design of housing developmentsPolicy 3.6 Children and young people’s play and informal recreation facilitiesPolicy 3.7 Large residential developmentsPolicy 3.8 Housing choicePolicy 3.9 Mixed and balanced communitiesPolicy 3.10 Definition of affordable housingPolicy 3.11 Affordable housing targetsPolicy 3.12 Negotiating affordable housing on individual private residential and mixed use schemesPolicy 3.13 Affordable housing thresholdsPolicy 3.16 Protection and enhancement of social infrastructurePolicy 3.17 Health and social care facilitiesPolicy 3.18 Education facilitiesPolicy 3.19 Sports facilitiesPolicy 4.1 Developing London’s economyPolicy 4.2 OfficesPolicy 4.3 Mixed use development and officesPolicy 4.4 Managing industrial land and premisesPolicy 4.7 Retail and town centre developmentPolicy 4.8 Supporting a successful and diverse retail sectorPolicy 4.9 Small shopsPolicy 4.10 New and emerging economic sectorsPolicy 4.11 Encouraging a connected economyPolicy 4.12 Improving opportunities for allPolicy 5.1 Climate change mitigation

Policy 5.2 Minimising carbon dioxide emissionsPolicy 5.3 Sustainable design and constructionPolicy 5.5 Decentralised energy networksPolicy 5.6 Decentralised energy in development proposalsPolicy 5.7 Renewable energyPolicy 5.8 Innovative energy technologiesPolicy 5.9 Overheating and cooling Policy 5.10 Urban greeningPolicy 5.11 Green roofs and development site environsPolicy 5.12 Flood risk managementPolicy 5.13 Sustainable drainagePolicy 5.14 Water quality and wastewater InfrastructurePolicy 5.15 Water use and suppliesPolicy 5.16 Waste self-sufficiencyPolicy 5.18 Construction, excavation and demolition wastePolicy 5.19 Hazardous wastePolicy 5.20 AggregatesPolicy 5.21 Contaminated landPolicy 6.1 Strategic approachPolicy 6.2 Providing public transport capacity and safeguarding land for transportPolicy 6.3 Assessing effects of development on transport capacityPolicy 6.4 Enhancing London’s transport connectivityPolicy 6.7 Better streets and surface transportPolicy 6.9 CyclingPolicy 6.10 WalkingPolicy 6.11 Smoothing traffic flow and tackling congestionPolicy 6.12 Road network capacityPolicy 6.13 ParkingPolicy 7.1 Building London’s neighbourhoods and communitiesPolicy 7.2 An inclusive environmentPolicy 7.3 Designing out crimePolicy 7.4 Local characterPolicy 7.5 Public realmPolicy 7.6 ArchitecturePolicy 7.7 Location and design of tall and large buildingsPolicy 7.8 Heritage assets and archaeologyPolicy 7.14 Improving air qualityPolicy 7.15 Reducing noise and enhancing soundscapesPolicy 7.18 Protecting local open space and addressing local deficiencyPolicy 7.19 Biodiversity and access to naturePolicy 7.24 Blue Ribbon NetworkPolicy 7.26 Increasing the use of the Blue Ribbon Network for freight transportPolicy 8.2 Planning obligationsPolicy 8.3 Community infrastructure levy

London Plan Supplementary Planning Guidance (SPG)

6.7 The London Plan SPG’s relevant to this application are:

Accessible London: Achieving an Inclusive Environment (2004)Sustainable Design and Construction (2006)Planning for Equality and Diversity in London (2007)Shaping Neighbourhoods: Play and Informal Recreation (2012)Housing (2012)

London Plan Best Practice Guidance

6.8 The London Plan Best Practice Guidance’s relevant to this application are:

Development Plan Policies for Biodiversity (2005)Control of dust and emissions from construction and demolition (2006) Wheelchair Accessible Housing (2007)Health Issues in Planning (2007)Managing the Night Time Economy (2007) London Housing Design Guide (Interim Edition, 2010)

Core Strategy

6.9 The Core Strategy was adopted by the Council at its meeting on 29 June 2011. The Core Strategy, together with the Site Allocations, the London Plan and the saved policies of the Unitary Development Plan, is the borough's statutory development plan. The following lists the relevant strategic objectives, spatial policies and cross cutting policies from the Lewisham Core Strategy as they relate to this application:

Spatial Policy 1 Lewisham Spatial StrategySpatial Policy 2 Regeneration and Growth AreasCore Strategy Policy 1 Housing provision, mix and affordabilityCore Strategy Policy 4 Mixed Use Employment LocationsCore Strategy Policy 6 Retail hierarchy and location of retail developmentCore Strategy Policy 7 Climate change and adapting to the effectsCore Strategy Policy 8 Sustainable design and construction and energy efficiencyCore Strategy Policy 9 Improving local air qualityCore Strategy Policy 10 Managing and reducing the risk of floodingCore Strategy Policy 12 Open space and environmental assetsCore Strategy Policy 13 Addressing Lewisham’s waste management requirementsCore Strategy Policy 14 Sustainable movement and transportCore Strategy Policy 15 High quality design for LewishamCore Strategy Policy 17 The protected vistas, the London panorama and local views, landmarks and panoramasCore Strategy Policy 18 The location and design of tall buildingsCore Strategy Policy 20 Delivering educational achievements, healthcare provision and promoting healthy lifestyles Core Strategy Policy 21 Planning obligationsStrategic Site Allocation 1 Requirements for strategic site allocationsStrategic Site Allocation 5 Plough Way

Development Management Local Plan

6.10 The Development Management Local Plan was adopted by the Council at its meeting on the 26th November 2014. The Development Management Local Plan together with the Site Allocations, the Lewisham Town Centre Local Plan, the Core Strategy and the London Plan is the borough’s statutory development plan. The following lists the relevant strategic objectives, spatial policies and cross cutting policies from the Development Management Local Plan as they relate to this application:

6.11 The following policies are considered to be relevant to this application.

DM Policy 1 Presumption in favour of sustainable developmentDM Policy 2 Prevention of loss of existing housingDM Policy 3 Conversion of a single dwelling to two or more dwellingsDM Policy 4 Conversions of office space and other B Use Class space into flatsDM Policy 7 Affordable rented housing

DM Policy 10 Local Employment Locations (LEL)DM Policy 13 Location of main town centre usesDM Policy 14 District centres shopping frontagesDM Policy 19 Shopfronts, signs and hoardingsDM Policy 20 Public housesDM Policy 21 Mini cab and taxi officesDM Policy 22 Sustainable design and constructionDM Policy 23 Air qualityDM Policy 24 Biodiversity, living roofs and artificial playing pitchesDM Policy 25 Landscaping and treesDM Policy 26 Noise and vibrationDM Policy 27 LightingDM Policy 28 Contaminated landDM Policy 29 Car parkingDM Policy 30 Urban design and local characterDM Policy 31 Alterations/extensions to existing buildingsDM Policy 32 Housing design, layout and space standardsDM Policy 33 Development on infill sites, backland sites, back gardens and

amenity areasDM Policy 34 Thames Policy Area and Deptford CreeksideDM Policy 35 Public realm

Residential Standards Supplementary Planning Document (August 2006)

6.12 This document sets out guidance and standards relating to design, sustainable development, renewable energy, flood risk, sustainable drainage, dwelling mix, density, layout, neighbour amenity, the amenities of the future occupants of developments, safety and security, refuse, affordable housing, self containment, noise and room positioning, room and dwelling sizes, storage, recycling facilities and bin storage, noise insulation, parking, cycle parking and storage, gardens and amenity space, landscaping, play space, Lifetime Homes and accessibility, and materials. This document has been largely superseded by the Mayors Housing SPG 2012.

Planning Obligations Supplementary Planning Document (February 2015)

6.13 This document sets out guidance and standards relating to the provision of affordable housing within the Borough and provides detailed guidance on the likely type and quantum of financial obligations necessary to mitigate the impacts of different types of development.

7.0 Planning Considerations

7.1 The main issues to be considered in respect of this application are:

a) Environmental Impact b) Land Use: Commercial Floorspacec) Proposed Residential Development e) Urban Design and Landscaping f) Open Spaceg) Highwaysh) Sustainability and Energyi) Ecology

j) Neighbouring Amenityk) Planning ObligationsL) Viability and Deliverability

7.2 Environmental Impact

7.2.1 The application subject of this report falls within Schedule 2, Category 10b (urban development project) of the EIA Regulations. Consequently it has been determined that the submission of an Environmental Statement is a necessary requirement for the full and proper consideration of the environmental impact of the proposed development (as amended).

7.2.2 The Council cannot grant planning permission for any development which is required to be subject to EIA unless it has first taken the environmental information into consideration. The environmental information means the original ES, the ES Addendum, any representations made by any consultation bodies and any representations made by any other person about the environmental effects of the proposed development. The ES and subsequently submitted ES Addendum is considered below and responses to consultations and other representations are also considered elsewhere in this report.

7.2.3 The Council appointed consultants Hyder Consulting to advise it on EIA issues and to help Officers scrutinise technical material prepared by the applicant.

Scoping

7.2.4 A formal Scoping Opinion was issued pursuant to Regulation 13 in September 2014.

7.2.5 At the scoping stage it was agreed that delivering redevelopment of this site could have significant adverse effects in respect of air quality, archaeology and cultural heritage, the water environment, ground contamination, noise and vibration, townscape and visual impacts, daylight and sunlight and the wind environment.

7.2.6 With the introduction of appreciably taller buildings within the site than those immediately surrounding the site to the north, east and west, it was clear that changes to the local microclimate (via changes to patterns of wind, and changes to the very local availability of daylight and sunlight) could also occur. The construction of foundations in previously contaminated soil could also affect the quality of the water environment.

7.2.7 All of these factors, together with consideration of changes to flood risk and effects on local patterns of transport, were identified at the EIA scoping stage as requiring assessment.

7.2.8 The Council were particularly considered about the cumulative impact of construction traffic taking into account the proposal on this site and other proposed and committed schemes in this locality. At the Scoping stage it was determined that the traffic impact could be addressed as part of Transport Assessment sitting outside of the ES but that the content of the TA must be reflected consistently in relevant chapters of the ES.

7.2.9 Ecology, sustainability and climate change, waste and socio-economics were scoped out of the ES as these areas could be addressed as stand alone technical reports forming part of the planning application.

7.2.10 The additional information submitted was of such a minor nature it was not considered necessary to re-advertise the application.

Environmental Impact Assessment

7.2.11 Overall the ES and subsequent Addendum is considered to be appropriate and correct. The Councils consultant (Hyder Consulting) has confirmed that greater clarity or additional information would not change the overall conclusions of the ES and therefore the document is fit for purpose and can be used to properly assess the environmental impact of the development.

7.2.12 The ES has addressed all of the topics that would be expected to be considered when undertaking an EIA of the type of development proposed and adequately assesses the likely significant effects. All sections include information on mitigation measures where appropriate. The one topic where the ES could helpfully have provided greater clarity in its presentation is daylight/sunlight, however the effects can still be properly considered in this respect.

7.2.13 The ES comprises the following documents:

Non-technical Summary – Volume 1 Main Environmental Statement Report – Volume 2 Townscape and Visual Impact Assessment – Volume 3 Technical Appendices – Volume 4

7.2.14 The main report contains the following chapters: Introduction Assessment Methodology Alternatives Considered Proposed Development Planning Policy Context Demolition and Construction Management Air Quality Archaeology and Cultural Heritage Daylight and Sunlight Ground Conditions and Contamination Noise and Vibration The Water Environment The Wind Environment Cumulative Effects Summary and Conclusions

7.2.15 In line with statutory requirements the ES provides a description of the main alternatives to the proposed development considered by the applicant. These include a ‘do-nothing’ scenario, alternative sites, alternative land uses and various design alternatives.

7.2.16 The rationale for continuing with the proposed development is set out in Section 03 of the Technical Summary.

Development Programme, Demolition and Construction

7.2.17 The ES states that a detailed demolition and construction programme has not yet been prepared but it is estimated that the development would be built over two years including demolition, other enabling works and construction. It is anticipated that development would commence in the summer of 2015 and would therefore be complete by end of 2017.

7.2.18 In order to manage the potential environmental effects typically associated with demolition and construction, a site specific Construction and Environmental Management Plan (CEMP) would be developed and implemented throughout the duration of the works. This would specify a range of measures to manage the environmental effects that could

arise and would provide details of controls for dust, noise and vibration, waste management, dealing with hazardous materials and archaeological resources.

7.2.19 The CEMP would include details of construction logistics and site waste management.

7.2.20 It is considered that the environmental effects of demolition and construction can be adequately addressed through a CEMP and controlled working hours for construction. This would be controlled by condition.

Air Quality

7.2.21 The ES states that an air quality assessment has been undertaken to assess the likely effects of development (construction and operational) on local air quality.

7.2.22 The ES states that existing conditions within the study area show acceptable air quality at monitoring locations close to the development site, with concentrations below the air quality objectives. Further from the site, near to busier roads there are a number of monitoring locations where air quality is poor and monitoring shows exceedences of the annual mean nitrogen dioxide objective. This site lies within an Air Quality Management Area.

7.2.23 The ES considers that the main effect during demolition and construction on local air quality relates to dust which would be most likely to be generated from demolition activities and enabling works. It is stated that there would be a maximum of 50 traffic vehicle movements at the site each day but only 25 of these (vehicles leaving the site) could contribute to issues with dust. It is stated that a range of best practice environmental controls would be implemented to minimise dust emissions thereby reducing the potential for nuisance. These measures would form part of the CEMP. However, even with mitigation in place to minimise effects it is difficult to completely eliminate such effects. Consequently with mitigation in place the overall effect of dust upon nearby receptors is considered to be minor during construction. However, these effects would be temporary and would depend on the type of work being undertaken.

7.2.24 The ES states that the effects of vehicle emissions during operation would be insignificant.

7.2.25 The impacts of the proposed CHP and boiler plant on existing and future residents would need to be fully assessed. This can be controlled by condition.

7.2.26 The cumulative impacts of traffic emissions, CHP and boiler equipment would need to be modelled taking into account neighbouring existing and committed developments. This can be controlled by condition.

7.2.27 It is considered that the air quality effects have been properly assessed. The ES considers the potential effects of dust from construction, and emissions from traffic and heating plant. The site itself lies within an Air Quality Management Area (AQMA), but air quality conditions on Plough Way are better than those on major roads in the area. Nevertheless, substantial protection from construction dust would be provided to existing residents through a site-specific CEMP, which would include provisions for dust monitoring and reporting, as well as procedures for dealing with any complaints.

7.2.28 The proposal includes an energy centre on the ground floor of Building A which would accommodate the CHP. The proposed roof level flue would allow the emissions to be discharged at a high level, achieving good dispersion over a wide area. However, full modelling of the air quality impact of the CHP and associated boiler plant would be controlled by condition.

7.2.29 The ES does not consider that any air quality effects would be significant. This is considered to be an appropriate assumption subject to the aforementioned conditions to control the development in detail.

Archaeology and Cultural Heritage

7.2.30 The ES states that the potential effect of the development on archaeological remains and built heritage resources within the site and in the immediate surrounding area was assessed.

7.2.31 The site is within an Archaeological Priority Area and as such there is potential for buried evidence of interest. The ES states that the potential for archaeological remains on the site is low and any remains found would be of local interest only. It is suggested that a further assessment could be controlled by condition.

7.2.32 Greater London Archaeological Advisory Service has advised that the archaeological potential is likely to be ‘low’ but the ES has not fully considered the potential for cultural material to be associated with the upper and lower horizon of peat that has been recorded on site. It is considered that the archaeological interest on the site could be safeguarded through a condition attached to the planning permission.

7.2.33 A condition is therefore recommended to require a two-stage process of archaeological investigation comprising: first, evaluation to clarify the nature and extent of surviving remains, followed, if necessary, by a mitigation strategy.

7.2.34 Subject to the recommended condition being complied with the impact upon archaeological and cultural heritage has been adequately addressed.

7.2.35 The proposal would not affect any conservation areas or listed buildings.

Sunlight, Daylight and Overshadowing

7.2.36 The ES acknowledges that changes in the massing, layout and height of buildings on this site could result in changes to the daylight and sunlight availability to buildings surrounding the site and could cause overshadowing of open space within the site. The ES includes an assessment of the likely effect of the development on the amount of daylight and sunlight experienced by residential buildings close to the site (Nos. 155-191 Plough Way, 1-16 Hockett Close, 282-296 Grove Street, 91 Carteret Way and the committed Marine Wharf West scheme) and also the residential accommodation proposed within the development itself. The assessment also considered whether the new buildings would overshadow amenity spaces within and around the development.

7.2.37 Three dimensional computer modelling of the site and surrounding area was used to charcaterise baseline conditions. The computer modelling was based upon a site inspection, photographs and survey drawings. The assessment has been based upon BRE guidelines and only includes residential properties which surround the site as commercial properties do not need to be assessed.

7.2.38 The ES states that there would be no specific construction related effects on sunlight, daylight or overshadowing. As construction work proceeds the level of daylight and sunlight received by adjacent properties would decrease, while the effect of overshadowing would increase as the development progresses to completion, as would be expected.

7.2.39 The ES states that owing to the site currently consisting of a low rise office building, the urban nature of the surroundings and the scale of the development, there would be some unavoidable but limited, negligible and minor adverse effects on the amount of daylight and sunlight experienced at some of the surrounding residential properties. As per the

BRE guidance, the resultant daylight and sunlight levels would still be consistent with other urban developments.

7.2.40 The ES concludes that the level of permanent overshadowing within the proposed amenity space in Building A would be within the level assessed as being acceptable by the BRE guidance.

7.2.41 It is considered that the ES has properly assessed the effects of the development on daylight, sunlight and overshadowing for the purposes of EIA. The way in which the information is presented could have been clearer but nevertheless the impact of the development in this respect can be fully considered.

7.2.42 For the purposes of EIA the assessment is acceptable. A full discussion of the impact of the development on neighbouring properties is set out in relevant sections below.

Ground Conditions and Contamination

7.2.43 The ES states that a ground conditions and contamination assessment was undertaken. The assessment was based on a range of information sources including a desk based investigation together with a site walkover which enabled the preparation of a Preliminary Site Conceptual Model.

7.2.44 The ES states that there is potential for contamination to be present on parts of the site owing to historical activities. At present the majority of the site is covered with buildings and hard standing. As such any contamination beneath the site would be largely contained and presents a low risk to present site users.

7.2.45 Demolition and construction work would be subject to a range of mandatory legislative health and safety controls. This would prevent construction workers coming into direct contact with ground and sub-surface soils. Such controls would form part of the CEMP, which would also include protective and preventative measures to ensure that contamination risks to underlying soils, ground water and nearby surface water resources would be reduced to a negligible level.

7.2.46 Intrusive environmental ground investigation prior to construction of the development would be undertaken. The results of the site investigation would be used to determine more definitively the presence, location and concentration of soil and/or groundwater contamination. The results should be used to determine the precise source of remediation work in addition to appropriate disposal of waste.

7.2.47 The ES concludes that on completion of the development, the risk posed to contamination to future occupants would be negligible owing to the remediation works that would be undertaken as part of the planned work for the scheme.

7.2.48 It is considered that the ground conditions and contamination effects have been properly assessed at this stage. The submission of a further, intrusive land contamination assessment would be controlled by condition.

Noise and Vibration

7.2.49 The ES states that an assessment of the potential noise and vibration effects of the development was undertaken. The noise survey shows that road traffic is the main source of noise in this location so noise levels reduce in the evening when there is a reduction in traffic.

7.2.50 The ES considers the most sensitive existing receptors to be the residential properties to the north, south and east as well as future residents of the new development to the west and the application site.

7.2.51 Demolition and construction activities would inevitably give rise to some noise and vibration effects to the receptors closest to the site. However, steps would be taken to minimise any noise and vibration through the CEMP, this would include careful selections of modern and quiet plant and machinery, set working hours, traffic management measures and monitoring of noise and vibration levels.

7.2.52 A contribution towards noise monitoring equipment during construction would be secured in the s106 agreement.

7.2.53 The ES concludes that given the existing noise sources surrounding the site, an appropriate choice of materials and building design would mean that residents would be unlikely to be affected by noise pollution.

7.2.54 The ES concludes that the development would generate a negligible amount of additional road traffic noise off-site owing to the low levels of traffic generated by the development. Appropriate design would ensure that the residential accommodation within the development would not be adversely affected by noise from servicing, building plant or noise from commercial use.

7.2.55 It is considered that the noise and vibration effects have been properly assessed. As with air quality (see above) considerable protection from the effects of early site works (including demolition and earthworks) would be afforded to nearby residents through the existence and operation of a site-specific CEMP, which should include provisions for noise and vibration monitoring and reporting, as well as procedures for dealing with any complaints.

7.2.56 Noise levels associated with building services and plant can be controlled by condition, as can delivery and operation times for the commercial units.

Townscape and Visual Impact

7.2.57 The ES states that short term townscape and visual effects arising during demolition and construction are likely to be moderate, the short term effects are of a temporary nature only and are inevitable with any similar form of redevelopment.

7.2.58 The ES states the significance of long term townscape and visual effects ranges from negligible to moderate and, where they are noticeable, the effects are generally beneficial as the proposed development integrates well into the built environment.

7.2.59 A range of rendered and wireframe views have been provided to show the impact of the development in the townscape. Views to be submitted were agreed with LBL Officers and cover views from the surrounding residential streets, a specified location on the north of the River Thames and the protected viewing corridors. Although this site does not lie within a protected viewing corridor it was considered necessary to show the impact of the proposal in the wider setting from the Greenwich and Blackheath viewpoints.

7.2.60 It is considered that the townscape and visual effects have been properly assessed.

The Water Environment and Flood Risk

7.2.61 The application site is raised above Plough Way sitting at a level of 4.68 – 6.62m AOD which is just above flood defence level. The site lies within Defended Flood Zone 3, which is classified as land that is unlikely to flood except in extreme conditions due to the presence of the flood defences.

7.2.62 The existing site is predominantly impermeable (87%) and is served by an exiting surface and foul water drainage system which discharges to the public sewer system in Plough Way.

7.2.63 The ES states that the likely effects of the development on surface water, drainage and flood risk have been assessed.

7.2.64 A Flood Risk Assessment was undertaken that assessed the risk of rapid inundation of the site by flood water as a consequence of overtopping or breach of the River Thames flood defences.

7.2.65 The development has been designed is as not to include any sleeping accommodation below 6.020m AOD with no self contained dwellings lower than 5.73m AOD. The courtyard within Block A is above the flood defence level and direct access to this courtyard can be provided for all residential units below the flood defence level. In the event of a flood adequate means of escape can be provided from within the units and car parking areas of Block A. The car park within Block B is sited below flood defence level but in the event of a flood a self contained escape to the podium can be provided via the stair case in the northeast corner of the block.

7.2.66 An automatic system will be installed within the car parks that prevent car removal in the event of a flood. A flood level sensor will trigger the lowering (or raising) of an automated barrier.

7.2.67 The building will be designed and constructed with flood resilient measures (concrete and brick floors and walls sealed with a waterproof finish, service entries to be sealed, gas boilers located above first floor, external drains and vent stacks to be fitted with non return valves, electrical wiring concealed with plastic coatings).

7.2.68 The ES states that the CEMP would set out measures to ensure that surface water pollution would be prevented as far as practically possible during demolition and construction, for example oil interceptors would be used in trafficked areas and there would be no discharge to ground via infiltration.

7.2.69 The inclusion of biodiverse roofs, permeable surfaces and storage tanks would ensure that surface water drainage would be restricted in line with Environment Agency guidance and would not affect the capacity of the existing sewers. In addition water efficient fixtures and fittings would be installed within the development and rainwater harvesting would be used to irrigate living roofs and soft landscaped areas.

7.2.70 The ES concludes that the effect of the proposed development on water demand, surface water, drainage and flood risk would be negligible.

7.2.71 It is considered that the effects of the development on water resources and flood risk have been properly assessed. The Environment Agency and Thames Water have raised no objection to the proposal subject to recommended conditions.

7.2.72 Conditions would be attached to control ensure full compliance with the Flood Risk Assessment and to control drainage which should include SUDs, surface water and to ensure that residential units meet Level 4 Code for Sustainable Homes which would help to reduce water consumption.

Wind

7.2.73 The ES states that the potential effects of the development on local wind conditions were assessed with regard to pedestrian comfort and safety. The assessment used 3 dimensional modelling for the development which was subjected to simulated prevailing

wind and weather conditions of the site in a wind tunnel. The assessment included the committed scheme at Marine Wharf West.

7.2.74 Based on the assessment of potential impacts, pedestrian level wind conditions would be safe.

7.2.75 It is considered that the wind effects have been properly assessed.

Cumulative Effects

7.2.76 The ES states that two types of cumulative effects were assessed in relation to the development:

The combination of individual effects arising from the development, for example the combination of noise, dust and visual effects; and

The effects resulting from the development in combination with other development projects in the surrounding area.

7.2.77 The ES States that during demolition and construction works of the development there could be some temporary combined effects, predominantly associated with townscape and visual effects, dust, noise and vibration and traffic. The CEMP would provide the mechanism by which temporary demolition and construction effects on surrounding receptors would be minimised.

7.2.78 The cumulative effects of the development in conjunction with the construction of a number of other reasonable foreseeable schemes, were generally found to be acceptable. The ‘cumulative schemes’ considered were agreed with Lewisham Officers and London Borough of Southwark.

7.2.79 The ES states that adverse effects could arise in terms of demolition and construction waste, noise and air emissions from construction traffic, and noise and dust from additional demolition and construction activities in the vicinity of the cumulative scheme sites. However it is assumed that the other cumulative schemes considered within the assessment would also be subject of site specific CEMP, which would serve to minimise any such adverse cumulative effects.

Conclusion

7.2.80 In conclusion the Environmental Assessment complies with the EIA Regulations (2011) and it is not considered that the proposed development would cause unacceptable harm that cannot be sufficiently mitigated. Given the assumptions built into the ES, conditions should be imposed to secure the stated mitigation measures.

7.3 Land Use

Commercial Floorspace

7.3.1 The planning system plays a fundamental role in securing economic growth. At national level, the NPPF requires Local Planning Authorities to set out a clear economic vision and strategy for their area which positively and proactively encourages sustainable economic growth. The planning system should support existing business sectors, taking account of whether they are expanding or contracting and, where possible, identify and plan for new or emerging sectors. Policies should be flexible enough to accommodate needs not anticipated in the plan and to allow a rapid response to changes in economic circumstances. Local Planning Authorities should identify priority areas for economic regeneration, infrastructure provision and environmental enhancement.

7.3.2 Core Strategy (Spatial Policy 2) sets out a vision for the Borough up to 2026 and seeks to focus new development within the Regeneration and Growth areas of Deptford New Cross, Lewisham and Catford. The Deptford and New Cross area (Evelyn and New Cross wards and part of Telegraph Hill Ward, north of New Cross Road) is expected to accommodate up to 2,300 additional new homes by 2016 and a further additional 8,325 new homes by 2026, and an increase in population of around 24,600 together with significant amounts of new business and other employment generating floorspace over this period.

7.3.3 Core Strategy Policy 4 sets out the objectives for Mixed Use Employment Locations which are existing industrial sites identified for redevelopment for mixed-use purposes. The Core Strategy notes that collectively redevelopment of Mixed Use Employment Locations will provide major regeneration benefits by making the best use of available land, attracting further investment, by providing a sense of place, by addressing severance issues and by increasing connectivity by visual and physical links.

7.3.4 Within the Regeneration and Growth areas Strategic Site Allocation 1 identifies ‘strategic sites’ that are of such a scale and significance that individually and collectively they are considered central to the achievement of the Lewisham Spatial Strategy and will act as catalysts for regeneration. Four strategic sites have been identified in the Deptford and New Cross area: Convoys Wharf, Surrey Canal Triangle, Oxestalls Road and Plough Way (Marine Wharf and Cannon Wharf). Development is due to be focused on these sites plus other proposed Mixed Use Locations (Grinstead Road, Arklow Road and Kent and Sun Wharf) and other sites (including Creekside Village East, Giffin Street masterplan area, New Cross Station sites and the New Cross Gate NDC Centre).

7.3.5 Redevelopment of the strategic sites can deliver a comprehensive range of regeneration outcomes in the borough's most deprived areas focused on the provision of housing, jobs, accessibility improvements (public transport, pedestrian and cycle), public realm improvements and infrastructure provision (physical, social and green) that collectively can transform the physical environment and achieve place-making objectives. A key consideration when releasing designated industrial locations for mixed use development was the ability for enabling residential development to facilitate the provision of high quality commercial uses that would generate employment opportunities in the borough.

7.3.6 Strategic Site Allocation 5 relates specifically to the Plough Way Strategic Site of which Marine Wharf East forms a part. This site is identified as a major regeneration opportunity, with comprehensive redevelopment providing for a mix of uses and improvements to the environmental quality of the site and the surrounding area, as well as improvements to accessibility, connectivity and legibility between the Pepys estate and the River Thames. The policy sets out both land use objectives and urban design principles to guide redevelopment of the site. Criterion 1 requires at least 20% of the built floorspace to be provided for a mix of business space (B1(c), B2, B8) as appropriate to the site and criterion 2a requires flexibility in the design to accommodate a range of business uses.

7.3.7 DM Policy 9 of the Development Management Local Plan further reinforces the requirement to provide 20% B Use commercial floorspace on mixed used sites. The policy also requires internal fit-out of commercial units to an appropriate level to ensure the deliverability and long term sustainability of the employment uses.

7.3.8 In line with the policy designation and objectives for this site the principle of a mixed use development is considered to be acceptable. There is however, a need to demonstrate that the amount and type of commercial floorspace to be provided as part of the scheme is appropriate and that the development can be delivered in a way which will offer genuine employment opportunities.

7.3.9 The two largest sites within the Plough Way Site Allocation (Cannon and Marine Wharf West) have planning permission for mixed use development which includes the provision of commercial floorspace. The planning permissions allow for a range of commercial uses falling within A and B Use Classes. The overall provision on both sites falls below the 20% policy requirement for B Use floorspace. Planning permissions were approved as ‘exceptions’ to the policy requirement on the grounds of a robust case being made for lower than 20% business floorspace.

7.3.10 The majority of the commercial uses are concentrated towards the northern sections of the Marine Wharf West and Cannon Wharf sites to create a commercial hub around the Linear Park. When the Yeoman Street sites come forward it is an aspiration of the Council (and a policy requirement) that they would also contribute to the commercial hub. It is considered that the long term success of any commercial uses in this area is dependant upon a cluster effect whereby businesses will support one another, people will undertake combined trips and collectively the sites will create a critical mass of commercial uses which will help this area to develop an identity as a genuine mixed use location. The existing Cannon Wharf business centre has a significant role to play as an anchor for commercial uses. Due to its size and established position within this area it is considered that other commercial uses would benefit from being positioned in close proximity. With this in mind it is considered necessary and appropriate for the Marine Wharf East development to include the provision of commercial uses along the Plough Way frontage as an extension to the uses already approved as part of the Marine Wharf West and Cannon schemes.

7.3.11 This application was accompanied by an Updated Economic Regeneration Statement. The statement seeks to identify current market trends both globally and within London and refers to local employment data by way of reference to the Lewisham Employment Land Study (2008) and Economic Development Business Plan (2004). Investigation into planned and available commercial units in the area has also been undertaken. The report concludes that provision of approximately 10% commercial floorspace is appropriate having regard to demand and viability in the current market.

7.3.12 It is suggested that there is little demand for B Uses in this location and therefore a range of commercial uses should be allowed for within the planning permission. The applicant is seeking permission for flexible spaces to be provided as part of the scheme which include retail, café, financial and professional services, business uses and assembly and leisure. It is hoped that a flexible range of uses would make the development attractive to commercial occupiers. If a range of complimentary uses are offered there is more chance of the commercial space being occupied from an early date and business being sustained in difficult market conditions.

7.3.13 The applicant estimated that from the original scheme that the range of uses applied for and number of dwellings could potentially generate 40-65 full time jobs. The additional 42 dwellings could support a further 3-4 construction jobs, additional household expenditure of £500,000 which would support a further 5 jobs.

7.3.14 Whilst the amount of commercial floorspace proposed falls below the 20% required by adopted planning policies and the flexible ranges of uses proposed does not comply with the policy requirement for B1, B2 and B8 Uses, it is considered that a reasonable and pragmatic approach must be taken when assessing the appropriate amount and type of commercial use that could be supported as part of the development. In current market conditions Officers accept that it could be difficult to justify the provision of 20% employment floorspace. It is not desirable to secure an arbitrary amount of commercial floorspace to meet policy requirements unless there can be some comfort that the floorspace would be occupied and would make a valuable contribution to the Borough both in terms of place making and job creation. Officers accept that vacant commercial units offer no economic benefit to an area and can have a significant adverse

impact in terms of placemaking. Consequently it is considered reasonable for the applicant to demonstrate that a lower provision of commercial floorspace is appropriate providing the space offered is deliverable and sustainable in the long term. This was accepted on the previously granted application and circumstances remain unchanged in this case.

7.3.15 In this instance the applicant has sought to include a range of uses which they believe will thrive in this location, complementing the increase in residential units on this site as well as the existing non residential uses in the area and commercial uses coming forward on the adjacent schemes. They have also sought to respond to issues raised as part of their pre application consultation where interest was expressed in the provision of café and gym uses on the site. It is considered important to recognise that whilst the development would not meet the 20% B Use policy requirement, it would contribute to employment in the Borough by generating the potential for 40-65 full time jobs. In current conditions, any employment opportunities generated will make a valuable contribution to the Borough.

7.3.16 The applicant has been in discussions with a local boxing charity regarding their potential interest in occupying the larger unit (478.57 sqm) as a gym (D2) but as this is not secured the unit has been designed so that it could be subdivided into smaller B1 units as a fallback position. If this unit were to be occupied by a local boxing charity or other form of gym this could make a valuable contribution to the Borough both in employment terms and in providing a leisure facility for this area. An occupier of this nature would be welcome in this location.

7.3.17 However, if this type of occupier cannot be secured in the future it is considered that as the largest unit, located immediately adjacent to what would be an employment (B Use) within the adjacent Berkeley’s development and in fairly close proximity to the Cannon Wharf business centre, this unit should be secured for B1 uses rather than A1, A2 or A3. With a flexible approach to design which allows subdivision of the space into smaller units and a tangible package of measures to make the units attractive to small businesses falling within a B1 Use Class, it is considered that this unit could be genuinely attractive to small and medium sized businesses that would benefit from being located close to other similar occupiers within the Cannon Wharf business centre. Consequently conditions are recommend to secure the largest unit for D2 or B1 uses only and the remaining units for a flexible range of uses across A1/A2/A3 and D2 Use Classes.

7.3.18 On balance Officers consider that a robust case has been made in respect of the amount of commercial floorspace to be delivered. In current market conditions it is accepted that it could be difficult to attract occupiers for a larger provision of commercial floorspace which would be located internally within the site or on the upper floors. Whilst the need and benefit of a critical mass with other surrounding sites is clear, in current market conditions a point could be reached whereby there are too many commercial spaces within the immediate area competing with one another, which could have an adverse impact on those units located internally or on upper floors. By the time this site is redeveloped a significant amount of commercial floorspace will already be provided within the Marine Wharf West and Cannon Wharf schemes which would make this site more difficult to occupy unless there is a significant increase in demand and improvement in market conditions. At this point in time Officers are convinced that the appropriate provision has been put forward.

7.3.19 The amount and location of the proposed ground floor commercial units along Plough Way is logical as it will provide a natural extension of the commercial uses on adjacent sites so could benefit from the cluster effect. In addition the proposed units will have a presence on what will be a popular and busy route for surrounding residents travelling on the 199 bus or to Surrey Quays which will help to make the units attractive for future occupiers.

7.3.20 Whilst Officers accept that the amount and location of the commercial uses proposed is appropriate and consider the flexible range of uses to be acceptable, it is considered necessary to secure a package of measures to ensure that the units are attractive in the market so that they are more likely to be occupied at an early stage of the development coming forward and are successful in the long term.

7.3.21 It is understood that one of the biggest barriers to small businesses being able to occupy new premises is affordability of the units that come forward, the start up costs associated with fitting out beyond shell and core and lack of flexibility with leases. In order to address this issue and to ensure that the reduced amount of commercial floorspace to be delivered as part of this mixed used development offers genuine employment opportunities, it is considered appropriate to secure a range of tangible measures within the s106 agreement that would make the commercial units affordable for small businesses.

7.3.22 Measures to make the commercial units attractive in the market were secured as part of the previous application and the applicant has confirmed that the same measures can be secured by s106 for this scheme. These are detailed below:

Shell and Core fit out (including an appropriate glazing solution) for the commercial units within each building before occupation of any residential unit within the building;

Once an occupier is known for each unit full fit out of the unit to meet the occupiers requirements, undertaken by the Developer at their cost (a minimum level of fit-out and appropriate sum agreed in the s106)

Flexible tenancy arrangements An agreed marketing strategy A period of 6 months rent free for the first occupier of each unit A period of 12 months free from service charges

7.3.23 The above measures would enable a small business to take over the unit without significant start up costs which can be prohibitive and would facilitate a bedding in period. Such benefits could be crucial for a small café operator, independent small retailer, small scale office use or business falling within a B Use Class. As the range of uses would make a valuable contribution to employment in the Borough it is considered that all types of commercial use should benefit from the measures not just businesses falling within a B Use Class.

7.3.24 In addition to the above a contribution of £103,054.55 would be paid to the Council towards employment and training initiatives in the Borough. The s106 would also include an obligation to use local labour during construction and operation.

7.3.25 The applicant has agreed to a clause preventing the submission of an application to change the use of the commercial units to residential for a period of 3 years as well as a clause to prevent the permitted change of use of any B1 space to C3 residential in the event that permitted development rights are extended. These measures are considered reasonable and necessary to ensure that the reduced amount of commercial floorspace is retained unless it is genuinely not viable.

7.3.26 The mitigation measures set out above are considered to be necessary to make the development acceptable and fairly and reasonably related to the scale of the development proposed. On balance, subject to the tangible measures secured as part of the s106 it is considered that the amount and type of commercial floorspace to be provided should be approved as an exception to Core Strategy Policy 4 and Strategic Site Allocation 5.

Retail

7.3.27 The NPPF and development plan policies require applications for main town centre uses that are not in a centre and not in accordance with an up to date development plan be assessed against a number of criteria. The NPPF states that comprehensive assessments will only generally be needed if a scheme is over 2,500 square metres or above a locally set threshold. The threshold set within the Development Management Local Plan is 1000 square metres. However, the policy recognises that assessments can be required for proposals falling below the threshold, particularly when taken together with other committed sites.

7.3.28 Core Strategy Policy 6 sets out the retail hierarchy and location of retail development across the borough and policy Strategic Site Allocation 5 notes that development of the Plough Way site will provide retail (A1, A2) uses to serve local needs where they do not adversely impact on existing town centres. London Plan Policy 4.7 states that boroughs should firmly resist inappropriate out of centre development and DM Policy 13 sets out a sequential test applicable to substantial retail development (over 1,000 sqm), confirming that such development, in the first instance, should be located in major and district centres.

7.3.29 The site is in fairly close proximity to Evelyn Street local parade and a smaller parade on Grove Street, with the nearest town centre at Deptford further to south east (Surrey Quays is a large retail centre within walking distance of the site but is located within Southwark Borough boundary). Given the proximity of the Strategic Sites to each other it is also relevant to consider the potential cumulative impact of the proposed retail floorspace across these sites. It is important to ensure that the proposals together do not provide a level of retail floorspace which could potentially harm Deptford Town Centre. Whilst the level of floorspace to be provided on this site falls significantly below the threshold for a Retail Impact Assessment it is considered that the cumulative impact must be considered as part of this application.

7.3.30 Of the 1045 sqm of commercial floorspace proposed as part of the redevelopment the plans indicate that 566 sqm (Units 2, 3 and 4) could be used for A1/A2/A3 purposes. It is not intended that all of the units would be occupied for retail (A1) , indeed it is stated within the Addendum to the Economic Regeneration Statement that only 350 sqm of retail would be provided on this site at one time. Consequently the applicants assessment of the impact of the retail use has been based on a maximum provision of 350 sqm of A1 use. Consequently it is considered reasonable to restrict the amount of the A1 use that can occupy the site at any time to accord with the parameters of the applicants assessment.

7.3.31 Based on 350 sqm of A1 retail being provided on this site together with 1,407 sqm of A1, A2 or A3 space provided on the Marine Wharf site and 2,208 sqm of A1, A2, A3 or A5 space on the Cannon Wharf site there is a need to consider the impact of a total provision of 3,965 sqm of retail use across the Plough Way Strategic Site on existing retail centres.

7.3.32 It is important to note that the Cannon Wharf approval restricts A1 retail floorspace to a maximum of 300sqm so the remaining floorspace would be occupied for other A uses.

7.3.33 The applicant has not submitted a full Retail Impact Assessment but has considered the cumulative impact of retail across the Plough Way Strategic Site as part of their Economic Regeneration Statement. The assessment looks at the proportion of trade that would be drawn to the entire Strategic Site from existing centres/facilities for comparison and convenience shopping. The report suggests that the scale of retail facilities to be provided across the Strategic Site is small relative to the existing large retail centres in Lewisham. Factors such as low level of local demand, accessibility and a significant retail provision at existing centres limits the size of retail facilities in this location. The report concludes that the cumulative impact of retail across Marine Wharf West, Cannon

and Marine Wharf East would equate to approximately 2.0% of the turnover from existing centres and Marine Wharf East would only contribute towards approximately 0.18% of this.

7.3.34 It is anticipated that the retail provision on this site will result in a small amount of trade diversion from Cannon and Marine Wharf West but this will not be significant.

7.3.35 The applicant’s assessment suggests that the impact of the proposed retail provision on this site (based on a maximum of 350 sqm) would not have a significant impact on existing retail provision in the Borough.

7.3.36 When considering the applications for Marine Wharf West and Cannon Wharf the Council determined that the existing retail provision in this area was not likely on its own to be sufficient to meet the needs of the new residential accommodation and employment uses coming forward on the Plough Way Strategic Site. In the circumstances it was considered that the provision of a limited amount of retail space on these sites would be unlikely to adversely affect the existing centres. However this is dependent on a) restricting the maximum amount of floorspace in each use class, b) restricting the amount of convenience floorspace and the maximum size of a convenience unit, and c) restricting the maximum size of units where appropriate. Cannon Wharf and Marine Wharf West are significantly larger sites than Marine Wharf East and consequently will deliver a much larger number of residential units and retail floorspace. Conditions have been attached to the permissions for the aforementioned sites to control the amount type and individual unit size for retail so that the cumulative impact is limited.

7.3.37 For this site it is only proposed to provide a total of 566sqm of floorspace that could accommodate A1, A2 or A3 use. The applicant has stated that only 350 sqm would be used for A1. This is a minor increase in retail provision across the Strategic site as whole which would be unlikely to have any significant effect upon existing retail facilities. Therefore subject to a condition to limit A1 provision to a maximum of 350 sqm across the site the proposed level of retail is considered to be acceptable.

7.4 Housing

7.4.1 At national level, the NPPF states that housing applications should be considered in the context of the presumption in favour of sustainable development. At regional level, the 2011 London Plan seeks mixed and balanced communities (Policy 3.9). Communities should be mixed and balanced by tenure and household income, supported by effective and attractive design, adequate infrastructure and an enhanced environment. Policy 3.3 (with 2013 alterations) establishes a housing target for the Borough of 13,847 newt additional dwellings for the plan period 2015-2025. Policies 3.11 and 3.12 of the plan confirm that Boroughs should maximise affordable housing provision. Though the Plan does not set percentage targets for provision at Borough Level, it sets a strategic target of 13,200 more affordable homes per year across London as a whole and confirms that Boroughs should set their own targets according to the Strategy of the London Plan. The policy also refers to a strong and diverse intermediate sector, where 60% of provision should be for social housing (comprising social and affordable rent) and 40% should be for intermediate provision and priority should be accorded to the provision of affordable family housing.

7.4.2 Spatial Policy 2 of the 2011 Core Strategy requires that the Deptford, Deptford Creekside, New Cross/New Cross Gate area accommodates up to 2,300 additional new homes by 2016 and a further additional 8,325 new homes by 2026. Core Strategy Policy 1 confirms that the maximum level of affordable housing would be sought by the Council, with a strategic target of 50%, as a starting point for negotiations and subject to an assessment of viability. The policy also seeks provision at 70% social rented and 30% intermediate housing and family housing (three+ bedrooms) in development of more than 10 units.

Where existing areas have a high concentration of social rented housing, different proportions of affordable housing could be sought. Different proportions are supported by the Lewisham Housing Market Assessment 2007-8 (HMA), published in December 2009 which states (paragraph 37) that affordable housing provision in Lewisham should comprise 85% social rented housing, and 15% intermediate housing, in order to meet the identified need.

7.4.3 The HMA states (at paragraph 35) that a net 6,777 dwellings should be provided over the current 5-year period to meet current identified need. This is equivalent to the provision of 1,345 dwellings per annum. Table 3.1 of the London Plan sets out a target of 13,847 additional homes to be built in Lewisham in the 10 years from 2015-2025, which is reflected in a monitoring target of 1,385 additional homes per year, which is an increase from the previous annual target of 1,105 dwellings in the 2011 London Plan. As part of the overall need for housing in Lewisham, there is a specific need for affordable housing. The HMA states (paragraph 36) that over 80% of all new housing built would need to be affordable in order to meet identified need. Core Strategy Policy 1 indicates that where a site falls within an area which has existing high concentrations of social rented housing, the Council would be prepared to consider an affordable housing contribution to be provided in a way which assists in securing a more balanced social mix. This may include a higher percentage of intermediate housing or other arrangements as considered appropriate.

a) Size and Tenure of Residential Accommodation

7.4.4 The proposed development would provide 225 residential units including 40 affordable units (18 intermediate and 22 affordable rent) The unit sizes and tenure breakdown of the proposed development are summarised in the table below.

Table [1]: Residential Tenure and Size Mix*

1 Bed 2 Bed 3 Bed 4 Bed + Total

Private 94 62 (11) 29 (5) 0 185 (16)

Social Rent 0 0 0 0

Affordable Rent

2 (1) 8 (3) 8 4 22 (4)

Intermediate 6 (2) 9 3 0 18 (2)

Total 102 (3) 79 (14) 40 (5) 4 (0) 225 (22)

*Wheelchair accessible units shown in ( )

7.4.5 The extant permission for 183 residential units included 20 affordable (11%). This new proposal with an additional 42 residential units includes a further 14 affordable dwellings (34 overall or 15% affordable dwellings). Following negotiations with the applicant the number of affordable dwellings on site has been increased to 40, which represents a total affordable provision of 17.7% (or 21.3% by habitable room). These additional units are secured as affordable rent and are 1 and 2 bedroom units which meet local housing need. The mix is broadly similar to that previously consented and provides a good mixture of housing sizes and tenure.

7.4.6 The percentage of affordable housing to be provided falls short of the affordable housing figure referred to in Core Strategy Policy 1 and the extent to which it meets the strategic target of 13,200 units per year across London in Policy 3.11 of the London Plan is limited.

7.4.7 The Applicant has submitted a confidential financial appraisal for the scheme that has enabled the Council, advised by specialist consultants, to assess the overall viability of the scheme and its ability, in financial terms, to meet policy in terms of affordable housing provision. Further consideration of financial viability is set out in section 9 of this report. However, in summary, the financial appraisal demonstrates that when taken with other policy requirements and the package of measures proposed to make the commercial units attractive and affordable, the proposed development provides the maximum viable amount of affordable housing at this time.

7.4.8 It is also important to consider the sizeable package of s106 obligations secured which includes a contributions towards employment, transport and public realm enhancements, as well as contributions for Education, Health, Leisure and Open space collected by CIL. Such mitigation has an impact on the viability of the scheme.

7.4.9 While it is accepted by Officers that the provision of a larger proportion of affordable housing is not possible at this time, given the shortfall in affordable housing provision relative to the levels set out in planning policies, it is appropriate that the level of provision be kept under review. To this end review mechanisms would be incorporated as part of the Section 106 to consider securing a financial contribution towards affordable housing provision off-site, should values increase to a level where this would be financially viable.

7.4.10 It is also relevant to note that the provision of the 40 affordable units does not meet the 70% social rented / 30% intermediate split for housing set out in Core Strategy and the 60/40% split in London Plan Policy 3.11. The development proposes an affordable split of 53:47 (affordable rent/intermediate). However, this site is located in an area of above average social rented housing and includes a good ratio of family sized dwellings within the affordable tenure and is broadly consistent with the 55:45 split approved previously. The Councils Strategic Housing Team are satisfied with the tenure split.

7.4.11 The affordable rented properties will be capped at 60% of market value.

7.4.12 The affordable units would be spread amongst both buildings with no discernable difference between the tenures.

7.4.13 For the reasons set out previously and in more detail in paragraphs 9, the proposals have been shown to include the maximum amount of affordable housing viable in a particular tenure and it is therefore recommended that this tenure mix is accepted.

7.4.14 The proposed size mix includes 45 family sized units (3 + bed) which equates to 20% overall but 37.5% within the affordable tenure. Although the family sized units fall below the policy provision of 42% for affordable and larger units are low in the private tenure, issues of affordability affect choice for larger private units and cuts to the amount of housing benefit that can be claimed means that there is pressure for smaller units in affordable tenure at the present time with 2 bed units being in highest demand. On balance the mix is considered to be acceptable overall and remains in line with that previously approved.

b) Standard of Residential Accommodation

7.4.12 The Council’s adopted Residential Standards SPD (2006) sets out criteria for new residential units but this document is largely superseded by Core Strategy and London Plan requirements and the recently adopted Mayor’s Housing SPG. The Housing SPG sets out guidance to supplement London Plan policies. Part 2 of the Housing SPG deals with the quality of residential accommodation setting out baseline and good practice standards for dwelling size, room layouts and circulation space, storage facilities, floor to ceiling heights, outlook, daylight and sunlight, external amenity space (including cycle storage facilities) as well as core and access arrangements. Given the status of the

Lewisham SPD ,Officers rely on the baseline and good practice standards within the Mayor’s SPG as minimum requirements.

7.4.15 Table 3.3 of the London Plan and Standard 4.1.1 of the SPG sets out minimum space standards for new development. The standards require the largest 1-bed to be a minimum 50 sqm, largest 2-bed, 70 sqm, and largest 3-bed, 95 sqm. All of the units comfortably meet the minimum room sizes.

7.4.16 The daylight/sunlight chapter of the ES included an assessment of the levels that would be achieved in the new dwellings. The assessment was based on the ground floor rooms as they would represent the worse case scenario. The assessment shows that new units would achieve a good level of natural daylight/sunlight.

7.4.17 A large percentage (60%) of the units are dual aspect including all of the family sized units and none of the single aspect units are north facing. All habitable rooms receive good levels of natural light, ventilation and outlook.

7.4.18 The layout of the development is such that habitable rooms are provided with an adequate level of privacy and units have been stacked so as to reduce noise pollution. There are no more than 7 units per floor accessed from each core and two wheelchair compliant lifts provided for each core. Duplex units are provided either so that they are accessed directly from the street with their own front doors and gardens, or on the upper levels of the central tower.

7.4.19 Standard 4.10.1 of the Housing SPG sets out the baseline requirements for private open space. The standard requires a minimum of 5sqm to be provided for 1-2 person dwellings and an extra 1sqm for each additional occupant. The minimum depth for all external space is 1500mm. All units within this development would have private amenity space in the form of balconies which meet the aforementioned standard. In addition all units have access to the communal landscaped courtyards.

7.4.20 All units benefit from cycle, refuse and recycling storage facilities that are secure, covered and well located in relation to the dwelling and follow a strategy which was considered acceptable with the previous permission.

7.4.21 As well as private amenity space and facilities the site provides a good amount of communal space and the there are a range of public open space facilities within walking distance of the site.

7.4.22 It is recognised that the communal podium courtyard in Block A would be overshadowed by the proposed buildings. The design of the building has tried to reduce the level of overshadowing as much as possible. However, due to the quantum of development required to make the scheme viable and represent a sustainable form of development that would meet policy objectives and the need for urban design reasons to locate the tallest element on the eastern side of the block, it is not possible to reduce the level of overshadowing any further. However, the amenity space would meet BRE minimum guidelines by receiving more than 2 hours of sunlight on 21st March.

7.4.23 It is recognised that some of the proposed residential units would be located in close proximity to commercial uses on the ground floor of the development as well as commercial uses within the adjacent Marine Wharf West sites. Given the mixed use location future occupiers should anticipate commercial activity taking place and a certain level of noise associated with the commercial uses must be accepted. Nevertheless, measures would be taken to ensure that the buildings are appropriately soundproofed and noise and vibration from plant and equipment kept to within acceptable limitations. Delivery and operation hours would also be restricted to 8:00 – 23:00. Appropriate ventilation would be provided for any A3 Use and a condition would be attached to

prevent any A3 use operating a take away facility. The range of commercial uses would not include A4, A5, B2 or D1 Uses which can be unsuitable in residential locations.

7.4.24 The Council’s Environmental Health Officer has raised no objection to the proposal subject to recommended conditions to control the level of noise within the units, the noise from external plant and transmitted noise.

7.4.25 Overall future occupiers of both the private and affordable units would benefit from high quality accommodation with a good standard of amenity.

7.4.26 London Plan Policy 3.8 and Core Strategy Policy 1 require all new homes to be built to Joseph Rowntree Foundation's Lifetime Homes Standards and 10% of all dwellings to be wheelchair accessible. The Councils Planning Obligations SPD specifically refers to the SELHP wheelchair accessibility standard.

7.4.27 The practical application of the Lifetime Homes Standard is to apply the criteria where relevant as many sites would not lend themselves to all of the criteria and some flexibility in their application is required. The accommodation schedule confirms that all residential units have been designed to Lifetime Homes standards, where the 16 criteria of the standard are applicable. In this case, criteria 1a (on plot car parking) is not applicable to any of the units and save for the duplex units criteria 9 (potential for entrance level bedspace), 12a (potential for stair lift installation) and 12b (potential for through the floor lift) would not apply.

7.4.28 The applicant has submitted 1:50 scale plans for all unit types to show compliance with lifetime home standards. It is clear from the application submission that the general approach to Lifetime Homes is acceptable and a condition is capable of inclusion on a planning permission to ensure the standard is met as far as practically possible.

7.4.29 In accordance with policy requirements the development would include 20 units (10%) as wheelchair accessible/adaptable in full compliance with SELHP 2012 standards. 2 of the units would be provided within the affordable accommodation, the remaining 20 units would be private dwellings, which follows the split previously approved. Plans have been submitted to demonstrate full compliance with SELHP standards. A disabled car parking space has also been identified for each unit. The provision of the units (including marketing details for the private units) would be secured through the s106 agreement.

Design

7.5 Urban design is a key consideration in the planning process. The NPPF makes it clear that national government places great importance on the design of the built environment. 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 states that it is important to plan positively for the achievement of high quality and inclusive design for all development, including individual buildings, public and private spaces and wider area development schemes.

7.5.1 The NPPF requires Local Planning Authorities to undertake a design critique of planning proposals to ensure that developments would function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development. Proposals must establish a strong sense of place, using streetscapes and buildings to create attractive and comfortable places to live, work and visit; optimise the potential of the site to accommodate development, create and sustain an appropriate mix of uses and support local facilities and transport networks. Developments are required to respond to local character and history, and reflect the identity of local surroundings and materials, while not preventing or discouraging appropriate innovation. New development must create safe and accessible environments where crime and disorder, and the fear of crime,

do not undermine quality of life or community cohesion; and are visually attractive as a result of good architecture and appropriate landscaping.

7.5.2 Access to high quality open space and public realm is an important urban design consideration that plays a fundamental role in enhancing the health and well being of communities.

7.5.3 London Plan and Core Strategy design policies further reinforce the principles of the NPPF setting out a clear rationale for high quality urban design. The 2014 approved scheme went through an extensive pre-application process which included several design workshops and discussion at the Lewisham Design Review Panel to embed quality into the scheme. This new application further develops the design from the 2014 permission and has similarly been discussed through an extensive pre-application process which included further design workshops and discussion at the DRP to ensure that the revised massing was of the highest quality. Through this process the Applicants Design Team have addressed many of the original concerns stemming from the original scheme and thus the application is largely viewed favourably in both urban design and architectural terms.

7.5.4 The layout, massing, height, scale and architectural appearance of the proposal has been described in section 4 of this report.

7.5.5 The Councils Design Team are now largely satisfied with the proposal subject to detailed elements being secured by the conditions recommended in this report.

Layout

7.5.6 The general approach to the site layout is appreciated and remains unchanged from the previous application. The separation of the site into two halves to allow the creation of an open, un-gated pedestrian and vehicular route through the centre of the site significantly enhances permeability within this area. This route should remain as a public benefit and thus site accessibility should be enshrined in the planning permission and secured by way of a Public Access Management Plan via the s106 agreement.

7.5.7 The proposed buildings would be set back into the site boundary so that the adjacent footways in Plough Way and Grove Street can be widened. The set back would reflect that agreed for the adjacent Marine Wharf West development. This would enable a more attractive and safe footpath for pedestrians. Improvements to the pavements, lighting and tree planting would significantly enhance the setting of this development, would ensure a good level of visual amenity for future occupiers and would enhance public realm in this location.

7.5.8 The duplex units fronting Grove Street would be provided with private accesses and front gardens. The private space would be delineated through the erection of a combination of low level brick walls and soft planting for the front boundary and brick built external refuse stores.

7.5.9 The location of the new buildings is understood in regards to desired routes and makes the best use of this site. The provision of commercial units fronting Plough Way is a logical approach, these units will contribute to the cluster of commercial spaces being developed as part of the Marine Wharf West and Cannon Wharf schemes and will provide active street frontage which is important in place making terms.

7.5.10 Block A has been designed so that the south elevation fronts onto the existing area of open space located within Hockett Close. At the present time this area of land is underused and not greatly overlooked. Many of the properties in Hockett Close that front onto the space have erected high boundary treatment to provide a level of privacy and

security to the front gardens. This has resulted in this area becoming rather desolate and poorly maintained with some instances of anti social behaviour. This application presents an opportunity to significantly enhance the public realm by providing a high level of natural surveillance and activity adjacent to this space and through a financial contribution towards open space improvements which could be used to enhance the area.

7.5.11 There would be no boundary treatment between the southern wing of Block A and the adjacent public open space. A footpath would be provided along this boundary to provide access from Grove Street to the ground floor units in the southern wing. In order to provide an appropriate level of privacy to residential occupiers fronting onto Hockett Close open space the proposal includes some defensible space which would be soft landscaped.

7.5.12 The homezone route is wide enough to accommodate vehicles including refuse trucks as well as on street parking. It is not intended that this shared surface would act as a busy vehicular route as it offers no benefit as a short cut/rat run. Indeed the southern access point would only allow one way access in a northerly direction but it would enhance permeability. The homezone has been designed and landscaped incorporating traffic calming measures such as build outs, delineations in materials and specially located planting / trees and kinks in the road. These will ensure cars will travel through the road slowly and carefully. it is also used to soften the appearance of this street and to provide defensible space to the dwellings.

7.5.13 A strategic east-west route is proposed which would link the home zone/ public open space with Marine Wharf West and onto towards the Linear Park in the west. This link would reflect the intentions of the Surrey Wharves masterplan and since the granting of the original scheme, where this route was aspirational, rather than secured, the developer is now working with Berkeley homes in a coordinated manner which would allow the link to be facilitated. Berkeley Homes have confirmed this by the submission of an amendment to their s106 agreement which would allow this link to be facilitated.

7.5.14 Access cores to the residential blocks are provided on all frontages which will ensure an appropriate level of activity on all public facing elevations and will provide some protection to the communal podium courtyards. Concerns have been raised about the ability to secure the courtyards which are intended for use by the residents but not the general public. A gated solution would not be acceptable so the applicant has sought to delineate the public and private space through the landscaping proposal. Site security is discussed in more detail below.

7.5.15 The amount of parking incorporated in the layout is acceptable from an urban design perspective. However, it is felt to be the most that the site can positively contain. The landscaping of the Homezone route includes measures to prevent ad-hoc on street parking. It will also be necessary for the Developer to implement controlled parking measures to ensure that this route does not become subject to excessive on-street parking. This should be addressed in the Parking Management Plan to be secured as part of the s106 agreement.

7.5.16 Overall the amount and layout of commercial and residential space within the site is considered to be appropriate from a design perspective.

Height and Mass

7.5.17 This site lies in an area of mixed character in terms of height and mass. The surroundings to the north and east (Plough Way and Grove Street) comprise smaller scale residential buildings (2-3 storey’s) but the new developments to the west include larger blocks ranging from 1-8 storeys with two tall buildings (20 and 23 storeys) in the Cannon Wharf development. The Tavern Quay development under construction (within LB Southwark)

reaches up to 9 storeys in height. The Plough Way Strategic Site is allocated as a tall buildings location but this part of the site is identified as being sensitive. Proposals must be considered in the context of the immediate surroundings.

7.5.18 It is considered that this site could accommodate buildings of a larger scale than those to the north and east but not significantly taller buildings. In the context of the strategic site as a whole it is considered appropriate that buildings step up in height towards the western edge of the strategic site.

7.5.19 The revised proposals at Block K, Marine Wharf West amended a consented (not constructed) four storey office block facing Plough Way to a part 6/ 7 storey mixed use residential building. This was approved in March 2015. The amendment to the height, although with between 2-3 additional storeys of accommodation, due to the difference in office and residential floor to ceiling heights the overall increase in height amounts to 5.24m. The revised massing proposals for Block B facing Plough Way would tie in with that of the lower element of Block K and represents an increase in height of 3m above the existing approval measuring a maximum of 20.2m compared to 17.2m. This increase extends in height along the Plough Way frontage of A to wrap the corner of Grove Street.

7.5.20 There is no height increase along Grove Street or the public open space, however, the previously recessed top floors are now finished flush with the main elevations. It is considered that the massing is acceptable and that the detailing of the parapet provides some visual interest.

7.5.21 The tallest element of the scheme, as per the 2014 permission remains at the centre of the site. This has been reconfigured from an 8 storey to a 10 storey block. The increase in height measures 5.2m (less than the equivalent conventional two storeys) as the upper levels are duplex residential units with no additional life overrun and due in part to the high parapet of the original design. So, similarly to that with the revisions at Block K, Marine Wharf West although there is an increased in the number of storeys, the physical increase in height is considered to be modest. The two upper levels of the central tower are recessed from the facades providing a slender appearance and acceptable mass.

7.5.22 It is considered that as per the consented scheme that there is an appropriate hierarchy of buildings through the site. Through the use of varying heights and set backs together with the recessed elements along the facades, the massing of the blocks has enough variation to ensure that the development will be visually interesting. In short range views the buildings will not appear overly dominant in the streetscene and in long range views the buildings will not appear bulky or incongruous. Following presentations at the Lewisham Design Review Panel, the applicant has provided high quality visuals of the buildings to support the scheme and these are considered to provide a realistic impression of the final buildings appearance.

7.5.23 It is considered that the new buildings would make a positive contribution to the townscape, both within the immediate surrounding streets and in longer views. On balance the height, scale and massing is considered to be acceptable taking into account the context of the site surroundings, emerging context and the design quality demonstrated in the proposal.

Architecture

7.5.24 It is considered that through the extensive design discussions, developing further the approved scheme, a high level of architectural quality has been achieved for the proposal.

7.5.25 The applicant has demonstrated their commitment to providing a high quality design by including detailed sections, CGI modelling, elevations and potential materials as part of the application to show how the proposal would be executed.

7.5.26 The Design and Access Statement (page 46), includes a high level of detail and identifies the following materials to be used throughout the development:-

One brick type to be used on all buildings with a darker mortar proposed for the ground floor level to articulate the facades (Normandy Grey or similar);

Engineered brick for the plinth on all buildings (Staffordshire Blue or similar) Powder coated aluminium frame windows set in horizontal window reveals (RAL

7039); Pre-fabricated aluminium box for planting to match the window frames; Powder coated aluminium fascia to balconies (RAL 7039) Metal balustrades to balconies and front gates (RAL 7039) Metal cladding within window frames (RAL 7039) One full brick setback for the windows to add depth to the facades; Re-constituted stone cills; Re-constituted stone copping; Iroko timber cladding to define the residential entrances

7.5.27 The proposed materials are considered to be a robust choice, the materials complement one another and would result in a high quality development. However, the applicant has stated that the exact brick cannot be confirmed at this stage. Consequently a condition is recommended to control the materials palette in detail. Samples of facing materials should be submitted prior to commencement of development. Any samples submitted would need to address the principles approved as set out in the Design and Access Statement thus if the stated bricks are not available a suitable replacement of similar colour and equal or better quality would need to be provided. As part of the Council’s assessment of viability an independent Quantity Surveyor has confirmed that appropriate build costs have been factored into the applicants viability statement and therefore there is no reason to believe that the quality of materials proposed cannot be delivered.

7.5.28 Through a basic but well detailed design and a simplified palette of brick with metal and wood cladding details, but with a more extensive use of glazing than with the approved scheme, the architectural approach is considered to present a good design solution for this location and reflect the quality of that achieved with the completed blocks in Marine Wharf West. The appearance of the blocks would be broken up through regular setbacks along the elevations which together with the generously sized fenestration would give a vertical appearance to the facades. The use of deep reveals (180mm) for fenestration, generous proportions of glazing and window sizes, inset balconies, picture window details on some balconies and use of reglit on the upper floor all help to articulate the elevations and break up what could otherwise be a rather monotonous form of development. The projecting balconies on the southern elevation of Block A would help to articulate this façade as well as providing a form of interaction and natural surveillance for the adjacent public open space. In addition, all balcony and window fixings will be hidden or discreet which will be important in achieving a high quality finish.

7.5.29 The architectural quality of the proposal is most importantly seen in the taller building. Due to its prominence, its appearance is of paramount importance. In particular, for this building the architecture should be used to help break down the scale. The proposed building successfully achieves this through detailing of the top floors and the approach to fenestration. The glazing patter and fenestration arrangement is considered to provide an elegant appearance which would be an improvement of that previously approved.

7.5.30 The submitted plans show how the commercial units could be occupied by a range of uses. Extensive glazing at the ground floor level would provide a good degree of animation to the street. Appropriate provision has been made for sympathetic fascia and

projecting signage so these feature would not appear as a later unsympathetic addition to the buildings. It is not proposed to install any form of security shutters to the commercial premises. Any future provision of such features would require planning permission.

7.5.31 Details of residential signage for the duplex units and communal access cores for the apartments have been provided within the Design and Access Statement. These features have been designed into the scheme at the outset to rationale the amount of ad hoc signage required and reduce visual clutter on the facades.

7.5.32 Overall the proposal is considered to represent a high quality design in architectural terms.

Landscaping, Connectivity and Public Realm

7.5.33 Landscaping is an integral part of the development and is fundamental to ensuring high quality public realm, appropriate to the character of the site and surrounding area. A high level of landscaping detail was secured with the original permission and this would continue to be secured.

7.5.34 Detailed landscaping proposals have been provided for the Homezone and internal courtyard within Block A which includes full planting specifications and a five year maintenance and management plan.

7.5.35 The Homezone has been designed as a shared surface, the vehicular surface would follow a curved route through the site. It is not proposed to delineate the hardscape through any change in levels, soft planting would be used as generous buffers on both edges which would help to keep the speed of vehicular traffic low and would provide good visual amenity. Details of lighting, seating and tree planting have been provided. The northern end of the Homezone allows for two-way traffic, to allow access into the car parking areas whilst the southern end only permits one way traffic in a northerly direction. Road widths have been kept to a minimum giving emphasis to pedestrians but are wide enough to allow access for refuse and emergency vehicles. It is considered that this route as designed would provide a high quality shared surface.

7.5.36 The podium courtyard for Block A is located above the lower level parking but due to the topography of the site the podium slopes down to the south so that it is accessible at grade from the southwest corner. The courtyard has been designed to incorporate a large areas of grass in the centre, raised mounds, seating, a pergola and children’s natural play equipment. It is considered that the inclusion of the raised mounds, seating areas and pergola will add interest and depth to the space. A path is located diagonally through the centre of the grassed area to take account of the natural desire line. The north edge of the podium would be hard landscaped with the addition of planters to add visual interest. A defensible buffer is proposed around the perimeter to protect the privacy of the ground floor units facing into the courtyard. A ramp would be provided in the northern section of the courtyard to ensure it is fully accessible.

7.5.37 The proposed soft planting species are considered to be suitable to provide year round interest and are of appropriate species to flourish in this environment.

7.5.38 Close to the centre of the Block A courtyard is a pergola that surrounds the escape stair providing emergency access to the basement car park. This is considered to be a suitable form of screening for the staircase which is essential to address potential flood risk issues on the site.

7.5.39 The landscaping for the internal courtyard of Block B is rather conceptual at this stage. The plans submitted demonstrate that the podium courtyard can be appropriately landscaped to provide a good level of amenity for future users and an appropriate relationship can be achieved with the adjoining podium in Marine Wharf West. It is not

intended that this would form a communal podium with the neighbouring site and there would be no access between the two sites at this juncture. However, a visual connection can be achieved. The landscaping details are considered to be acceptable subject to a pre commencement condition requiring the submission of a detailed landscaping scheme for this particular podium.

7.5.40 The southern boundary of the site adjacent to the Hockett Close POS would remain open with low level planting. A well lit footpath would be provided within the site boundary which would provide the main access route into the dwellings fronting the POS. This would significantly increase pedestrian activity at this point which would benefit the public realm.

7.5.41 As discussed above it intended to improve connectivity and permeability through the site by opening up the Homezone route which will provide pedestrian and vehicular access from Hockett Close to Plough Way. This route will also facilitate future pedestrian access from the site through Marine Wharf West into the linear park which has been agreed with the developer of that site. This route is considered to be an fundamental part of the design approach. The detailed landscaping proposals for the Homezone have been subject to extensive discussions with Officers and the Design Review Panel. The proposal is now considered to be acceptable as it would provide a high quality, safe and legible route through the site. It is appropriate to secure public access through the site by way of a management plan to be controlled as part of the s106 agreement.

7.5.42 As part of the approach to improving permeability and legibility it is proposed to provide way finding signage to the Thames, pedestrian and cycle routes within the vicinity of the site and other local facilities. The Design and Access Statement identifies 3 locations for the signage together with designs. The provision of this signage should be secured as part of the Public Access Maintenance and Management Plan.

7.5.43 The landscaping proposals for the site have been subject to extensive discussions with the Council’s Landscape Officer and the Design Review Panel. The approach is considered to be acceptable and will be controlled by conditions.

Density

7.5.44 Core Strategy Policy 15 seeks to ensure a high quality of development in Lewisham, including residential schemes and that densities should be those set out in the London Plan. Policy 3.4 in the London Plan 2015 seeks ensure that planning decisions take into account local context and character, the design principles of Chapter 7 (of the London Plan) and public transport capacity to optimise housing output. Table 3.2 (Sustainable residential quality) identifies appropriate residential density ranges related to a site’s setting (assessed in terms of its location, existing building form and massing) and public transport accessibility (PTAL).

7.5.45 This site is considered to be in an ‘urban’ setting and has a PTAL rating of 2 giving an indicative density range of 45-170 dwellings per hectare / 200-450 habitable rooms per hectare (dependent on the unit size mix). The London Plan states that residential density figures should be based on net residential area, which includes internal roads and ancillary open spaces. The approved scheme proposed a density of 210 dwellings per hectare with 587 habitable rooms per hectare. The principle of higher density accommodation has therefore been established.

7.5.46 This application proposes a density of 258 dwellings per hectare or 709 habitable rooms per hectare. This would remain above the indicative density range, however, as with the previous scheme, it is important to note that the accessibility of this site will increase as the surrounding major redevelopments come forward. Furthermore the proposed development represents a high quality proposal which will result in the provision of a mixture of dwellings sizes that all meet the London Plan minimum unit size and many of

the Mayors Housing SPG design guidelines for good quality housing. The proposal is considered to be appropriate in terms of layout, height and mass and therefore the density is accepted in this instance.

Site Security

7.5.47 Secure by Design principles have been considered as part of the design process and the Designing Out Crime Officer has been consulted.

7.5.48 The layout and position of buildings within the site and mix of uses has been designed to maximise activity and natural surveillance within the site as well as introducing surveillance to surrounding areas which are currently not well overlooked (Hockett Close open space). The commercial units along Plough Way have the potential to generate a good level of activity during the day and evening .

7.5.49 The Homezone route would aid legibility and has been designed to ensure that it is visually open, inviting space. Changes in road surface and landscaping would help define defensible space.

7.5.50 All residential areas are designed to be well lit and visible from other areas of the site. Cycle stores have been designed to be secure.

7.5.51 Well integrated lighting and CCTV would be installed throughout the site.

Open Space and Play Facilities

7.6 This site is located within a designated area of local open space deficiency however, there are a number of parks located within the proximity of the site which include a range of facilities. Upper and Lower Pepys and Deptford Park are located within walking distance of the site (500m) both of these parks include play facilities and the linear park that is being delivered as part of the Marine Wharf West development will also include play facilities. Whilst these parks and open spaces are in walking distance of the site it is recognised that pedestrian and cycle routes to these facilities are in need of environmental enhancement to ensure direct, safe, legible and attractive access to the facilities from the site can be achieved. There is also opportunities to enhance some of the play facilities within this area as well as other public open spaces.

7.6.1 As part of the application it is has been recognised that the adjacent are of POS in Hockett Close is in need of significant improvements. This area could provide opportunities for informal recreation but at the present time it is not well maintained, it is poorly landscaped and has inadequate lighting, seating and street furniture. Improvements to this space would significantly enhance the public realm and would provide a good opportunity for amenity for future residents of the application site as well as existing residents in the neighbouring estate.

7.6.2 As part of this application landscaping proposals have been developed to suggest how this area could be improved. The designs have been discussed with Lewisham Homes (as manager of the area). The approach is supported in principle. As this area of open space falls outside of the site boundary but would significantly enhance the amenity enjoyed by future residents overlooking the space and contribute to the provision of safe and well lit access to the ground floor units in the southern block it is considered appropriate to secure a financial contribution towards future enhancement.

7.6.3 Based on the Mayor’s play space SPG, 39 children are predicted to live in the development of which 15 would be under the age of 5. This gives rise to a total child play space requirement of 393 sq.m. of which 196.5 sq.m. should be on-site and designed for under 5s. This application proposes the provision of a total of 1,958 sq.m. of amenity space to be provided within the two courtyards, which have been designed so as to

provide dual-use general residential amenity space, as well as play space, utilising natural features to facilitate play. Given the location of the site and existing and planned facilities for under 5’s in this area the playspace provision is considered to be acceptable.

7.6.4 It is not proposed to provide dedicated facilities for over 5’s on site. Whilst there are facilities within adequate proximity of the site, as discussed above there is a need to enhance facilities and routes to them. There is also a requirement to address the impact of the proposal on other forms of open space. The impact of the development in this respect would be mitigated by virtue of financial contributions towards open space collected via CIL, transport and public realm as set out in the s106 Heads of Terms later in this report.

Highways and Traffic Issues

7.7 The NPPF recognises that transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives. All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. Plans and decisions should take account of whether the opportunities for sustainable transport modes have been taken up depending on the nature and location of the site, safe and suitable access to the site can be achieved for all people. It should be demonstrated that improvements can be undertaken within the transport network that cost effectively limit the significant impacts of the development. The NPPF clearly states that development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.

7.7.1 London Plan and Core Strategy Policies encourage sustainable transport modes whilst recognising the need for operational parking for commercial uses and disabled parking facilities. Car parking standards within the London Plan should be used as a basis for assessment. Priority should be given to enhancing pedestrian and cycle routes and promoting use of sustainable transport modes through a Travel Plan.

Transport Assessment

7.7.2 This planning application is accompanied by a Transport Assessment (TA) to assess the impacts of the Development on the local highway and transport network, including during the construction period as well as the operation of the development.

7.7.3 As originally submitted the TA was not considered to adequately assess the impact of the development. Specifically the trip generation modelling was not sufficient to demonstrate what impact the development would have on vehicle movements to and from the site and impact on the Lower Road junction, the Construction Traffic Management Plan was lacking in detail and there was insufficient discussion as to what the impact on walking and cycling would be and how this could be mitigated.

7.7.4 The original TA outlines the relevant policies at the national, regional and local level and then sets out the baseline conditions for the site, in terms of the local highway network, public transport and the existing usage of the site. The report notes that the site is currently occupied by an office building totalling approximately 4,700 sqm Net Internal Area with approximately 130 on-site parking spaces.

7.7.5 Traffic surveys were undertaken to establish the vehicle movements on Grove Street and Plough Way and those generated by the existing site. The survey of the existing site showed approximately 350 vehicle trips per day. The surveys for Grove Street and Plough Way suggest that both roads are relatively lightly trafficked but Plough way is the more heavily trafficked of the two. On average in the weekday AM peak period Plough Way carried 242 vehicles per hour and in the PM peak period 319 vehicles per hour. The

total vehicle movements along Plough Way reach day range between 2583 and 3132 spread across a 24 hour period.

7.7.6 Existing parking conditions were surveyed. The site and surrounding streets within the Lewisham Borough boundary are not currently within a Controlled Parking Zone. To the west of the site within the Southwark Borough boundary there is a controlled parking zone. The surveys suggest that there is capacity for 245 on-street parking spaces within the vicinity of the site.

7.7.7 Personal injury data was obtained from TfL to asses safety with regards to past reported incidents. The date covered the past 3 years and a 300m radius of the site. The data show 6 collisions, 2 serious and 4 slight injury collisions in the area. This suggests there are no accident clusters, none of the accidents were recorded at the site access or at the Grove Street/Plough Way junction.

7.7.8 The total proposed car parking provision is:-

85 car parking spaces for the residential units (20 of which would be DDA spaces for the wheelchair units);

1 car parking space for the non-residential units 1 car club parking space. 1 in 5 spaces will have active and passive electrical charging points 3 motor cycle spaces will be provided in the car park of Block A, with a further 3 in

Block B.

7.7.9 It is stated that parking would be provided within under croft basements of Blocks A and B with limited parking at street level in the homezone. Parking would be strictly controlled within the development through a Parking Management Plan for both the commercial and residential uses.

7.7.10 It is noted that the development would provide 271 secure, covered cycle parking spaces for the residential uses, and 14 uncovered spaces for visitors to the commercial units and site visitors within the home zone. Staff working within the commercial units are likely to park their bikes within the units for additional security. The cycle parking provision is considered to be acceptable.

7.7.11 Refuse would be stored on the lower ground and ground floors of the development with collections being made on-site via the internal access road.

7.7.12 A detailed Delivery and Servicing plan will be secured via condition so that the Highways Authority can be satisfied that appropriate servicing arrangements are in place once occupiers are known.

7.7.13 Future trips for the development have been predicted using the TRANSYT model. The trips have been compared to existing vehicle movements. The Transport Assessment (as amended) suggests that there would be a reduction in respect of inbound trips and a slight net increase in outbound vehicle trips during the AM peak hour (24% increase in outbound trips), this equate to 34 vehicles. In the PM peak hour there would be a decrease in outbound trips (19%) and a slight increase in inbound trips (1%). Overall when operational the vehicular trip generation would not be significant and would be unlikely to affect the highway network or capacity of nearby junctions.

7.7.14 The impact of construction related trips has also been assessed including cumulative impact with other planned and committed schemes coming forward. The modelling undertaken suggests that the highway network including the Lower Road junction could accommodate the additional capacity.

7.7.15 An assessment of the effects of construction activity on the local road network was included within the Transport Assessment based on the assumption that all materials would be moved by road. It is noted that on average there would be 50 (two-way) construction vehicle trips per day. It is argued that the level of daily and peak construction vehicle movements are less than the existing vehicle trips currently accessing the site. This figure excludes vehicle trips associated with construction workers and staff. It is anticipated that there would be between 250 – 300 construction workers on site but most of these would travel to the site by public transport. A framework Construction Logistics Plan has been submitted but this would be controlled in detail as part of a combined Construction Environmental and Traffic Management Plan.

7.7.16 A Residential Travel Plan has been submitted. The plan sets out various targets to reduce the number of trips to and from the land uses by car and increase trips by sustainable modes such as walking, cycling and public transport. The Framework Travel Plan targets seeks to limit car use to 20% of total trips over the 5 year lifetime of the plan. The first baseline travel survey will take place at 75% occupancy rate and carried out annually for five years after that.

7.7.17 Key measures of the Travel Plan include the appointment of a Site-wide Travel Plan Coordinator, raising awareness of sustainable modes of travel, broadband connections to support working from home, discounted public transport fares (one off pre paid oyster card with £50 credit for the first occupiers of each dwelling or a £50 voucher towards a new bike), two years free car club membership, personalised travel planning on request, promotion of lift share and other web based travel tools. These measures will be promoted to residents using welcome packs, onsite posters and notice boards. The plan will be subject to monitoring and review using TRAVL surveys. The Travel Plan includes an Action Plan as well as details about its on-going funding.

7.7.18 The framework travel plan is considered to be acceptable. The implementation of the travel plan would be controlled by way of a s106 obligation. The detailed travel plan should cover the commercial units. Specifically how the commercial unit would make the most of walking and cycling and how staff could access shower facilities. This has been discussed with the applicant, it is considered that staff within the commercial units could use showers within the gym if it is provided (this could be fed into the lease agreement) or individual showers could be provided within the units subject to occupier requirements.

Access

7.7.19 The site is located within an area of fairly low accessibility according to PTAL Ratings. The only bus route directly serving the site is the 199 bus which is over subscribed. The site is within walking distance of Surrey Quays Station and other bus services can be accessed on Evelyn Street. It is recognised that accessibility in this area will be greatly improved as a result of the large developments coming forward is part of the redevelopment of the strategic sites. Whilst a lower provision of parking and reliance upon sustainable transport modes is supported in principle there is a need for significant enhancements to pedestrian and cycle routes to improve accessibility and ensure that future occupiers can make use of sustainable transport modes.

7.7.20 Lewisham Council has a long standing commitment to improving the pedestrian and cycle networks in the Borough. The North Lewisham Links Strategy 2007, updated in 2012 identifies options for improving pedestrian and cycle routes in the Deptford and New Cross Area and has formed the basis for successful bids for government funding as well as informing the approach taken to improving a number of pedestrian links and enhancement to public spaces in recent years.

7.7.21 The applicant was requested as part of their submission to undertake their own assessment of pedestrian and cycle routes within the vicinity of the site to explore what

enhancements would be required to increase accessibility in the area and provide safe, legible routes to provide access to a range of local amenities and public transport options.

7.7.22 As submitted the application proposed improvements to the footways immediately adjacent to the site boundary, provision of a new vehicular and pedestrian route through the site providing access from Hockett close to Kempthorne Way and installation of way finding signage to identify routes towards the Thames, local facilities and established cycle routes. Whilst these enhancements are positive and would make a valuable contribution to connectivity and permeability they are required to ensure the successful delivery of this development and do not go far enough to mitigate the impact of the development in terms of accessibility, public realm and reliance upon sustainable transport modes.

7.7.23 It is considered that in addition to the measures discussed above there is a need for this development to contribute towards wider pedestrian and cycle enhancements. Given the number of new dwellings proposed on this site and the fact that future occupiers will need to use existing local facilities and public transport options, the development should contribute towards improvements to surroundings pedestrian and cycle routes so that future occupiers have safe, legible and attractive access to local amenities (parks/health facilities/schools/shops etc…) as well as access to other public transport options. Grove Street is likely to be the most heavily used route from the site to local amenities and is in need of improvements, therefore it is considered that enhancements to this route are a priority. This would link in to other planned and committed public realm enhancement projects in the vicinity which form part of the Lewisham Links strategy. In this respect it is considered that a financial contribution of £147,000 is necessary to mitigate the impact of the development.

7.7.24 Two existing points of access to the site on Grove Street and Plough Way will be blocked up and the pavement reinstated. A new vehicular access into the site would be provided from Plough Way and Hockett Close. It is proposed that the Homezone route would operate as two-way on the north end and one way on the southern end. This route is wide enough to accommodate servicing and refuse vehicles.

7.7.25 Delivering this route is reliant upon an area of land within Hockett Close being re-configured. The are of land in question is currently used as parking area for 10 cars. There is no formal layout or spaces marked up. The applicant has submitted plans to show that the area can be re-configured to provide 10 formal spaces in a way which allows vehicular access through the area into the site. This has been discussed with Lewisham Homes (as manager of the estate) and the Councils Strategic Housing Team (as land owner) and is considered to be acceptable in principle. The necessary works must be undertaken by the applicant controlled via a s106 obligation. There would be a need for them to obtain necessary consent and a license from the Council as landowner but there is no reason at this stage to suspect that permission cannot be obtained. However, in the event that the re-configuration or access across Council owned land cannot be achieved the applicant has submitted tracking diagram’s to show that as a fall back position the internal route can operate as two-way cul-de-sac which would allow sufficient access for parking, servicing and pedestrians.

7.7.26 The applicant has confirmed that in respect of access arrangements within the site the development has been designed to accord with the Equality Act 2010, Building Regulations Part M 2004 (as amended), British Standard 5588 Part 8 1990, British Standard 8300 2001, The Disability Discrimination Act 1995 and Accessible London – Achieving an inclusive environment (2004).

7.7.27 As part of the development site levels would be addressed to ensure that level access would be provided externally and at entrances into the buildings. Dwelling entrances along Grove street will be level or via 1:21 gradients. Where living and entrance spaces are required to be raise for adequate flood defence, level access is maintained by

elevated entry porches. All communal accesses will be designed with level thresholds. A ramped access is required into Block A and within the podium of this block to deal with a change in levels across the site.

7.7.28 Level access would be provided into all of the commercial units via ramps in order to meet existing street levels and dependent upon individual fit-out requirements may be designed with ramped internal lobbies with appropriate gradients.

7.7.29 All the communal amenity spaces are accessible by lift, the podium in Block A can also be accessed at grade on the south-western corner.

Servicing

7.7.30 All servicing and delivery activity would be undertaken at ground level with service and delivery vehicles using the site entrance on Plough Way. The swept path analysis submitted with the Transport Assessment clearly demonstrates that arrangements could safely and adequately facilitate access for all types of vehicles anticipated to require entry into the site.

7.7.31 It is proposed to provide a loading bay on Plough Way. An indicative location has been identified but this would be confirmed as part of a Delivery and Servicing Plan (DSP) once confirmed occupiers of the units are known. Servicing and deliveries at the site would be strictly managed and monitored as through a DSP, whose implementation would form part of the overall management of the site. It is noted that a number of the objections received refer to servicing issues associated with the commercial units. However, provided that a condition is secured which requires the submission of DSP prior to any of the commercial uses being brought into use there are no objections raised from a servicing perspective.

7.7.32 Emergency access and escape routes in the event of a fire or flooding have been identified within the Design and Access Statement.

Cycle Parking

7.7.26 Representations from the GLA (Stage 1 response) state that there is a shortfall of 63 cycle spaces required by the London Plan (2015), and that whilst the application was submitted before the adoption of this plan, the cycle parking standards were publicised at the time. The applicant has submitted revised lower ground and upper ground floor plans which seek to provide an additional 77 cycle spaces in order to allow for a policy compliant provision. This has involved the omission of the water tanks and heat exchange in block B, and replacement with cycle storage and the reconfiguration of the cycle store in block A to increase its provision from 25 to 47 spaces. The applicant has confirmed that in working up a detailed design these two rooms in block B are no longer required and that they can be transferred over to cycle storage without detriment to the overall scheme. This is considered acceptable and would address the GLA concerns with regard to cycle parking.

7.7.27 The location of the spaces in relation to the units they would serve accords with current best practice and the cycle parking would be covered and secure. Suitable conditions are recommended to ensure that the cycle parking proposed is provided prior to occupation.

Car Parking

7.7.27 The development proposals include the provision of 85 spaces which equates to 0.38 spaces per residential unit. This is below the maximum permissible standard for this development but reflective of parking level agreed for other sites within the vicinity. For comparison the approved scheme has a parking ratio of 0.4 spaces per unit. The low level of car parking for the residential units is considered to be acceptable subject to

appropriate mitigation for pedestrian and cycle routes as discussed above. In order to ensure that the level of parking remains genuinely low it is necessary for the future occupiers of the residential units to be prevented from applying for parking permits in future Controlled Parking Zones (CPZs), including extensions or adjacent CPZs. Subject to the necessary s106 mitigation measures the level of residential parking is considered to be acceptable.

7.7.28 The majority of the car parking spaces (81) would be provided within the covered parking areas in Blocks A and B. These spaces would be accessed directly off the new Plough Way entrance or via the restricted northbound one-way entrance from Hockett Close. The parking areas would be secured with fob access gates.

7.7.29 A single residential space would be located at the southern end of the homezone, a further 2 spaces would be located at the northern end of the homezone. The spaces at the northern end would be used for the car club and one disabled space for the commercial units.

7.7.30 The level of accessible spaces accords with London Plan standards and SELHP requirement to provide 1 space per wheelchair unit. One additional accessible space would provided for the commercial element. This would be provided at the northern end of the Homezone. The proposed car parking provision for the commercial element of the development is 1 space which considering the amount of commercial floorspace and the location is considered to be acceptable.

7.7.31 3 motorbike parking spaces would provided in the Block A car park, with a further 3 in Block B. 1 in 5 spaces would be provided with electrical charging points. This will be controlled by condition.

Car Club

7.7.33 It is proposed to provide one car club parking space on site for use by residents and commercial tenants as well as the general public. As part of the s106 agreement all residential units (first occupiers only) would receive a period of 2 years free membership and £25 driving credit; whilst each business tenant (first occupiers only) would receive a period of 1 year free access to a business account.

7.7.34 There are already a number of car club spaces operated by ZipCar in close proximity of the site (10 minute walk) and further spaces secured as part of the Marine Wharf and Cannon redevelopments currently coming forward. ZipCar has confirmed that the provision of 1 space as part of this development is appropriate.

Refuse

7.7.35 Refuse storage points are located in specified areas on the lower ground and ground floor levels with separate areas for refuse and recycling. Refuse and recycling would be dropped off by residents in bin stores adjacent to their cores with the exception of the ground floor units along Grove Street. A managed system will collect the refuse at one point within the basement to bring to the collection point at upper ground floor level via a service lift to allow for easy access on refuse collection days. Duplex units on Grove Street are provided with individual refuse stores at the front of their properties to be collected via the roadside.

7.7.36 The internal route has been designed to accommodate a refuse vehicle of 11.2m and therefore adequate collection arrangements could be provided. The location of the waste collection points for both land uses accord with current standards in relation to access by the refuse vehicle and pulling distances by waste operatives. There are no outstanding concerns about the size and location of the waste collection points proposed. The refuse arrangements would be secured through the Delivery and Servicing Plan.

Blue Ribbon Network

7.7.37 Policy 7.26 of the London Plan states that development proposals close to navigable waterways should maximise water transport for bulk materials, particularly during demolition and construction phases. The use of the river and waterway network for transport purposes is supported by Core Strategy Policy 11. Given the sites location in close proximity to the Thames it is considered important to explore the option of transporting construction material and waste from the site via the Thames. This would help to reduce the road borne vehicle trips which would reduce congestion and traffic in the area. The applicant has agreed to explore this option as part of the Construction Logistics Plan for the site. This would be secured by condition.

Construction

7.7.38 The Transport Assessment and Environmental Assessment estimated that there would be some 50 two-way construction vehicle movements per day to the site. In order to mitigate the potential impacts during the construction phase of the development a Constructions Logistics Plan (CLP) would be secured by way of a planning condition, in line with London Plan Policy 6.14 (Freight) as would the provision of a Construction Environmental Management Plan. These plans would control the impact of construction activity on the highway and would also ensure that the construction takes into account the cumulative impact with other development that could be on site at that time, should planning permission be granted.

Highway Improvements

7.7.39 A s278 agreement is required to undertake improvements to the footways of Plough Way and Grove Street adjacent to the site to provide a minimum 4.0m wide footway, as shown on the submitted plans. The works are considered to be a vital part of the high quality environment the development proposals are seeking to create in order to enhance pedestrian accessibility to and from the site. Consequently the s106 should include an obligation to enter into a s278 agreement which should also include an obligation to secure any necessary repair works to the footway and carriageway of Plough Way and Grove Street along the specified construction vehicle routes and in front of the development site in the instance that this is damaged during construction. This is considered necessary to safeguard the pedestrian and cycle environment within the vicinity of the Site.

Conclusion

7.7.40 Based on the trip generation the Transport Assessment predicts a minimal net increase in vehicular trips and concludes that the proposed development would not have a material impact on the surrounding highway and public transport network.

7.7.41 Given the low level of parking, the proposed development does have the potential to generate a need for on-street parking demand in the surrounding area. Plough Way and the surrounding streets are not covered by a Controlled Parking Zone (CPZ) and as such a S106 contribution should be secured for the undertaking of a study into the implementation of a CPZ in the surrounding areas and future occupiers of the development should be restricted from applying for parking permits.

7.7.42 With the controls that are proposed to restrict occupiers’ right to a parking permit, the submission of Commercial and Residential Travel Plans, the low levels of on-site car parking and the implementation of a Delivery and Servicing Plan, it is felt that sufficient controls would be in place, to control the effects of the proposed development.

7.7.43 The transport document submitted have been independently assessed and it is considered that the additional information about traffic impacts provided by the applicant

is sufficient to demonstrate that the level of trips predicted to be generated by the proposed development would not have a significant impact on the surrounding highway and public transport network in terms of capacity and operation and that potential impacts on on-street parking could be mitigated against.

7.7.44 The impact on sustainable transport modes is considered to be acceptable subject to the necessary mitigation set out in the Heads of Terms below.

Impact on Adjoining Properties

7.8 DM Policy 32 of the Development Management Local Plan states that all new residential development should provide a satisfactory level of privacy, outlook and natural lighting for both its future residents and its neighbours. The siting and layout of new-build housing developments, including the housing element of mixed-use developments, will need to respond positively to the site specific constraints and opportunities as well as to the existing and emerging context for the site and surrounding area.

7.8.1 This site has existing residential properties that could be affected by the development to the north (Plough Way), east (Grove Street), south (Hockett Close) and planned residential and commercial uses immediately to the west (Marine Wharf West).

Daylight/Sunlight/Overshadowing

7.8.2 An assessment of daylight and sunlight has been carried out for the development in accordance with the Building Research Establishment’s good practice guide "Site Layout planning for daylight and sunlight”. This allows the Council to consider the impact of the proposal on the extent of daylight/sunlight received in the windows of adjacent properties serving the rooms used most frequently. This is useful in assessing the extent to which the site layout allows for natural lighting but is only one factor in considering whether the scheme is well designed and should be considered in the context of the overall approach to the design of the scheme.

7.8.3 It is also important to note that the BRE guidance includes a level of flexibility within its application and for instance, developments in urban areas are treated differently to suburban areas because expectations of daylight and sunlight into properties differ in such locations. Consequently, it is often necessary to aim for different ‘target values’ of daylight and sunlight into rooms according to the location of the development.

7.8.4 This site is located within an urban area considered appropriate for high density development. Whilst there are some low and medium rise developments in the area there are also examples of high rise, high density developments and this location has been identified as a ‘growth area’ capable of accommodating a significant number of new dwellings. It is therefore important to acknowledge that residents could not expect to enjoy the same level of amenity as would be expected within a low/medium density, suburban location. Furthermore, some properties that currently enjoy a higher than average level of daylight/sunlight because they are located close to low rise former industrial sites will experience a change in the level of daylight/sunlight received when allocated sites are developed. Notwithstanding this there is a need for all new developments to demonstrate that any loss of light or increase in overshadowing would be within acceptable levels so as not to give rise a significant loss of amenity.

7.8.5 The assessment of daylight is based on the calculation of the vertical sky component (VSC) to an affected window in both the existing and proposed condition. The VSC, simply put, is the amount of light received at the centre of a window. There is a further assessment that assesses the distribution of daylight within a room. This is called the average daylight factor (ADF).

7.8.6 Whereas VSC assessments are influenced by the size of obstruction, ADF is more influenced by the room area, the area of room surfaces, the reflectance of room surfaces and the transmittance of the glazing with the size of the obstruction being a smaller influence. The extent to which the effect of a proposal on surrounding properties is considered significant, is dependent on the use of the room to which the window relates. The significance of any impact of proposals on non-habitable or less well-used rooms such as bedrooms is therefore reduced. In this case, the relevant tests are essentially whether less than 0.8 times the existing level of daylight and sunlight is retained within a room and whether more than half of any one garden space is over shadowed.

7.8.7 The site currently comprises a two storey building albeit constructed at a higher ground level than surrounding properties. As a result the surrounding residential buildings enjoy a level of daylight and sunlight in excess of those found in a typical urban location such as this. For this reason losses of daylight and sunlight as a result of the development would be expected, with the quantum of light retained taking precedence over the percentage reduction.

7.8.8 The relevant properties tested are residential buildings with windows that face the site (Plough Way, Grove Street, Hockett Close, Carteret Way and Marine Wharf West). With regard to overshadowing, there are no main rear gardens for neighbouring properties facing the application site so in accordance with the BRE guidelines an assessment has not been done in this respect. The POS located to the south of the development will not be affected by the proposal given that shadow will cast northwards as a result of the sunpath.

7.8.9 In respect of current baseline conditions the assessment shows that for the properties in Plough Way the majority of windows in the surrounding properties achieve 27% compliance with VSC levels, most habitable rooms achieve ADF levels and APSH levels meet BRE guidelines. For the properties in Grove Street all of the windows achieve 27% compliance with VSC levels, most habitable rooms achieve ADF levels and ASPH levels meet BRE guidelines. For the properties in Hockett Close and Carteret Way all windows achieve 27% compliance with VSC levels and ADF levels indicate a degree of compliance with BRE standards, APSH was not assessed as the windows face north.

7.8.10 The assessment shows that as a result of the development 57% of rooms (37 of 65 windows) in Plough Way would experience a noticeable reduction in daylight but that 43% of windows would retain 27% of VSC. In respect of sunlight, the assessment shows that 97% of windows tested would retain in excess of BRE compliant levels of sunlight access. The reduction is largely attributed to the fact that at the present time above average daylight/sunlight is received into these properties because of the low level nature of existing buildings on the Marine Wharf Site, which is considered to be an unusual scenario. In a dense location such as this lower levels of daylight and sunlight are often experienced. On balance whilst the development would give rise to a noticeable reduction in daylight into some habitable rooms it is not considered that this would be significantly detrimental to the amenity enjoyed by occupiers of those properties. Consequently it is not considered that it would be reasonable to refuse planning permission on the grounds of loss of daylight, sunlight or overshadowing to those properties in Plough Way, taking into account the site allocation, context and extant planning permission.

7.8.11 The assessment shows that 19% (7 of 36 windows tested) in Grove Street would experience a noticeable reduction in daylight but the majority of windows would retain 27% of VSC. In respect of sunlight all rooms but one would maintain BRE compliant levels of sunlight access. For properties in Grove Street the development would give rise to only a slightly noticeable reduction in daylight into a small number of habitable rooms. It is not considered that this would be significantly detrimental to the amenity enjoyed by occupiers of those properties. Consequently it is not considered that it would be reasonable to refuse planning permission on the grounds of loss of daylight, sunlight or overshadowing to those properties in Grove Street.

7.8.12 The assessment shows that none of the windows in Hockett Close would experience a reduction in daylight or sunlight. All rooms would maintain BRE compliant levels of daylight/sunlight access.

7.8.13 The nearest property in Carteret Way has 3 windows which could be affected by the development. The assessment shows that 1 of the windows would experience a slightly noticeable reduction in daylight. It is not considered that this would give rise to a loss of amenity for the occupier.

7.8.14 For the properties in the adjacent Marine Wharf West development the assessment shows that all living room and bedroom windows would receive the BRE minimum ADF targets with the proposed development in place. Whilst there would be a reduction in daylight and sunlight level enjoyed within the adjacent development the levels achieved would be typical of a high density urban location. It is not considered that the reduction in daylight/sunlight levels would be significantly detrimental to the amenity enjoyed by occupiers of those properties. Consequently it is not considered that it would be reasonable to refuse planning permission on the grounds of loss of daylight, sunlight or overshadowing to those properties in the adjacent Marine Wharf West development.

7.8.15 This site is allocated within the development plan for high density mixed use development and it is therefore expected that there would be a significant increase in built form on the site. At the present time the site is occupied by a low rise building which means that surrounding residential priorities experience higher than average levels of daylight and sunlight. However, any replacement building would give rise to a change in the amount of daylight/sunlight received into neighbouring properties. In urban locations such as this it is accepted that redevelopment could give rise to a reduction in daylight/sunlight enjoyed by existing dwellings. However, new development should be designed to minimise any adverse impact and to comply with BRE recommended guidelines as much as possible. In this respect a balance must be struck between the benefits of the proposed scheme and the level of harm being caused by any reduction in daylight/sunlight.

7.8.16 Given the existing built form of surrounding properties and the fact that the proposed buildings have been designed to have a minimal impact on neighbouring buildings in terms of their siting, mass and scale, it is not considered that the proposed development would cause unacceptable harm to neighbouring properties by way of overshadowing or loss of light. It is recognised that there would be an increase in loss of light/overshadowing to some windows although BRE guidelines would largely still be met. A small number of windows would fall below BRE guidelines but it is considered that it would difficult to sustain a refusal on this basis.

7.8.17 On balance, Officers have concluded that the impact of the proposals on adjoining properties in terms of daylight, sunlight and overshadowing would be acceptable.

Light Pollution

7.8.18 It is recognised that there would be a significant increase in light emitted from this site due to the increase in the amount of development and the number of residential units proposed which would use lighting at night. It is considered that sufficient distance would be retained between the application site and the neighbouring buildings to prevent unacceptable light pollution occurring.

7.8.19 The use of exterior lighting within the site would be restricted to that necessary for security and safe movement around the site. A detailed lighting strategy would be controlled by condition, any lighting strategy should ensure that all exterior luminaries are shrouded so that upward spread of light is restricted and lamp outputs restricted to levels suitable for their task. Consequently it is not considered that the proposal would cause harm to neighbouring development by way of light pollution.

Outlook

7.8.20 Another important consideration is the impact of the development on the outlook from neighbouring properties and whether the development would have an overbearing impact. Views of the development from surrounding locations have been provided. Whilst it is clear that views of the site from the neighbouring buildings would dramatically change it is not considered that there would be an adverse impact in this respect. Sufficient distance would be retained between the neighbouring windows and the new development to prevent any overbearing impact or loss of outlook.

Privacy

7.8.21 In terms of privacy it is not considered that the proposal would have an adverse impact. There would be direct views from the buildings into existing residential properties on the north side of Plough Way, east side of Grove Street and north elevations of the properties in Hockett Close. There would also be direct overlooking between the new buildings on this site and approved units in Phase 7 of the adjacent Berkeley’s scheme. However, sufficient distances would be retained between the proposed buildings and surrounding developments (minimum 15m) to prevent any significant loss of privacy or overlooking. Furthermore the proposed buildings would be separated from neighbouring properties via roads (Plough Way/Grove Street), areas of public open space (Hockett Close) or via internal courtyard podiums (Marine Wharf West). It is considered that the level of mutual overlooking that would occur would be similar to that experienced on existing sites in this area and as expected in any urban residential location.

7.8.22 Given the location of the ground floor commercial units and the fact that the footway and road would provide a buffer between the commercial uses and residential dwellings on the opposite sides of Plough Way and Grove Street it is not considered that the commercial uses would give rise to significant harm to neighbouring properties.

7.8.23 All residential units would be provided with balconies. These would largely face into the courtyards of the new buildings. A mutual level of overlooking would occur between the users of the balconies but this is to be expected in a development of this nature. The balconies on the southern elevation of Block A would overlook the public open space in Hockett Close which is welcome as it will add a good level of natural surveillance and activity. Sufficient distance will be retained between these balconies and the properties in Hockett Close to prevent any loss of privacy occurring.

Noise and Disturbance

7.8.24 It is recognised that during implementation of the development there would be a significant amount of noise and disturbance from construction related activity including vehicular traffic. Traffic has been discussed above and the impact has been deemed to be acceptable.

7.8.25 Construction related noise and activity cannot be avoided when implementing a development of this nature and scale. This is a relatively short term impact that can be managed as much as practically possible through measures such as a Construction Environmental Management Plan (CEMP) and control of construction hours. The applicant has stated that construction would take approximately 2 years. On balance subject to control of the CEMP via condition it is not considered appropriate or reasonable to raise an objection to the proposal on the grounds of harm to neighbouring amenity from construction related activity.

7.8.26 Once operational it is not considered that the proposal would have an unacceptable adverse impact on neighbouring amenity by way of noise and disturbance. The proposed commercial uses on this site (B1/A1/A2/A3/D1) can operate in residential areas without giving rise to pollution, noise or disturbance if properly managed. The proposed uses do

not include hot food take always or drinking establishments which can give rise to unacceptable impacts in certain locations. Given the location and aspirations for this mixed use site and the number of betting shops already located in the north of the Borough it is considered appropriate to exclude the operation of a betting shop at this site, which would normally operate within an A2 Use Class. This has been discussed with the applicant who has agreed to accept the exclusion of a betting shop by way of condition.

7.8.27 Subject to conditions to control soundproofing, servicing and deliveries and hours of operation it is not considered that the commercial uses would give rise to adverse impacts on amenity. However, if in the future excessive noise or disturbance were to occur it would be open for appropriate action to be taken through Environmental Protection legislation.

7.8.28 It is not considered that the residential element would give rise to significant harm to neighbouring amenity by way of noise or disturbance.

7.8.29 In conclusion for the reasons set out above the proposal is not considered to have a significant adverse impact on neighbouring amenity.

Sustainability and Energy

7.9 The NPPF requires Local Planning Authorities to adopt proactive strategies to mitigate and adapt to climate change. The NPPF requires planning policies to be consistent with the Government’s zero carbon buildings policy and adopt nationally described standards. In determining planning applications, Local Planning Authorities should expect new development to comply with adopted policies on local requirements for decentralised energy supply unless it can be demonstrated by the applicant, having regard to the type of development involved and its design, that this is not feasible or viable and take account of landform, layout, building orientation, massing and landscaping to minimise energy consumption

7.9.1 London Plan and Core Strategy Policies advocate the need for sustainable development. All new development should address climate change and reduce carbon emissions. For major development proposals there are a number of London Plan requirements in respect of energy assessments, reduction of carbon emissions, sustainable design and construction, decentralised and renewable energy. Major developments are expected to prepare an energy strategy based upon the Mayors energy hierarchy adopting lean, clean, green principles. Core Strategy Policies 7 and 8 support the London Plan principles and also require all new residential development to meet a minimum of Level 4 standards in the Code for Sustainable Homes and non-residential development to meet a minimum of BREEAM ‘Excellent’.

Energy Strategy

7.9.2 This application was accompanied by a Energy Strategy and Sustainability Statement developed in line with the Mayors energy hierarchy. The development proposes:-

To utilise passive design measures such as building orientation, fabric performance, air tightness and natural ventilation to prevent overheating and to reduce requirements for mechanical heating and cooling;

Natural ventilation will be provided to residential units. Over 60% of residential units are dual aspect so will benefit from good levels of cross ventilation;

Glazing within the residential units would be specified as solar control glazing, U-values for the building fabric would exceed Part L requirements, thermal bridging would checked and quality controlled on site;

Energy efficient lighting, boilers, white goods, chillers and ventilation systems would be utilised,

Mechanical ventilation with heat recovery would be provided in the commercial units;

Roof mounted air source heat pumps would be used for comfort cooling to communal areas;

A gas fired CHP system (1 no.48kWe unit) meeting around 70% of the developments heat load and hot water demand will be provided in Building A. This is expected to deliver a reduction in CO² emissions of at least 43%;

As a back up for peak demand or in the event that the CHP equipment fails 93% efficient gas boilers will be used to provide space heating and hot water generation along with energy saving heat control measures such as time and temperature control;

376 sqm (287) Photovoltaic Panels (41,506 kWh/year) would be installed on the roofs of Buildings A and B. This is expected to provide a further reduction of 14.9% in regulated CO² emissions, after the implementation of passive design, energy efficiency and CHP

Water fixtures and fittings will comply with BREEAM 2011 ratings;

All materials used in the construction of the buildings will achieve high ratings in the BRE Green Guide to Specification;

During construction a Site Waste Management Plan with best practice benchmarks will be produced.

7.9.3 The CHP plant room would be located within Block A. The applicant has confirmed that sufficient space has been allocated for any necessary plant and equipment.

7.9.4 A preliminary study to assess the feasibility of connecting into a local district network has been undertaken. The nearest network is SELCHP which extends into the vicinity of the site and could connect to this site in the future. The applicant has entered into discussions with SELCHP, it has been confirmed that at the present time a connection with SELCHP could not be made but the development should include future provision for necessary connection to the network. A condition is recommended to ensure that the necessary pipework is installed within the site as part of the redevelopment to enable future connection if possible and that the Developer makes provision for the future connection as soon as it becomes available.

7.9.5 A range of renewable energy technologies have been appraised. It is concluded that PV Panels are the most appropriate solution for use with the CHP.

7.9.6 After including low and zero carbon technologies, it is expected that the development would have CO² emissions that are approximately 51.7% better than the requirements of Part L 2010 (regulated emissions only). This is therefore expected to exceed indicated Part L 2013 compliance levels, demonstrating very high carbon performance. This targeted improvement also exceeds the required 40% CO² reduction set out in Policy 5.2 of the London Plan.

Code for Sustainable Homes (CfSH) and BREEAM

7.9.1 The Energy Strategy and Sustainability Statement confirms that the residential units are aiming to meet CfSH Level 4 in line with policy requirements. The commercial units would aim to meet BREEAM ‘Very Good’.

7.9.2 CfSH and BREEAM Pre Assessments has been undertaken for the proposed development to identify at this early stage in the design process, the maximum number of credits than can be achieved. The BREEAM Pre Assessment score shows the commercial units can only achieve a ‘Very Good’ rating. The Pre Assessment shows that the development can achieve a rating 61.24% and the applicant has confirmed that they would endeavour to obtain more credits in the detailed design assessment.

7.9.3 The applicant has stated that an ‘excellent’ rating is difficult to achieve in this location as the amount of transport related points that can obtained are limited. Further, achieving an excellent rating for small commercial units is significantly difficult unless a full and detailed fit out is specified and implemented. Without known occupiers it is difficult to implement the level of fit out required to obtain the necessary points. A full fit out to meet BREEAM ‘excellent’ could be prohibitive to future tenants as it would not meet their needs and could be onerously expensive which would make the unit less attractive in the market place.

7.9.4 Whilst this development will include a degree a fit-out beyond shell and core it is not of sufficient detail to enable the necessary BREEAM credits to be obtained at this stage. A way around this is to enforce a Building Green Guide/Tenancy Lease Agreement on the future occupiers but this is problematic as it would tie down a future occupier to operate in a certain way. For larger businesses a Building Green Guide/Tenancy Lease Agreement can work but for small businesses it can be onerous and expensive. On balance given the need to make these units affordable and attractive to a range of local and/or small businesses it is not considered appropriate to enforce a Building Green Guide/Tenancy Lease Agreement.

7.9.5 The minimum score rating for ‘Very Good’ is 55%. BREEAM Assessors recommend that pre assessments must achieve more than 2 points above the minimum score to ensure that the development can meet the required standard in its detailed design (this allows for a margin of error in the pre assessment). The document submitted shows a clear commitment to meeting the ‘Very Good’ rating.

7.9.6 The fact that the commercial units cannot meet ‘Excellent’ is regrettable. However, this was accepted on the previous application and on balance it is considered that the proposal represents a sustainable form of development that addresses climate change policies in a variety of ways. The redevelopment would make effect use of this Brownfield site, the new buildings would be far more efferent in terms of energy, water and materials than the existing buildings on site, the proposal includes a site wide CHP and the Mayors targets for CO2 emission are exceeded. The proposal includes high proportion of living roofs, PV panels and incorporates sustainable urban drainage.

7.9.7 The development would bring a range of social, economic and environmental improvements to the area and is an important part of the Plough Way Strategic Site therefore Officers do not consider that it would be reasonable to refuse planning permission because the proposed commercial units cannot meet BREEAM ‘Excellent’ rating. It is considered that this would be difficult to justify at an appeal when an Inspector is likely to take a pragmatic approach to approving the application as an exception to Core Strategy Policy 8, giving significant weight to the positive benefits of the proposal, which include compliance with all other climate change polices as well as the commercial buildings meeting a high scores with the BREEAM ‘Very Good’ rating.

7.9.8 For the reasons stated, on balance it is recommended that this application should be approved subject to a condition requiring the residential units to meet CfSH minimum Level 4 and the commercial units to meet BREEAM minimum ‘Very Good’ as an

exception to Core Strategy Policy 8. A condition would be attached requiring the development to achieve a minimum rating of ‘Very Good’ which allows the opportunity for the Developer to achieve a higher rating if possible at the time of preparing detailed construction drawings. The condition would require the submission of a Design Stage Certificate to confirm that the development is capable of meeting the standard. The Council would not look favourably upon any rating lower than ‘Very Good’. Evidence that the constructed buildings do meet this standard would be required by way of submission of a Post Construction Certificate issued by an Accredited BREEAM Assessor.

7.9.9 It is important to note that significant weight has been given to the benefits of the proposal and its ability to meet all other climate change mitigation policies, which justifies this approach in this instance, but this should not be regarded as setting a precedent for other developments of this nature not meeting the required BREEAM standard, which would need to be assessed on their merits.

7.9.7 For the reasons stated, it is recommended that this application should be approved subject to a condition requiring the residential units to meet CfSH minimum Level 4 and the commercial units to meet BREEAM minimum ‘Excellent’ The condition would require the submission of a Design Stage Certificate to confirm that the development is capable of meeting the standard. Evidence that the constructed buildings do meet this standard would be required by way of submission of a Post Construction Certificate issued by an Accredited BREEAM Assessor.

b) Living Roofs

7.9.8 Policy 5.11 of the London Plan confirms that development proposals should include ‘green’ roofs and that Boroughs may wish to develop their own green roof policies. To this end, Core Strategy Policy 7 specifies a preference for Living Roofs (which includes bio-diverse roofs) which in effect, comprise deeper substrates and a more diverse range of planting than plug-planted sedum roofs, providing greater opportunity for bio-diversity.

7.9.9 The application proposes sedum, green and brown living roofs on both buildings (2579 sqm). Details have been submitted to demonstrate that the substrate build up can accommodate biodiverse living roof comprising ‘London Wildflower Mix’. The proposed type and extent of living roofs complies with Policies 5.11 of the London Plan and CSP7 of the LDF and can be secured by condition.

c) Sustainable Urban Drainage Systems

7.9.10 Policy 5.13 of the London Plan requires development to utilise SUDS, unless there are practical reasons for not doing so though supporting text to the policy also recognises the contribution ‘green’ roofs can make to SUDS. The hierarchy within that policy is for a preference for developments to store water for later use.

7.9.11 The surface water strategy for the site has been developed in conjunction with the Environment Agency and where possible incorporates SUDs features to reduce the impact on the receiving sewers and watercourses.

7.9.12 The livings roofs would assist in attenuating and reducing the amount of run-off actually leaving the site.

7.9.13 Overall the proposal is considered to be acceptable when judged against sustainability policies.

Ecology

7.10 The planning system should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes, geological conservation interests and

soils; minimising impacts on biodiversity and providing nets gains in biodiversity where possible. The NPPF addresses ecology in paragraph 109 which states, the planning system should aim to conserve and enhance the natural and local environment by minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures. Paragraph 118 of the NPPF also states that opportunities to incorporate biodiversity in and around developments should be encouraged. Core Strategy Policy 11 seeks to protect the Borough’s rivers and waterway network and Core Strategy Policy 12 seeks to protect open space and environmental assets.

7.10.1 This site is a brownfield site with limited ecological value. There is a Site of Importance for Nature Conservation (SINC) located on the former railway embankment to the east of the site (Rainsborough Avenue). However, this is not close enough to be adversely affected by the redevelopment of this site.

7.10.2 As part of this application an Ecological Appraisal has been undertaken. The applicants landscape consultant undertook a site inspection in June 2013 to assess the land for the presence (actual or potential) of important or protected species or habitats. The report states that none of the trees on site support features that would be considered suitable for bat roosting or hibernation. Due to the lack of vegetation on site and in the wider landscape foraging and commuting opportunities appeared to be limited. There were no signs of Badger activity found within or near to the site and there is limited potential for breeding amphibians or reptiles. Only 3 bird species were recorded, all of which were of low conservation value according to the RSPB Green list. No other protected or important species were observed.

7.10.3 The report concludes that from an ecological perspective the proposed development is considered to have little impact on wildlife or habitats.

7.10.4 Although this site has limited ecological value at the present time, there is a need to enhance opportunities for ecology and biodiversity as part of the redevelopment. This application proposes extensive living roofs and soft landscaped areas which will help to enhance opportunities for biodiversity. For a development of this scale it is considered appropriate to require the development to incorporate bird and bat boxes and to produce an ecological enhancement and management plan. This can be controlled by condition.

Other Considerations

7.11 Flooding, air quality and land contamination have been addressed as part of the ES assessment discussed in earlier sections of this report, appropriate conditions are recommended.

Planning Obligations

7.12 The National Planning Policy Framework (NFFP) states that in dealing with planning applications, local planning authorities should consider whether otherwise unacceptable development could be made acceptable through the use of conditions or planning obligations. Planning obligations should only be used where it is not possible to address unacceptable impacts through a planning condition. It further states that where obligations are being sought or revised, local planning authorities should take account of changes in market conditions over time and, wherever appropriate, be sufficiently flexible to prevent planned development being stalled. The NFFP also sets out that planning obligations should only be secured when they meet the following three tests:

(a) Necessary to make the development acceptable

(b) Directly related to the development; and

(c) Fairly and reasonably related in scale and kind to the development

7.13 Paragraph 122 of the Community Infrastructure Levy Regulations (April 2010) puts the above three tests on a statutory basis, making it illegal to secure a planning obligation unless it meets the three tests.

7.14 The applicant has provided a planning obligations statement outlining the obligations that they consider are necessary to mitigate the impacts of the development.

7.15 London Plan Policy 8.2 (Planning obligations), and Core Strategy Policy 21 (Planning Obligations) together with the Councils Adopted Planning Obligations SPD (2015) sets out the policy context for considering planning obligations. Whether a development makes appropriate provision for, or contribution towards, requirements that are made necessary by, and are related to, the proposed development would be a material consideration relevant to the planning application being considered. Negotiations should seek a contribution towards the full cost of all such provision that is fairly and reasonably related in scale and in kind to the proposed development and its impact on the wider area. Planning obligations should reflect strategic and local needs. In accordance with the statutory and policy context, and as a result of the assessment of the impacts of the proposed development the agreed Heads of Terms for a Section 106 Agreement are set out below.

7.16 Given that the applicant proposes works to public highways, an agreement or agreements with LB Lewisham under Section 278 and Section 38 of the Highways Act 1980 would also be necessary.

7.17 On the 1st April the borough adopted its Community Infrastructure Levy, contributions that previously would have been secured by Section 106 such as Education, Health, Leisure are now collected by CIL. Contributions (financial and non-financial) which are site specific continue to be secured by Section 106 agreement.

7.18 The proposed heads of terms are listed below:

Heads of Terms

Housing 40 Affordable units (22 affordable rent and 18 intermediate), comprising 8 x 1 bed,

17 x 2 bed, 11 x 3 bed and 4 x 4 bed. Affordable rent units to be capped at 60% of market value; Review mechanisms for affordable housing provision to include a review if

development does not commence in 24 months of the permission being issued and in any event upon 75% occupation;

Affordable units within each block to be built and transferred to a Registered Provider upon occupation of 50% of the private residential units with each block;

Provision of 20 wheelchair units of which 6 would be affordable and 16 private. All units to be capable of adaption to SELHP. The affordable units to be fitted out and private units to be subject to an agreed marketing strategy and fitted out only in response to demand;

Not to occupy more than 50% of any residential units until the Energy Centre is complete and operational.

Employment Use An obligation to acknowledge the appropriateness of securing the commercial units

as part of the development; Shell and Core fit-out (with appropriate glazing solution) of the commercial units

prior to any occupation of the residential units;

Full fit out of the commercial units once an occupier has been secured (and their specific requirements known). Fit out to be paid for and undertaken by the Developer with a cap of £40 per so ft;

An agreed marketing strategy for the commercial units; Flexible tenancy arrangements for the commercial occupiers; A period of 6 months rent free for the first occupiers of the commercial units; A period of 12 months free from ground rent and service charges for the first

occupiers of the commercial units; A clause to prevent a change of use under permitted development from B1 to C3; A clause to prevent change of use any of the commercial units to residential for a

period of 3 years following practical completion.

Financial Contributions £103,054.55 towards employment and training. To be paid on commencement of

any part of the development; £44,017.35 towards town centre management. To be paid on first occupation of the

residential development; £147,000 towards transport and public realm. To be paid on commencement of any

part of the development; £180,000 to be paid to TfL for bus service improvements. To be paid on

commencement of any part of the development; £10,000 towards environmental protection monitoring. To be paid on

commencement of any part of the development; £35,000 towards the consultation and implementation of a future Controlled Parking

Zone. To be paid on commencement of any part of the development. Occupiers of the development would be excluded from obtaining permits for the CPZ.

Provision of car club facilities for one vehicle within the site together with a membership package for residential and commercial occupiers. Membership package includes 2 years membership for first residential occupiers

In-kind/other obligations Implementation of off-site improvements to re-configure the existing parking area in

Hockett Close/Carteret Way in order to implement the proposed Homezone route (subject to necessary consents being obtained). This would comprise the submission of detailed specification of works followed by implementation prior to first occupation of the development;

Enter into a s278/s38 agreement to undertake improvements to the highways adjacent to the site (Plough Way and Grove Street);

Local labour obligations e.g. use of local labour during construction, working with the Councils Local Labour and Business Coordinator etc..;

Provision of a real-time public transport board within the foyer/concierge of the development;

Submission of a Parking Management Plan (prior to first occupation); Submission of Travel Plans for the commercial and residential elements (prior to

first occupation). The residential travel must take account of all measures identified in the framework travel plan submitted with the application. The commercial travel plan must address arrangements for staff showing facilities to promote cycling;

Submission of a Public Access Management Plan including a commitment to erecting the way-finding signage and CCTV as set out in the Design and Access Statement hereby approved (prior to first occupation);

Reimbursement of the Councils legal, professional and monitoring costs associated with the drafting, finalising and monitoring the agreement.

7.19 Officers consider that the obligations outlined above are appropriate and necessary in order to mitigate the impacts of the development and make the development acceptable

in planning terms. Officers are satisfied the proposed obligations meet the three legal tests as set out in the Community Infrastructure Levy Regulations.

8 Local Finance Considerations

8.10 Under Section 70(2) of the Town and Country Planning Act 1990 (as amended), a local finance consideration means:

(a) a grant or other financial assistance that has been, or will or could be, provided to a relevant authority by a Minister of the Crown; or

(b) sums that a relevant authority has received, or will or could receive, in payment of Community Infrastructure Levy (CIL).

8.11 The weight to be attached to a local finance consideration remains a matter for the decision maker.

8.12 The Mayor of London's CIL is therefore a material consideration. CIL is payable on this application and the applicant has completed the relevant form.

9 Viability and Delivery

Viability

9.1 The Applicant has submitted a confidential financial appraisal for the scheme that has enabled the Council, advised by specialist consultants, to assess the overall viability of the scheme and its ability, in financial terms, to meet policy in terms of affordable housing provision.

9.1.2 The financial viability assessment has been independently tested in terms of its methodology for assessment. The content has been found to be robust in terms of development opportunity, and viable against a number of land and profit benchmarks . It has been necessary to consider the value of the site in terms of Quickdrop Ltd owning the site and as an investment opportunity. The scheme assumptions and build costs have been tested and consideration has been given to sensitivity tests, s106 and CIL requirements in seeking to ascertain whether the development is viable and what level of affordable housing can be provided.

9.1.3 With regard to a suitable development return, the GLA Toolkit’s default allowance is 17% of Gross Residential Development Value (GDV) ( c. 20% on Cost). The applicants viability report stated that a development comprising 15% affordable units (18% by habitable room) would provide a return of 19.81% on total cost or 16.5% GDV.

9.1.4 The applicants initial viability appraisal suggested an affordable housing provision of 15% or 34 dwellings. However, negotiations between officers and the applicant have resulted in an additional 6 affordable dwellings to provide a total of 40 units or 17.7% overall provision.

9.1.5 The increased affordable housing offer has resulted from discussion with the applicant, and both the Council’s and applicants Quantity surveyor regarding scheme build costs and potential sales figures. Furthermore, since the granting of the original scheme in 2013 the applicant has been working on detailed design and this has produced some additional costs, such as the need to provide a transfer slab between the floors. This was not originally specified in the original build costs and has resulted only through detailed design. The build costs have now been agreed with the Councils consultant and are considered to be reasonable. It is also noted that since the granting of permission in 2013 build costs have risen in London.

9.1.6 As stated above, these discussions have successfully resulted in an increased affordable housing offer. It is now proposed that there would be 40 affordable units and officers have also sought to increase the levels of affordable rent, rather than intermediate and cap those rents at 60% of market value. Such restrictions on the tenure have impacts upon scheme viability.

9.1.7 The original permission on this site (2013) was subject to Mayoral CIL and s106. In April 2015 the Council adopted its Community Infrastructure Levy, which is a mechanism that charges new development that allows local authorities to fund infrastructure. The Councils Planning Obligations Supplementary Planning Statement (2015) provides further guidance on CIL. Previous obligations that would have been secured by Section 106 – namely Education, Health, Leisure, Community Facilities and Open Space are now collected via CIL, whilst other site specific obligations such as affordable housing, public realm and car club provision remain Section 106 items.

9.1.8 The borough has two CIL charging zones, with development in postcode SE8 located in Zone 1 with a residential development (use class C3) charged at £100 per sqm, B-use Class development with £0 no charge and all other uses at £80 per sqm. The site is located in Zone 1 for Lewisham CIL.

9.1.9 Officers have agreed a S106 contribution of approximately £519,071.90, maximum fit out cost of £449,520 for the commercial unit generating a total of £968,891.690. The Mayoral and Lewisham CIL figure stands at £1,837,281 creating a total of £2,805,872.90. This compares £2,463,613 for the previous application, representing an additional £342,259.90 in financial contributions.

9.1.10 The change in mechanism, for the collection of financial obligations has not impacted upon the viability of the scheme to deliver affordable housing which has been confirmed by the Council’s viability consultant, despite an increase in financial contributions and affordable housing offer.

9.1.11 The reasons for a lower than policy compliant level of affordable housing relate to lack of grant funding, potential remediation costs to deal with potential contamination and the package of measures provided to make the commercial units affordable and attractive to small businesses. There are also a range of transport and public realm improvements that would be undertaken to enhance pedestrian and cycle routes to the site as well as open space enhancements. These parts of the scheme require substantial investment but also offer very significant regeneration benefits to Lewisham borough.

9.1.12 While it is accepted that the provision of a larger proportion of affordable housing is not possible at this time, given the shortfall in affordable housing provision relative to the levels set out in planning policies, it is appropriate that additional affordable housing be kept under review. To this end, two review mechanisms are to be incorporated into the Section 106 agreement to secure a financial contribution towards affordable housing off-site, should values increase to a level where this would be financially viable. The first review would take place if development does not commence within 24 months. The second review would occur upon 75 completion of the development. Both review mechanisms have been discussed with the applicant.

Delivery

9.1.13 The viability appraisal confirms that the proposed development at this point in time, would achieve a profit level below the GLA toolkit accepted level of 17% GDV but the level of profit that can be obtained at this point in time takes into account the costs associated with delivery the development as proposed. The build costs have been checked by an independent QS and full account has been taken of the costs associated with implementing the development (S106 and CIL). The applicant has accepted the level of profit shown in the viability assessment and will proceed with the development as it is

anticipated that sales values will improve over the next 18 to 24 months. On this basis there is nothing to suggest that the development could not be delivered in accordance with the details submitted with this application, at this point in time.

9.1.14 It is proposed to deliver this development as one construction phase over a period of approximately 2 years. The applicant does not have vacant possession of the site until Autumn 2015 so construction is not anticipated to be complete until the end of 2017. As discussed above if there is a delay in the delivery of the project it remains open for the Council to re-consider the affordable housing provision and in any event the Council would look to re-consider viability upon 75% completion.

9.1.1 There are no known land ownership issues that would prevent delivery of the development. As discussed in earlier sections of the report full delivery of the Homezone route is reliant upon a re-configuration of land that falls within Council ownership and rights of access being granted across the areas of land. However, this approach is supported in principle, has been discussed with relevant parties within the Council and it is not anticipated that this part of the scheme could not be delivered through an appropriately worded s106 obligation. Nevertheless a fallback position has been secured in the event that necessary consents cannot be obtained to re-configure the area of land that falls outside of the applicants ownership or gain access rights across it. If the fallback position were to be implemented (only after the applicant had used reasonable endeavours to implement the homezone route) the scheme could be delivered without detriment to the quality of the development or level of amenity secured for future occupiers.

9.1.2 The development can still be accommodated with the Thames Tideway Tunnel project albeit that this is a consideration in respect of construction logistics.

9.1.3 This development would not prejudice the future development of any adjoining sites.

10 Equalities Considerations

10.1 Section 149 of the Equality Act 2010 (“the Act”) imposes a duty that the Council must, in the exercise of its functions, have due regard to:

(a) eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under the Act;

(b) advance equality of opportunity between persons who share a relevant protected characteristic and those who do not;

(c) foster good relations between persons who share a relevant protected characteristic and persons who do not share it.

10.1 The protected characteristics under the Act are: Age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex and sexual orientation. The duty is a “have regard duty” and the weight to attach to it is a matter for the decision maker bearing in mind the issues of relevance and proportionality.

10.2 Equality issues have been duly considered as part of the assessment of this application. It is not considered that the application would have any direct or indirect impact on the protected characterises.

11 Conclusion

11.1 The proposed development of the site raises issues relating to the provision of employment space and introduction of residential development together with matters associated with the nature and scale of the proposed development and its impact on the

local environment. This report has considered those matters in the light of adopted and emerging development plan policies and other material considerations including the information set out in the Environmental Statement.

11.2 As discussed in this report the redevelopment of this site as part of the wider Plough Way Strategic site is considered to make a significant positive contribution to the regeneration of this part of the Borough. Officers have engaged in extensive discussions with the applicant regarding redevelopment opportunities for the site in order to try and influence the nature and quality of the development proposals that come forward.

11.3 In physical terms and in its mix of uses, Officers feel that a high quality proposal has been negotiated, but it is recognised that its success will be dependent on how the proposal is executed, the detailed construction of the buildings and the successful delivery of the commercial uses. It is felt that as far as reasonably possible, within the parameters of the planning framework, an appropriate package of measures has been secured to try and ensure that the benefits of the scheme are delivered and a high quality development executed.

11.4 Officers consider that the site analysis and its context is based on an appropriate understanding of the benefits, problems, constraints and opportunities of this part of the borough and an appropriate response to these considerations has been demonstrated within the proposal. Whilst adopted policies require 20% of B1 Use to form part of development proposals for the strategic sites, on balance Officers are satisfied that the material submitted with the application demonstrates a robust case for allowing 6.5% commercial floorspace across flexible uses classes. However, this is subject to a package of measures being secured within the s106 to make the commercial units attractive and affordable in the market. On balance it is considered that the proposal together with the package of s106 mitigation measures represents a realistic and sustainable mixed use redevelopment of the site that can respond to current market conditions. Consequently the planning permission should be granted as an exception to Core Strategy Policy 4: Mixed Use Employment Locations and Strategic Site Allocation 5: Plough Way of the Core Strategy (July 2011).

11.5 Other site specific issues include: the height, massing and design of buildings and the impact that the development would have on protected views and townscape; the ability of local transport and social infrastructure to cope with the level of change proposed; the accessibility of the scheme; the impact the development would have on the occupiers of surrounding properties and the wider local environment including ecological impact; and the ability to deliver an environmentally sustainable development. For the reasons set out in this report it is considered that the proposal adequately responds to the aforementioned issues.

11.6 In addition to the lower than policy compliant inclusion of B1 floorspace, the proposal does not comply with adopted policy in terms of the level of affordable housing due to accepted viability constraints. However, the proposed development would result in the provision of much needed housing including the provision of family sized dwellings across private and affordable tenures. The proposal would include a significant package of environmental improvements by way of enhanced public routes to the site, increase permeability through the site and open space improvements. It has been demonstrated that the scale of the development is acceptable, that the buildings have been designed to respond to the site’s context, constraints and potential and that the development would provide a good standard of accommodation.

11.7 Revised plans have been submitted which now accord with the London Plan for cycle parking standards and negotiations with the applicant have resulted in the provision of additional affordable homes on the site.

11.8 Officers consider that, with the recommended mitigation, planning conditions and obligations in place the proposal represents a high quality development that would bring a range of positive benefits to the Borough. As such the development should be approved as an exception to Core Strategy Policy 4: Mixed Use Employment Locations and Strategic Site Allocation 5: Plough Way of the Core Strategy (July 2011).

8 RECOMMENDATIONS12.1 The recommendations to the Committee are set out below.

12.2 As the proposed development is not in accordance with the provisions of the relevant development plan in terms of the provision of employment floorspace (Core Strategy Policy 4: Mixed Use Employment Locations and Strategic Site Allocation 5: Plough Way of the Core Strategy (July 2011), there is a requirement to refer the application to the Secretary of State under the Town and Country Planning (Consultation) (England) Direction 2009 (paragraph 5). There is also a requirement to refer the application to the Mayor of London.

RECOMMENDATION (A)

To agree the proposals and refer the application, this report and any other required documents to the Mayor for London (Greater London Authority) under Article 5 of the Town and Country Planning (Mayor of London) Order 2008.

RECOMMENDATION (B)

7.3 Subject to no direction being received from the Mayor of London, to refer the application to the Secretary of State at the appropriate government office (National Planning Casework Unit) under the Town and Country Planning (Consultation) (England) Direction 2009 (paragraph 5), as a departure from the development plan in respect of Core Strategy Policy 4: Mixed Use Employment Locations and Strategic Site Allocation 5: Plough Way of the Core Strategy (July 2011).

RECOMMENDATION (C)

7.4 Subject to no direction being received from the Secretary of State, authorise officers to negotiate and complete a legal agreement under Section 106 of the 1990 Act (and other appropriate powers) to cover the principal matters set out in section 7 of this report, including such other amendments as considered appropriate to ensure the acceptable implementation of the development:

RECOMMENDATION (D)

7.6 Subject to completion of a satisfactory legal agreement, authorise the Head of Planning to GRANT PLANNNG PERMISSION subject to conditions including those set out below and such amendments as considered appropriate to ensure the acceptable implementation of the development.

Conditions

1. Full Planning Permission Time Limit

The development to which this permission relates must be begun not later than the expiration of three years beginning with the date on which the permission is granted.

Reason: As required by Section 91 of the Town and Country Planning Act 1990.

2. Develop in Accordance with Approved Plans and Documents and Environmental Statement

The development shall be carried out strictly in accordance with the application plans, drawings and documents hereby approved and as detailed below:

102, 103, 104, 105, 106, 107, 108, 109, 110, 200, 201, 202, 203, 204, 220, 221, 222, 223, 300, 301, 302, 303, 304, 305, 320, 321, 322, 323, 324, PL 001, PL 002, Pl 003, PL 400, PL 401, PL 402, PL 403, PL 404, PL 405, PL 406, PL 407, PL 408, PL 409, PL 410, PL 411, PL 412, PL 413, PL 414, PL 415, PL416, PL 417, PL 418, PL 419, PL 420, PL 412, PL 422, PL 423, PL 424, PL 425, Pl 426, PL 427, PL 428, PL 429, PL 430, PL 431, PL 432, PL433, PL 434, PL 435, PL 436, PL 437, PL 438, PL 439, PL 440, PL 441, PL 442, PL 443, PL 444, PL 445, PL 446, PL 447, PL 448, PL 448, PL 450, Design and Access Statement, Homes Landscape Illustrative Material 5165.LIM.006, Arboricultural Statement 5165 FE AS 01 Rev A, Landscape Management Plan, Construction Environmental Management Plan Revision 03, Ecological Appraisal of Land at Plough Way, Outline Construction Logistics Plan February 2015, Planning Statement, Travel Plan February 2015, Transport Assessment February 2015, Statement of Community Involvement, Sustainability Statement, Energy Strategy, Update to Economic Regeneration Statement, Environmental Statement Volume 1 Non-Technical Summary, Environmental Statement Volume 2 Main Report, Environmental statement Volume 3 Townscape and Visual Impact Assessment, Environmental statement Volume 4 Technical Appendices Part 1, Environmental Statement Volume 4 Technical Appendices Part 2 received on 26th February 2015, 100 A, 101 A received on the 22nd May 2015.

Reason: To ensure that the development is carried out in accordance with the approved documents, plans and drawings submitted with the application and is acceptable to the local planning authority.

Pre Commencement Conditions

3. Construction Environmental Management and Logistics Plan

No development shall commence on site until such time as a Construction Environmental Management Plan incorporating Traffic Construction Logistics and Site Waste Management has been submitted to and approved in writing by the local planning authority. The plan shall be include the mitigation measures specified within all chapters of the Environmental Statement (and Addendum) and shall cover:-

(i) Full details of arrangements for the management and disposal of construction material and waste

(ii) Exploration of the potential for transporting construction materials and waste via the River Thames to reduce construction related traffic movements

(iii) Dust mitigation/management measures

(iv) The location and operation of plant and wheel washing facilities

(v) Details of best practical measures to be employed to mitigate noise and vibration arising out of the construction process

(vi) Details of construction traffic movements including cumulative impacts which shall demonstrate the following:-

Rationalise travel and traffic routes to and from the site.

Provide full details of the number and time of construction vehicle trips to the site including the route for heavy goods vehicles, with the intention and aim of reducing the impact of construction relates activity.

Measures to deal with safe pedestrian movement.

(vii) Measures to prevent construction workers coming into direct contact with ground and sub-surface soils which should include protective and preventative measures to ensure that contamination risks to underlying soils, ground water and nearby surface water resources would be reduced to a negligible level

(viii) Use of oil interceptors in trafficked areas so that there would be no discharge to ground via infiltration.

(ix) Security Management (to minimise risks to unauthorised personnel).

(x) Details of the training of site operatives to follow the Construction Environmental Management Plan requirements and including Construction Logistics and Site Waste Management.

(xi) Details of methods to liaise with the public and neighbouring sites, including procedures for receiving and responding to complaints

(xii) Protocols for reviewing and monitoring the CEMP including timeframes for meetings and environmental audits.

Reason: To comply with the content of the Environmental Impact Assessment submitted with this application and in order that the local planning authority may be satisfied that the demolition and construction process is carried out in a manner which will minimise possible noise, disturbance and pollution to neighbouring properties and to ensure satisfactory vehicle management in accordance with Policy 5.3 Sustainable design and construction, Policy 6.3 Assessing effects of development on transport capacity and Policy 7.14 Improving air quality of the London Plan (2011).

4. Site Contamination

(a) No development shall commence until each of the following have been complied with:-

(i) A desk top study and site assessment to survey and characterise the nature and extent of contamination and its effect (whether on or off-site) and a conceptual site model have been submitted to and approved in writing by the local planning authority.

(ii) A site investigation report to characterise and risk assess the site which shall include the gas, hydrological and contamination status, specifying rationale; and recommendations for treatment for contamination. encountered (whether by remedial works or not) has been submitted to and approved in writing by the Council.

(iii) The required remediation scheme implemented in full.

(b) If during any works on the site, contamination is encountered which has not previously been identified (“the new contamination”) the Council shall be notified immediately and the terms of paragraph (a), shall apply to the new contamination. No further works shall take place on that part of the site or adjacent areas affected, until the requirements of paragraph (a) have been complied with in relation to the new contamination.

(c) The development shall not be occupied until a closure report has been submitted to and approved in writing by the Council. This shall include verification of all measures, or treatments as required in (Section (a) i & ii) and relevant correspondence (including other regulating authorities and stakeholders involved with the remediation works) to verify compliance requirements, necessary for the remediation of the site have been implemented in full.

The closure report shall include verification details of both the remediation and post-remediation sampling/works, carried out (including waste materials removed from the site); and before placement of any soil/materials is undertaken on site, all imported or reused soil material must conform to current soil quality requirements as agreed by the authority. Inherent to the above, is the provision of any required documentation, certification and monitoring, to facilitate condition requirements.

Reason: To ensure that the local planning authority may be satisfied that potential site contamination is identified and remedied in view of the historical use(s) of the site, which may have included industrial processes and to comply DM Policy 28 Contaminated Land of the Development Management Local Plan (November 2014).

5. Protecting Residential Properties from External Noise (a) The building shall be designed so as to provide sound insulation against external noise and vibration, to achieve levels not exceeding 30dB LAeq (night) and 45dB LAmax (measured with F time weighting) for bedrooms, 35dB LAeq (day) for other habitable rooms, with window shut and other means of ventilation provided. External amenity areas shall be designed to achieve levels not exceeding 55 dB LAeq (day) and the evaluation of human exposure to vibration within the building shall not exceed the Vibration dose values criteria ‘Low probability of adverse comment’ as defined BS6472.

(b) Development shall not commence until details of a sound insulation scheme complying with paragraph (a) of this condition have been submitted to an approved in writing by the local planning authority.

(c) The development shall not be occupied until the sound insulation scheme approved pursuant to paragraph (b) has been implemented in its entirety. Thereafter, the sound insulation scheme shall be maintained in perpetuity in accordance with the approved details.

Reason: To safeguard the amenities of the occupiers of the proposed dwellings and to comply with DM Policy 26 Noise and vibration and DM Policy 32 Housing design, layout and space standards of the Development Management Local Plan (November 2014).

6. Soundproofing Mixed Use Buildings or Where Commercial Adjoins Residential(a) No development shall commence until full written details, including relevant drawings and specifications of the proposed works of sounds insulation against airborne noise to meet D’nT,w + Ctr dB of not less than 55 for walls and/or ceilings where residential parties non domestic use shall be submitted to and approved in writing by the local planning authority. (b) The development shall only be occupied once the soundproofing works as agreed under part (a) have been implemented in accordance with the approved details.

(c) The soundproofing shall be retained permanently in accordance with the approved details.

Reason: In the interests of residential amenity and to comply with DM Policy 26 Noise and vibration and DM Policy 32 Housing design, layout and space standards of the Development Management Local Plan (November 2014).

7. Operational Noise Control (a) The rating level of the business operational noise (including any fixed plant) emitted from the site shall be 5dB below the existing background level at any time. The noise levels shall be determined at the façade of any noise sensitive property. The measurements and assessments shall be made according to BS4142:1997.

(b) Development shall not commence until details of a scheme complying with paragraph (a) of this condition have been submitted to and approved in writing by the local planning authority.

(c) The development shall not be occupied until the scheme approved pursuant to paragraph (b) of this condition has been implemented in its entirety. Thereafter the scheme shall be maintained in perpetuity.

Reason: To safeguard the amenities of the adjoining premises and the area generally and to comply with DM Policy 26 Noise and vibration the Development Management Local Plan (November 2014).

8. BREEAM for Non Residential Buildings(a) The commercial units hereby approved shall achieve a minimum BREEAM Rating of ‘Very Good’ scoring at least 61% as set out in the BREEAM Pre Assessment hereby approved.

(b) No development shall commence until a Design Stage Certificate for each commercial unit (prepared by a Building Research Establishment qualified Assessor) has been submitted to and approved in writing by the local planning authority to demonstrate compliance with part (a).

(c) Within 3 months of occupation of any of the commercial units, evidence shall be submitted in the form of a Post Construction Certificate (prepared by a Building Research Establishment qualified Assessor) to demonstrate full compliance with part (a) for that specific building.

Reason: To comply with Policies 5.1 Climate change and mitigation, 5.2 Minimising carbon dioxide emissions, 5.3 Sustainable design and construction, 5.7 Renewable energy, 5.15 Water use and supplies in the London Plan (2015) and Core Strategy Policy 7 Climate change and adapting to the effects, Core Strategy Policy 8 Sustainable design and construction and energy efficiency (2011).

9. Code for Sustainable Homes for New Build Residential Development (a) The residential buildings hereby approved shall achieve a minimum Code for Sustainable Homes Rating Level 4.

(b) No development shall commence until a Design Stage Certificate for each residential unit (prepared by a Code for Sustainable Homes qualified Assessor) has been submitted to and approved in writing by the local planning authority to demonstrate compliance with part (a).

(c) Within 3 months of occupation of any of the residential units, evidence shall be submitted in the form of a Post Construction Certificate (prepared by a Code for Sustainable Homes qualified Assessor) to demonstrate full compliance with part (a) for that specific unit.

Reason: To comply with Policies 5.1 Climate change and mitigation, 5.2 Minimising carbon dioxide emissions, 5.3 Sustainable design and construction, 5.7 Renewable energy, 5.15 Water use and supplies in the London Plan (2011) and Core Strategy Policy 7 Climate change and adapting to the effects, Core Strategy Policy 8 Sustainable design and construction and energy efficiency (2015).

10. Future Connection to a District Combined Cooling, Heat and Power or Combined Heat and Power Scheme(a) No development shall commence until the following details have been submitted to and approved in writing by the local planning authority.

(i) Written information, drawings and sections showing a scheme for the provision of conduits and/or piping for future connection to a District Combined Cooling, Heat and Power (CCHP) or Combined Heat and Power Scheme CHP Scheme and Network and

(ii) A written feasibility, commitment and timeframe for connecting to a District Combined Cooling, Heat and Power (CCHP) or Combined Heat and Power Scheme (CHP) Scheme and Network

(b) The development shall be carried out in accordance with the approved details under part a (i) and (ii).

Reason: To comply with Policies 5.1 Climate change and mitigation, 5.2 Minimising carbon dioxide emissions, 5.3 Sustainable design and construction, 5.5 Decentralised energy networks and 5.7 Renewable energy in the London Plan (2015) and Core Strategy Policy 7 Climate change and adapting to the effects and Core Strategy Policy 8 Sustainable design and construction and energy efficiency (2011).

11. Site Wide CHP Details

(a) No development shall commence until details of the proposed heat networks and Combined Heat and Power (CHP) system set out in the applicant’s Energy and Sustainability Statements hereby approved have been submitted to and approved in writing by the local planning authority.

(b) The details shall include the commissioning of the networks and CHP system and details of the catalytic converter if required.

(c) The networks and systems shall be provided in accordance with the approved details and maintained thereafter.

Reason: To comply with Policies 5.1 Climate change and mitigation, 5.2 Minimising carbon dioxide emissions, 5.3 Sustainable design and construction, 5.5 Decentralised energy networks and 5.7 Renewable energy in the London Plan (2015) and Core Strategy Policy 7 Climate change and adapting to the effects and Core Strategy Policy 8 Sustainable design and construction and energy efficiency (2011).

12. Site LevelsNo development shall commence on site until the following information has been submitted to and approved in writing by the local planning authority:

(a) A full site survey showing: the datum used to calibrate the site levels along all site boundaries, ground levels across the site at regular intervals, levels across the landscape podiums at regular intervals, floor levels of adjoining buildings, ground

floor levels of the adjacent public open space, full details of the proposed finished ground floor levels and finished floor levels of all buildings and hard surfaces.

(b) The development shall be carried out only in accordance with the approved details.

Reason: Because of the topography of the site and the extent of re-grading required to implement the development hereby approved it is necessary to ensure that the local planning authority are satisfied as to the detailed relationship between ground floor levels on this site in relation to adjacent land and to the external appearance of the development in relation to its surroundings and to comply with Policy 15 High quality design for Lewisham of the Core Strategy (June 2011) and Saved Policy URB 3 Urban Design in the Unitary Development Plan (July 2004).

13. Surface Water(a) Surface water discharge from the development hereby approved to public sewer

system shall not exceed 5.0 L/s.

(b) No infiltration of surface water drainage into the ground is permitted other than with consent of the local planning authority.

(c) No development shall commence on site until a scheme for surface water management, including specifications of the surface treatments and sustainable urban drainage solutions and an assessment of hydrological and hydro geological context has been submitted to and approved in writing by the local planning authority.

(d) The development shall be carried out in accordance with the approved scheme and thereafter the approved scheme is to be retained in accordance with the details approved therein.

Reason: To prevent the increased risk of flooding and to improve water quality in accordance with Policies 5.12 Flood risk management and 5.13 Sustainable drainage in the London Plan (July 2011) and Objective 6: Flood risk reduction and water management and Core Strategy Policy 10:Managing and reducing the risk of flooding (2011).

14. Piling Operations(a) No piling or any other foundation designs using penetrative methods shall take place, other than with the prior written approval of the local planning authority.

(b) Details of any such operations must be submitted to and approved in writing by the local planning authority prior to commencement of development on site and shall be accompanied by details of the relevant penetrative methods including the methodology by which such piling will be carried out, measures to prevent and minimise the potential for damage to subsurface water infrastructure, and the programme for the works

(c) Any such work shall be carried out only in accordance with the details approved under part (b).

Reason: To prevent pollution of controlled waters and to comply with Core Strategy (2011) Policy 11 River and waterways network and Development Management Local Plan (November 2014) DM Policy 28 Contaminated land.

15. Materials/Design Quality(a) No development shall commence on site until a detailed schedule and samples of all

external materials and finishes, windows and external doors to be used on the buildings (in accordance with the principles set out in the Design and Access Statement and plans hereby approved) have been submitted to and approved in writing by the local planning authority.

(b) For the avoidance of doubt, if the proposed bricks stated within the approved Design and Access Statement are not available only bricks of similar texture and colour and equal quality will be acceptable.

(c) The development shall be carried out in strict accordance with the approved details.

Reason: To ensure that the local planning authority may be satisfied as to the external appearance of the building(s) and to comply with Policy 15 High quality design for Lewisham of the Core Strategy (June 2011) and Development Management Local Plan (November 2014) DM Policy 30 Urban design and local character.

16. Air Quality Assessment (a) No development shall commence until an Air Quality Assessment using the modelling approach outlined in Chapter 07 of the Environmental Statement and Addendum hereby approved has been submitted to and approved in writing by the local planning authority. The assessment shall include full details of the abatement technology utilised to minimise emissions to air from the CHP and boiler plant.

(b) The Air Quality Assessment will need to utilise an appropriate air quality model and/or emissions assessment tool to predict air quality concentrations at agreed receptor locations. Data should be presented for the first year of occupation as ‘with development’ and ‘without development’ to allow comparisons to be made.

(c) The CHP and associated abatement shall be installed in accordance with the approved details prior to occupation of the development and shall thereafter be permanently maintained in accordance with the approved specification.

Reason: To improve air quality in the interest of safeguarding the health of the local population and to protect the amenities of adjoining premises in accordance with Policy 7.14 Improving air quality of the London Plan (2011), Policy 7 Climate change and adapting to the effects and Policy 9 Improving local air quality of the Core Strategy (June 2011) and to comply with Development Management Local Plan (November 2014) DM Policy 23 Air quality.

17. Archaeology A) No development other than demolition to existing ground level shall take place until the applicant (or their heirs and successors in title) has secured the implementation of a programme of geo-archaeological assessment and potentially borehole survey work plus possible mitigation strategy in accordance with a Written Scheme of Investigation and a report on that evaluation to be submitted to and approved in writing by the local planning authority.

B) Under Part A, the applicant (or their heirs and successors in title) shall implement a programme of archaeological investigation in accordance with a Written Scheme of Investigation.

C) The development shall not be occupied until the site investigation and post investigation assessment has been completed in accordance with the programme set out in the Written Scheme of Investigation approved under Part (A), and the provision for analysis, publication and dissemination of the results and archive deposition has been secured.

Reason: Heritage assets of archaeological interest may survive on the site. The planning authority wishes to secure the provision of appropriate archaeological investigation, including the publication of results, in accordance with Section 12 of the NPPF (2012).

Prior to Above Ground Works Conditions

18. Landscaping for Block B Podium

(a) A scheme of landscaping for the communal podium in Block B (including details of any hard surfaces, proposed plant numbers, species, location and size of trees and tree pits, furniture and lighting and finished levels related to AOD) and details of the management and maintenance of the landscaping for a period of five years shall be submitted to and approved in writing by the local planning authority prior to construction of any above ground works.

(b) The approved landscaping scheme shall be implemented in full and all planting, seeding or turfing shall be carried out in the first planting and seeding seasons following the completion of the development, in accordance with the approved scheme under part (a). Any trees or plants which within a period of five years from the 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.

Reason: In order that the local planning authority may be satisfied as to the details of the proposal and to comply with Core Strategy Policy 12 Open space and environmental assets, Policy 15 High quality design for Lewisham of the Core Strategy (June 2011) and Development Management Local Plan (November 2014) Policy 25 Landscaping and trees, and DM Policy 30 Urban design and local character.

12. Boundary Treatment(a) Details of proposed boundary treatments including any gates, walls or fences shall be submitted to and approved in writing by the local planning authority prior to construction of the above ground works.

(b) The approved boundary treatments shall be implemented prior to occupation of the buildings and retained in perpetuity.

Reason: To ensure that the boundary treatment is of adequate design in the interests of visual and residential amenity and to comply with Policy 15 High quality design for Lewisham of the Core Strategy (June 2011) and DM Policy 30 Urban design and local character of the Development Management Local Plan (November 2014).

13. Bird/Bat Boxes(i) An Ecological Enhancement and Management Plan including details of the number and location of bird and bat boxes to be provided as part of the development hereby approved shall be submitted to and approved in writing by the local planning authority prior to commencement of above ground works. (ii) The development shall be implemented in accordance with the details approved under part (i).

Reason: To comply with Policy 7.19 Biodiversity and access to nature conservation in the London Plan (2015), Policy 12 Open space and environmental assets of the Core Strategy (June 2011), and DM Policy 24 Biodiversity, living roofs and artificial playing pitches and local character of the Development Management Local Plan (November 2014).

14. Electric Vehicle Charging Points(a) A minimum of 17 of the car parking spaces hereby approved shall be fitted with electric vehicle charging points. Details of the location of the electric vehicle charging points and a programme for their installation and maintenance shall be submitted to and

approved in writing by the local planning authority prior to construction of the above ground works.

(b) The electric vehicle charging points as approved shall be installed prior to occupation of the Development and shall thereafter be retained and maintained in accordance with the details approved under (a).

Reason: To reduce pollution emissions in an Area Quality Management Area in accordance with Policy 7.14 Improving air quality in the London Plan (July 2011), and DM Policy 29 Car parking of the Development Management Local Plan (November 2014).

Prior to Occupation Conditions

15. Living Roofs

(a) The development shall be constructed with biodiverse living roofs laid out in accordance with Drawing No. PL.108.A and the Landscape Illustrative Material and Landscape Management Plan (prepared by First Environment Ltd) hereby approved and maintained thereafter.

(b) The living roofs shall not be used as an amenity or sitting out space of any kind whatsoever and shall only be used in the case of essential maintenance or repair, or escape in case of emergency.

(c) Evidence that the roofs have been installed in accordance with (a) shall be submitted to and approved in writing by the local planning authority prior to the first occupation of the development hereby approved.

Reason: To comply with Policies 5.10 Urban greening, 5.11 Green roofs and development site environs, 5.12 Flood risk management, 5.13 Sustainable Drainage and 7.19 Biodiversity and access to nature conservation in the London Plan (2015) and Core Strategy Policy 10 managing and reducing flood risk and Core Strategy Policy 12 Open space and environmental assets.

16. Ventilation Equipment for A3 Uses(a) For any commercial unit intended to be operated as an A3 Use, detailed plans and a specification of the appearance of and the equipment comprising a ventilation system which shall include measures to alleviate noise, vibration, fumes and odours (and incorporating active carbon filters, silencer(s) and anti-vibration mountings where necessary) shall be submitted to and approved in writing by the local planning authority.

(b) The ventilation system shall be installed in accordance with the approved plans and specification before any A3 use first commences and shall thereafter be permanently maintained in accordance with the approved specification.

Reason: In order that the local planning authority may be satisfied that the lighting is installed and maintained in a manner which will minimise possible light pollution to the night sky and neighbouring properties and to comply with DM Policy 27 Lighting of the Development Management Local Plan (November 2014).

17. External Lighting(a) Prior to occupation of the development hereby approved a scheme for any external lighting that is to be installed at the site, including measures to prevent light spillage shall be submitted to and approved in writing by the local planning authority.

(b) Any such external lighting as approved under part (a) shall be installed in accordance with the approved drawings and such directional hoods shall be retained permanently.

(c) The applicant should demonstrate that the proposed lighting is the minimum needed for security and working purposes and that the proposals minimise pollution from glare and spillage.

Reason: In order that the local planning authority may be satisfied that the lighting is installed and maintained in a manner which will minimise possible light pollution to the night sky and neighbouring properties and to comply with DM Policy 27 Lighting of the Development Management Local Plan (November 2014).

18. Delivery and Servicing Plan(a) The development hereby approved shall not be occupied until a Delivery and Servicing Plan has been submitted to and approved in writing by the local planning authority.

(b) The plan shall include details of refuse and recycling collection arrangements for the commercial and residential elements, any on site or off site servicing bays and shall demonstrate the expected number and time of delivery and servicing trips to the site, with the aim of reducing the impact of servicing activity.

(c) The approved Delivery and Servicing Plan shall be implemented in full accordance with the approved details from the first occupation of the development and shall be adhered to in perpetuity.

Reason: In order to ensure satisfactory vehicle management and to comply with Policy 14 Sustainable movement and transport of the Core Strategy (June 2011).

Conditions which do not require details to be submitted

19. Refuse Storage The on-site storage facilities for refuse and recycling within each building, as shown on the plans hereby approved shall be carried out in full prior to occupation of any unit within the relevant building and shall be retained thereafter.

Reason: In order that the local planning authority may be satisfied with the provisions for recycling facilities and refuse disposal, storage and collection, in the interest of safeguarding the amenities of neighbouring occupiers and the area in general, in compliance Core Strategy Policy 13 Addressing Lewisham waste management requirements (2011).

20. Implementation of Landscaping Scheme for the Homezone and Block A Podium

(a) The landscaping proposals hereby approved for the Homezone and Block A Podium shall be implemented in full and all planting, seeding or turfing comprised in the landscaping scheme shall be carried out in the first planting and seeding seasons following the occupation of the buildings or the completion of the development, whichever is the sooner.

(b) The landscaping shall be managed and maintained in full accordance with the documents hereby approved.

(c) Any trees or plants which within a period of 5 years from the 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.

Reason: In order that the local planning authority may be satisfied as to the details of the proposal and to comply with Core Strategy Policy 12 Open space and environmental assets, Policy 15 High quality design for Lewisham of the Core Strategy (June 2011) and DM Policy 25 Landscaping and trees and DM Policy 30 Urban design and local character of the Development Management Local Plan (November 2014).

21. Lifetime Homes Each of the dwellings shall meet Lifetime Home Standards (in accordance with the 2010 (Revised) document) as shown on drawing nos. 990.PL.405, 406, 407, 408, 409, 410, 411, 412, 413, 414, 415, 416, 417, 418, 419, 420, 421, 422, 423, 426, 427, 428, 429, 430, 431, 432, 433, 434, 436, 437, 438, 439, 440, 441, 443, 445, 447, 448, 449, 451, 452 and 453 hereby approved.

Reason: In order to ensure an adequate supply of accessible housing in the Borough in accordance with Policy 1 Housing provision, mix and affordability and Policy 15 High quality design for Lewisham of the Core Strategy (June 2011) and DM Policy 32 Housing design, layout and space standards of the Development Management Local Plan (November 2014).

22. Satellite DishesNotwithstanding the Town and Country Planning (General Permitted Development) Order 1995 (or any Order revoking, re-enacting or modifying that Order), no satellite dishes shall be installed on the street facing elevations or the roof of the building without planning permission first being obtained.

Reason: In order that the local planning authority may be satisfied with the details of the proposal and to accord with Policy 15 High quality design for Lewisham of the Core Strategy (June 2011) and DM Policy 30 Urban design and local character of the Development Management Local Plan (November 2014).

23. Plumbing or PipesNotwithstanding the Town and Country Planning (General Permitted Development) Order 1995 (or any Order revoking, re-enacting or modifying that Order), no plumbing or pipes, including rainwater pipes, shall be fixed on the external elevations of the buildings hereby approved.

Reason: It is considered that such plumbing or pipes would seriously detract from the appearance of the building(s) and to comply with Policy 15 High quality design for Lewisham of the Core Strategy (June 2011) and DM Policy 30 Urban design and local character of the Development Management Local Plan (November 2014).

24. Construction Deliveries and Hours of Worka) No deliveries in connection with construction works shall be taken at or

despatched from the site other than between the hours of 8 am and 6 pm on Mondays to Fridays and 8 am and 1 pm on Saturdays and not at all on Sundays or Public Holidays.

b) No construction work shall take place on the site other than between the hours of 8 am and 6 pm on Mondays to Fridays and 8 am and 1 pm on Saturdays and not at all on Sundays or Public Holidays.

Reason: In order to safeguard the amenities of adjoining occupants at unsociable periods and to comply with Paragraph 120 of the National Planning Policy Framework

and DM Policy 26 Noise and Vibration, and DM Policy 32 Housing design, layout and space standards of the Development Management Local Plan (November 2014).

25. Restriction on Commercial ActivityNo process shall be carried on nor machinery installed which could not be carried on or installed in any residential area without detriment to the amenity of that area by reason of noise, vibration, smell, fumes, smoke, soot, ash, dust or grit.

Reason: To safeguard the amenities of the adjoining premises and the area generally and to comply with Paragraph 120 of the National Planning Policy Framework and DM Policy 26 Noise and vibration of the Development Management Local Plan (November 2014).

26. Restricting A3 Use to Prevent Take Away Use Notwithstanding the Town and Country Planning (General Permitted Development) Order 1995 (or any Order revoking, re-enacting or modifying that Order), and the provisions of the Town and Country Planning (Use Classes) Order 1987, (or any Order revoking and re-enacting that Order), any A3 use of the commercial units hereby approved shall not include the provision of hot food take-away or home delivery service.

Reason: To ensure that the use does not result in parking and congestion in surrounding streets, to safeguard the amenities of adjacent premises and to comply with DM Policy 18 Hot food take-away shops (A5 uses) of the Development Management Local Plan (November 2014).

27. Commercial Hours of UseAny A1, A2, A3 or B1 use within the site shall not be open to the public other than between the hours of 8 am and 11 pm on any day of the week.

Reason: To ensure that the development does not prejudice the enjoyment by neighbouring occupiers of their properties and to comply with Policies ENV.PRO 11 Noise Generating Development and HSG 4 Residential Amenity in the adopted Unitary Development Plan (July 2004)

28. Commercial Hours of UseAny D2 use within the site shall not be open to the public other than between the hours of 6 am and 11 pm on any day of the week.

Reason: To safeguard the amenities of the adjoining premises and the area generally and to comply with Paragraph 120 of the National Planning Policy Framework and DM Policy 26 Noise and Vibration and DM Policy 32 Housing design, layout and space standards of the Development Management Local Plan (November 2014).

29. Commercial Delivery HoursNo deliveries shall be made to any A1, A2, A3, B1 or D2 use within the site other than between the hours of 7 am and 11 pm on Mondays to Fridays, 7 am to 7 pm on Saturdays and 7 am to 5 pm on Sundays and Bank Holidays.

Reason: To safeguard the amenities of the adjoining premises and the area generally and to comply with Paragraph 120 of the National Planning Policy Framework and DM Policy 26 Noise and vibration of the Development Management Local Plan (November 2014).

30. Restriction of A1 FloorspaceNotwithstanding the Town and Country Planning (Use Classes) Order 1987 (or in any provision equivalent to that Class in any statutory instrument revoking and re-enacting

that Order with or without modification) the total provision of retail floorspace (Use Class A1) within the development hereby approved shall not exceed 350 square metres (GIA) at any time.

Reason: To accord with the retail impact assessment submitted as part of the economic regeneration statement hereby approved and to ensure that the amount of A1 floorspace provided at the site does not adversely affect the viability and vitality of existing town and district centres, and to comply with DM Policy 13 Location of Town Centres of the Development Management Local Plan (November 2014) and Policies 4.7 Retail and Town Centre Development and 4.8 Supporting a Successful and Diverse Retail Sector in the London Plan (July 2015).

31. Restriction of A2 UsesNotwithstanding the Town and Country Planning (Use Classes) Order 1987 (or in any provision equivalent to that Class in any statutory instrument revoking and re-enacting that Order with or without modification) the commercial units identified as Units 2, 3 and 4 in the plans hereby approved shall be used for any purpose within Classes A1, A2, A3, B1 and D2 of the Schedule to the Town and Country Planning (Use Classes) Order 1987 other than as a betting office (A2).

Reason: To accord with the retail impact assessment submitted as part of the economic regeneration statement hereby approved and to ensure that the amount of A1 floorspace provided at the site does not adversely affect the viability and vitality of existing town and district centres, and to comply with DM Policy 13 Location of Town Centres of the Development Management Local Plan (November 2014) and Policies 4.7 Retail and Town Centre Development and 4.8 Supporting a Successful and Diverse Retail Sector in the London Plan (July 2015).

32. Restriction of Commercial Unit 1Notwithstanding the Town and Country Planning (Use Classes) Order 1987 (or in any provision equivalent to that Class in any statutory instrument revoking and re-enacting that Order with or without modification) the commercial unit identified as Unit 1 in the plans hereby approved shall only be used for a purpose falling within Use Class B1 or D2 of the Schedule to the Town and Country Planning (Use Classes) Order 1987. Any other use of the premises shall be subject to planning permission first being obtained.

Reason: In accordance with the development as applied for and to ensure that if the largest commercial unit hereby approved is not occupied as a D2 use it shall revert to B1 Use in the interests of protecting employment use on the site in accordance with Core Strategy Policy 4: Mixed Use Employment Locations and Strategic Site Allocation 5: Plough Way of the Core Strategy (July 2011). .

33. Flood RiskThe development hereby approved shall be carried out in full accordance with the Flood Risk Assessment (FRA) prepared by Cole Eason Consultants Ltd (dated December 2013) and attached to the Environmental Statement, Volume 4, Technical Appendices, Part 3 hereby approved. The development shall comply with the following mitigation measures:(i) Flood proofing measures as detailed on page 6 of the FRA(ii) Finished floor levels for sleeping accommodation shall be set no lower than 6.02m

above Ordnance Datum (AOD)

Reason: To ensure the development minimises risk associated with flooding in accordance with Policies 5.12 Flood risk management and 5.13 Sustainable drainage in the adopted London Plan (July 2015) and Objective 6: Flood risk reduction and water management and CS Policy 10:Managing and reducing the risk of flooding (LDF 2011)

34. Cycle Parking Provision(a) A minimum of 285 secure cycle parking spaces shall be provided within the

development as indicated on the plans hereby approved.

(b) All cycle parking spaces shall be provided and made available for use prior to occupation of the development and maintained thereafter.

Reason: In order to ensure adequate provision for cycle parking and to comply with Policy 14: Sustainable movement and transport of the Core Strategy (2011).

Informatives

1. Positive and Proactive StatementThe Council engages with all applicants in a positive and proactive way through specific pre-application enquiries and the detailed advice available on the Council’s website. On this particular application, a significant amount of pre application discussions took place and as a result of positive discussions that took place throughout the assessment of the application further information was submitted.

2. Commencement of Development

The applicant is advised that any works associated with the implementation of this permission (including the demolition of any existing buildings or structures) will constitute commencement of development. Further, all pre commencement conditions attached to this permission must be discharged, by way of a written approval in the form of an application to the Planning Authority, before any such works of demolition take place.

3. CIL Community Infrastructure Levy

You are advised that the application granted is subject to the Mayoral Community Infrastructure Levy (‘the CIL’). More information on the CIL is available at: - http://www.communities.gov.uk/publications/planningandbuilding/communityinfrastructurelevymay11 (Department of Communities and Local Government) and http://www.legislation.gov.uk/ukdsi/2010/9780111492390/contents

4. Site Contamination

The land contamination condition requirements apply to both whole site and phased developments. Where development is phased, no unit within a phase shall be occupied until a), b) and c) of the condition have been satisfied for that phase.

Applicants are advised to read ‘Contaminated Land Guide for Developers’(London Borough’s Publication 2003), on the Lewisham web page, before complying with the above condition. All of the above must be conducted in accordance with DEFRA and the Environment Agency's (EA) - Model Procedures for the Management of Land Contamination.

Applicants should also be aware of their responsibilities under Part IIA of the Environmental Protection Act 1990 to ensure that human health, controlled waters and ecological systems are protected from significant harm arising from contaminated land. Guidance therefore relating to their activities on site, should be obtained primarily by reference to DEFRA and EA publications.

5. Construction

You are advised that all construction work should be undertaken in accordance with the "London Borough of Lewisham Code of Practice for Control of Pollution and Noise from Demolition and Construction Sites" available on the Lewisham web page.

6. CEMP/Dust Minimisation

In preparing the scheme of dust minimisation as part of the CEMP, reference shall be made to the London Councils Best Practice Guide: The Control of Dust and Emissions from Construction and Demolition. All mitigation measures listed in the Guide appropriate to the size, scale and nature of the development will need to be included in the dust minimisation scheme.

7. Lighting Control

The assessment of the light spill and lux level at the window of the nearest residential premises shall follow the guidance provided in The Institution of Lighting Engineers, Guidance Notes for the Reduction of Obtrusive Light.

8. Street Naming & Numbering

The applicant be advised that the implementation of the proposal will require approval by the Council of a Street naming & Numbering application. Application forms are available on the Council's web site.

9. Fixed Plant and Operational Noise Control

Assessment of all sound insulation scheme should be carried out by a suitably qualified acoustic consultant.

10. Soundproofing Mixed Use Buildings or Where Commercial Adjoins Residential

The weighted standardised level difference (D’nT,W + Ctr) is quoted according to the relevant part of the BS EN ISO 717 series. To guarantee achieving this level of sound insulation, the applicant is advised to employ a reputable noise consultant details of which can be found on the Association of Noise Consultants website.

11. Legal Rights of Existing Tenant

You are advised that this permission must not be construed as overriding any legal rights which the existing tenant of the property may have.

12. Drainage

Where a developer proposes to discharge groundwater into a public sewer, a groundwater discharge permit will be required. Groundwater discharges typically result from construction site dewatering, deep excavations, basement infiltration, borehole installation, testing and site remediation. Groundwater permit enquiries should be directed to Thames Water’s Risk Management Team by telephoning 020 8507 4890 or by emailing wwqriskmanagement@thameswater.co.uk. Application forms should be completed on line via www.thameswater.co.uk/wastewaterquality. Any discharge made without a permit is deemed illegal and may result in prosecution under the provisions of the Water Industry Act 1991.

13. Drainage

Thames Water will aim to provide customers with a minimum pressure of 10m head (approx 1 bar) and a flow rate of 9 litres/minute at the point where it leaves Thames Waters pipes. The developer should take account of this minimum pressure in the design of the proposed development.

14. Piling

Piling has the potential to impact on local underground water utility infrastructure. The applicant is advised to contact Thames Water Developer Services on 0845 850 2777 to discuss the details of the piling method statement.