Committee STRATEGIC PLANNING COMMITTEE

Report Title CANNON WHARF BUSINESS CENTRE, 35 EVELYN STREET SE8 5RT

Ward Evelyn

Contributors Julia Robins

Class PART 1 Date: 23 JUNE 2011

Reg. Nos. DC/08/68523 as Revised Application dated 25.03.08 as revised on 29.06.09,

28.03.11, 15.04.11, 18.04.11 Applicant CgMs on behalf of London Business

Centres Proposal Demolition of existing buildings at

Cannon Wharf Business Centre, 35 Evelyn Street SE8 and construction of buildings 3 to 8 storeys plus two buildings 20 and 23 storeys in height, comprising 6,588m2 commercial space (Use Classes B1, A1, A2, A3, A5 & D1) and 696 residential units with on-site energy centre, 401 car parking spaces, cycle parking, and associated landscaping, with accesses onto Evelyn Street, Rainsborough Avenue and Yeoman Street.

Applicant's Plans and other documents submitted with the application 815_0010 E Application Boundary Plan 815_0020 B Site Survey 815_0503 M Site Plan 815_0100 P Ground Floor Plan 815_0101 N First Floor Plan 815_0102 N Second Floor Plan 815_0103 N Third Floor Plan 815_0104 N Fourth Floor Plan 815_0105 N Fifth Floor Plan 815_0106 N Sixth Floor Plan 815_0107 N Seventh Floor Plan 815_0108 M Eighth – Sixteenth Floor Plans 815_0117 M Seventeenth Floor Plan 815_0118 M Eighteenth Floor Plan 815_0119 M Nineteenth Floor Plan 815_0120 N Twentieth Floor Plan 815_0121 G Twenty-First Floor Plan 815_0122 G Twenty second Floor Plan

815_0123 G Roof Plan 815_0200 N Elevations 01 815_0201 M Elevation 02 815_0202 L Elevation 03 815_0203 K Elevation 04 815_0204 L Elevation 05 815_0205 L Elevation 06 815_0206 F Elevation 07 815_0207 J Elevation 08 Revised Planning Statement and Appendices (CgMs, March 2011) Revised Design and Access Statement (RMA Architects, March 2011) Revised Non Technical Summary (CgMs, April 2011) Updated Flood Risk Assessment (CgMs, June 2009) Revised Environmental Assessment: Text Only (CgMs, March 2011) including Transport Assessment (Colin Buchanan & Partners, updated March 2011) Revised Environmental Assessment: Technical Appendices Part 1 (CgMs, March 2011 BVP letter dated 1st June 2011, Appendix 64c dated 13th June 2011) Updated Baseline Ecological Evaluation (May 2011) Construction Ecological Management Plan: Draft Heads of Terms (May 2011) Planning Energy Statement (April 2011) Statement of Community Consultation and Appendices (CgMs, February 2008 and March 2010) Background Papers (1) Case File – DE/151/B/TP (2) Adopted Unitary Development Plan (July 2004) (3) Core Strategy (October 2010) (4) The London Plan (2004, consolidated with alterations 2008) (5) The London Plan (consultation draft replacement October 2009) (6) PPS 1: Delivering Sustainable Development (2005) (7) Planning and Climate Change – Supplement to PPS 1 (2007) (8) PPS 3: Housing (2006) (9) PPS 4: Planning for Sustainable Economic Growth (2009) (10) PPS 5: Planning for the Historic Environment (2010) (11) PPG 8: Telecommunications (2001) (12) PPS 9: Biodiversity and Geological Conservation (2005) (13) PPS 10: Planning for Sustainable Waste Management (2005) (14) PPG 13: Transport (2001) (15) PPG 17: Planning for Open Space, Sport and Recreation (2002) (16) PPS 22: Renewable Energy (2004) (17) Planning for Renewable Energy – A Companion Guide to PPS 22 (2004) (18) PPS 23: Planning and Pollution Control (2004) (19) PPG 24: Planning and Noise (1994) (20) PPS 25: Development and Flood Risk (2006) (21) Delivering Affordable Housing – Good Practice and Guidance (2006) (22) The Code for Sustainable Homes – Setting the Standard in Sustainability for

New Homes (2008) (23) Planning and Access for Disabled People – A Good Practice Guide (2003) (24) Circular 11/1995 – The Use of Conditions in Planning Permissions (25) Circular 02/1999 – Environmental Impact Assessment (26) Circular 05/2005 – Planning Obligations (27) Mayor of London’s Transport Strategy (2010)

(28) Mayor of London’s Housing Strategy (2010) (29) Mayor of London’s Air Quality Strategy – Cleaning London’s Air (2002) and

second draft Air Quality Strategy (2010) (30) Mayor of London’s Biodiversity Strategy (2002) (31) Mayor of London’s Energy Strategy (2004) and draft Climate Change Mitigation

and Energy Strategy (2010) (32) Mayor of London’s draft Water Strategy (2009) (33) Mayor of London’s Housing SPG (2005) and draft revised interim Housing SPG (2009) (34) Mayor of London’s Sustainable Design and Construction SPG (2006) (35) Mayor of London’s London View Management Framework Revised SPG (2010) (36) Mayor of London’s Accessible London SPG (2004) (37) Mayor of London’s Providing for Children and Young People’s Play and Informal

Recreation SPG (2008) (38) Mayor of London’s Planning for Equality and Diversity in London SPG (2007) (39) Mayor of London’s Economic Development Strategy for London (2010) (40) Mayor of London’s Industrial Capacity SPG (2008) (41) Living Roofs and Walls – Technical Report Supporting London Plan Policy (2008) (42) Mayor of London’s The Control of Dust and Emissions from Construction and

Demolition BPG (2006) (43) Mayor of London’s Wheelchair Accessible Housing BPG (2007) (44) Mayor of London’s Health Issues in Planning BPG (2007) (45) London Housing Design Guide Interim Edition (2010) (46) LB Lewisham Residential Development Standards SPD (2006) (47) Lewisham Housing Market Assessment 2007-8 (2009) (48) Lewisham Leisure and Open Space Study Final Report (2010) (49) By Design – Urban Design in the Planning System: Towards Better Practice (2000) (50) Urban Design Compendium (2000, 2007) (51) South East London Housing Partnership's Wheelchair Homes Design Guidelines

(2009) (52) Homes and Communities Agency’s Investment and Planning Obligations –

Responding to the Downturn Good Practice Note (2009) (53) Local meeting notes (May 2011) Zoning UDP – Defined Employment Area,

Thames Policy Area, Site of Nature Conservation Importance, Area of Archaeological Priority, Strategic Viewing Corridor and Strategic Wider Viewing Corridor

Core Strategy – Plough Way Strategic Site

Screening (13.02.07) The proposed development is EIA

development for the purposes of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999.

CONTENTS

1. INTRODUCTION

1.1 Background

1.2 Plough Way Strategic Site

2. APPLICATION SITE AND SURROUNDINGS

2.1 Site Description

2.2 The Surrounding Area

2.3 Relevant Planning History

3. PRESENT APPLICATION

3.1 Proposed Development

3.2 General Layout and Uses

3.3 Residential Accommodation

3.4 Non-Residential Uses

3.5 Open Space, Playspace and Landscaping

3.6 Parking and Movement

3.7 Servicing and Refuse

3.8 Highway Works

3.9 Implementation and Phasing

3.10 Application Documents

4 Environmental Impact Assessment (EIA)

4.1 EIA Screening Assessment

4.2 EIA Scoping Assessment

4.3 Environmental Statement (ES) Documents

5. CONSULTATION

5.1 Introduction

5.2 Consultation Process

5.3 Consultation Responses

5.4 Local Societies, Groups and Organisations

5.5 Statutory Agencies and Other Organisations

5.6 Internal Consultee Responses

6. PLANNING POLICIES AND GUIDANCE

6.1 Introduction

6.2 Planning Policy Guidance and Planning Policy Statements

6.3 London Plan

6.4 Adopted Unitary Development Plan

6.5 Local Development Framework

7. PLANNING CONSIDERATIONS

7.1 Introduction

7.2 Principle of Mixed-Use Development

7.3 Land Use: Employment

7.4 Land Use: Housing

7.5 Land Use: Retail

7.6 Design

7.7 Transport

7.8 Environmental Sustainability

7.9 Other Planning Considerations

8. ENVIRONMENTAL IMPACT ASSESSMENT

8.1 Introduction

8.2 Air Quality

8.3 Archaeology

8.4 Construction

8.5 Daylight and Sunlight

8.6 Ecology

8.7 Ground Conditions and Contamination (including Groundwater)

8.8 Micro-climate (Wind)

8.9 Noise and Vibration

8.10 Socio-economics

8.11 Telecommunications and Interference

8.12 Transport

8.13 Waste

8.14 Water Resources, Drainage and Flooding

8.15 Townscape and Visual

8.16 Cumulative Effects

8.17 Residual Effects

9. FINANCIAL VIABILITY AND DELIVERY

9.1 Introduction

9.2 Viability and Deliverability

10 CONSIDERATION OF OBJECTIONS

10.1 Introduction

10. LEGAL AGREEMENTS

11.1 Introduction

11.2 Planning Obligations (Section 106 Agreement)

12. CONCLUSIONS AND RECOMMENDATIONS

12.1 Introduction

12.2 Summary of Reasons for Grant of Planning Permission

12.3 Conditions

APPENDICES

1 Site Layout - Proposed

2 Map Showing Consultation Letter Distribution Area

3 Summary of Responses from Residents and Businesses

1. INTRODUCTION

1.1 Background

1.1.1 In March 2008 the Council received a detailed planning application made by

CgMs on behalf of London Business Centres for the comprehensive redevelopment of the Cannon Wharf site. The application was the subject of extensive consultation with local residents and businesses, statutory consultees, elected Members, CABE and the Council’s Design Panel and was the subject of a Stage 1 Report by the GLA.

1.1.2 Following lengthy discussions with the applicant regarding the form and

content of the application, revised application documents were submitted in

March 2011. The amended application incorporates a number of changes to the scale of development and use mix of the scheme that seek, in part, to address the issues raised by the Council and consultees and to achieve a financially viable scheme. The principal changes between 2008 and 2011 can be summarised as:

• Reduction in the number of dwellings from 756 to 696

• Reduction in residential car parking reduced from 484 to 401 spaces

• Reduction in the amount of commercial floorspace from 8,324m2 to 6,588m2

• Conversion of space above the Energy Centre from commercial to residential

• Reduction in affordable housing from 25% to 20% (by habitable room)

• Increase in quantum of green/brown roofs (from three blocks to all blocks other than the houses)

• Changes to the elevation of buildings, in particular the two tall buildings (Buildings B1 and C1) and massing and elevation of Block D1-D3

• Reduction in height of most of the medium rise blocks by 1-3 storeys

1.1.3 The proposed development (as amended) comprises 696 residential units and 6,588m2 of commercial space in a series of buildings ranging in height from 3 storey houses to 8 storey perimeter blocks and including two tall buildings (20 and 23 storeys).

1.1.4 Revised drawings and supporting documents including an amended

Environmental Statement (ES) were submitted on 28th March 2011 and have been the subject of consultation with statutory consultees and local residents. In addition a Local Meeting was held on 19th May 2011. This report considers the proposals (as amended) in the light of relevant planning policy and guidance, representations received and other material considerations, and makes recommendations on the determination of the application.

1.2 Plough Way Strategic Site

1.2.1 The application site forms part of the Plough Way Strategic Site designation

in the Core Strategy. An application for the mixed-use redevelopment of the adjacent Marine Wharf site, which also forms part of the Plough Way site, was reported to the Strategic Planning Committee in November 2010 where it was resolved to grant planning permission subject to conditions and a s.106 agreement. The s.106 agreement for that development is currently being finalised and the application is to be referred to the GLA for the Stage 2 report in the near future.

2. APPLICATION SITE AND SURROUNDINGS 2.1 Site Description 2.1.1 The application site is an irregular shape, bounded to the immediate north by

sites on Yeoman Street, to the east by the route of the former Grand Surrey Canal, to the south by a former railway embankment and to the west by

properties fronting Evelyn Street and in Acacia Close and Woodcroft Mews. Further to the north is the Iceland Wharf development, Greenland Dock and Surrey Quays in LB Southwark, and to the east is the Marine Wharf West site which is currently vacant. Beyond the railway embankment to the south is Rainsborough Avenue and the Pepys Estate.

2.1.2 The site comprises three main elements:

i) the Cannon Wharf Business Centre (a 2/3 storey former 1960’s

industrial laundry converted in 1990 into B1 offices, workshops and storage) comprising 5,240m2 of space (3,250m2 B1/Workshop units and 1,990m2 under croft storage (B8) units) and occupied by mainly local businesses providing employment for about 250 people. Access is from Evelyn Street and immediately to the east of the Business Centre is associated open car parking.

ii) the former Insulcrete works in the centre of the site with access off

Yeoman Street comprising 1,650m2 of mainly single storey low quality buildings and open storage/sheds (1,343m2).

iii) the former Salters Paper Mill on the eastern part of the site fronting the

route of the former canal occupied by a number of separate businesses dealing with clothes and mattress recycling, freight distribution, building material recycling and skip hire. The area comprises mainly open sided storage buildings (4,531m2), yard and 3 storey dilapidated office accommodation (338m2).

2.1.3 Vehicular access to the site is from Evelyn Street and Yeoman Street. Both

accesses are two-way. There are two gaps in the former railway embankment on the southern boundary of the site which allow access from the site to a route that runs parallel to Rainsborough Avenue and is separated from it by a 3m high brick wall. Some current occupiers of the site exit via this route. The route of the former canal runs north-south along the site’s eastern edge and is currently overgrown with no public access. Ground levels vary across the site, generally increasing by 1-1.5m from west to the east.

2.1.4 The applicant controls the freehold of the application site, excluding the

former canal. The application site area including the former canal is 3.58 hectares, and 3.01 hectares excluding the canal.

2.2 The Surrounding Area 2.2.1 The surrounding land uses on the western and southern side of the site are

residential, with industrial uses to the north and east including the cleared Marine Wharf West site and the Yeoman Street sites. The housing to the west and south comprises blocks of flats with Hazelwood House to the west (5 storeys) and blocks fronting Rainsborough Avenue on the Pepys Estate to the south (8 storeys). Housing immediately adjoining the site to the west also includes 2-3 storey 19th century terraced houses in Woodcroft Mews leading to a new small gated cul-de-sac of semi-detached dwellings, and a mix of houses and flats in Acacia Close. Further to the north east is the 8 storey Iceland Wharf development and further north are South Dock and the

15 storey Baltic Quay development. Further to the south are three towers ranging in height from 26 to 31 storeys.

2.2.2 The industrial sites to the north are currently open storage including a

builder’s yard/dept contained within dilapidated open sided buildings at 19 Yeoman Street and an office/warehouse and vehicle storage/maintenance opposite (also fronting Croft Road).

2.2.3 The topography of the surrounding area is generally flat with no significant

variations in ground levels however infilling of the route of the Grand Surrey Canal directly to the south east has raised ground levels above the level of the route of the canal within the application site.

2.2.4 The largest areas of public open space within 1km of the application site are

Deptford Park, Pepys Park and Southwark Park. In addition, there are smaller green spaces within the Pepys Estate.

2.2.5 The site is served by the 47, 188 and N47 along Evelyn Street and the 199

bus (and N1 night bus) along Plough Way. The nearest bus stop to the application site is located on Evelyn Street south of Bestwood Street and north of Rainsborough Avenue, and also on Plough Way just west of Yeoman Street. The nearest London Overground station is Surrey Quays with underground services further away at Canada Water on the Jubilee Line. The nearest mainline railway stations are some distance away at South Bermondsey and Deptford providing connections to south and central London and Kent. Commuter river bus services are available from Greenland Pier to the northeast of the application site, providing connections to central London to the west and Woolwich Arsenal to the east.

2.2.6 The majority of the site and surrounding area has a Public Transport

Accessibility Level (PTAL) rating of 3, 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. Evelyn Street has been identified as part of the London Mayor’s planned Cycle Superhighway.

2.2.7 The nearest district centre within the Borough is Deptford High Street

however the Surrey Quays Shopping Centre in LB Southwark (to the northwest) is closer.

Proposed Thames Tunnel

2.2.8 Thames Water is currently developing proposals for a new Thames Tunnel

(sewer) between Hammersmith and Abbey Mills or Beckton, and related surface development. Under the current proposals this tunnel would be either i) the connection tunnel running between Greenwich and King's Stairs Gardens (where a connection would be made with the Thames Tunnel if routed along Thames Water’s preferred Abbey Mills route), or ii) the Thames Tunnel itself if routed along the Rotherhithe route (which is not Thames Water's preferred route).

2.2.9 Thames Water have identified part of the Plough Way Strategic Site – the

Earl Pumping Station and adjacent land between Croft Street and Yeoman

Street immediately to the north of the application site – 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 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. The Council has objected to the Thames Water proposals.

2.2.10 As part of Thames Water’s proposals a new tunnel would pass beneath the

application site linking to the Greenwich Pumping Station and other interceptor sites in the wider area, however given the depth of the tunnel it is not anticipated that this would have implications on the proposed development at Cannon Wharf. The Cannon Wharf development would though locate new residential units (in Block J) adjacent to the land identified by Thames Water for its plant and ventilation system for the tunnel. The layout of Block J locates the access core (staircase and lift shaft) at the northern end of the building with no windows overlooking the Pumping Station site. As a consequence the proposals need not significantly affect the Council’s consideration or determination of the current application.

2.3 Relevant Planning History Application Site 2.3.1 The site has a long history of industrial use and development with a wide

range of buildings and uses permitted on different parts of the site. Perhaps most relevant is the Refusal of a Certificate of Lawful Use or Development in 1996 for the use of the site as a Waste Transfer Station. A current planning application (ref. DC/10/73735/X) for “Retention of the change of use from B8 to shop storage, vehicle storage, recycling of building materials, freight distribution and clothes and mattress recycling” is undetermined. This use has already commenced and is causing significant disturbance to local residents. Although a site where industrial uses are long-established the Council is considering appropriate action to address these concerns including, if expedient, the use of enforcement powers to control the use.

Adjacent Sites

2.3.2 Marine Wharf West (DC/10/73437, DC/10/73437A & DC/10/73437B) – located immediately to the east of the application site - the Council has resolved to grant detailed planning permission for 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 and new public open space along the route of the former Grand Surrey Canal. A s.106 agreement is currently being drafted and the application is due to be referred to the GLA for its Stage 2 assessment in the near future.

2.3.3 19 Yeoman Street (DC/10/75430) – Planning application for the demolition

of existing buildings and the erection of two buildings of 8 and 9 storeys to

provide 111 residential units and 949 square metres of commercial floorspace (Use Classes A3, B1 and D1). Application currently not validated.

3. CURRENT PLANNING APPLICATION

3.1 Proposed Development

3.1.1 The application is for detailed planning permission with no matters reserved. The development comprises 696 residential units and 6,588m2 of commercial space, with 401 car parking spaces (282 residential, 113 commercial and 6 car club) and 749 cycle parking spaces (696 residential and 53 commercial).

3.2 General Layout and Uses 3.2.1 The development of the site comprises four principal elements, linked by a

main ‘spine’ road that runs roughly west-east and south-north through the site with the turning point in the centre of the site marked by a square – see Appendix 1. Pedestrian routes continue towards the former canal to the east. A summary of the proposed floorspace and parking is set out below. The design and materials for the various buildings is provided in Section 7.1 of this report below.

3.2.2 The first element to the west of the site (where it abuts Hazelwood House

and backs on to the properties in Acacia Close/Woodcroft Mews) comprises Blocks E and F a series of 2-3 storey houses with larger (3-4 storey) buildings on the site access route. These houses face a taller stepped (5-7 storey) block of flats – Block D – along the southern boundary of the site adjacent to the former railway embankment. The southern block includes non-residential/commercial uses in the ground floor with parking accessed at the eastern edge of the site. Between the lower-rise houses to the north and the site access road is a children’s play area.

3.2.3 The 16 houses are a mix of 3 4 and 5 bed properties with private amenity

space. Two blocks of flats at the entrance to the mews will provide a total of 19 1, 2 and 3 bed units. The houses are arranged as a ‘mews’ (with courtyard parking for 24 cars) and a terrace forming the northern boundary of the site and facing onto the site access road and open space. Block D to the south of the site access road facing Blocks E and F provides 61 1, 2 and 3 bedroom flats with 16 car parking spaces in a covered car park accessed from the eastern end of the block. The ground floor comprises residential entrance cores and units providing 435m2 of commercial floorspace.

3.2.4 The second main element is a series of buildings along the western edge of

the south-north route that adjoin properties in Woodcroft Mews and Croft Street – Blocks G, H and J. These are 4-6 storeys in height, increasing in height away from the western site boundary and towards the northern boundary of the site. The lower floors are non-residential, predominately commercial including a proposed nursery, and the on-site energy centre located in the northernmost building. Parking is provided to the rear of these buildings.

3.2.5 These buildings will provide a total of 108 1 2 and 3 bedroom flats with ground floor units providing a total of 1,088m2 of commercial floorspace including a nursery (297m2) and A3 cafe/restaurant use (400m2). Parking in rear courts is intended for the commercial units only. The ground floor of Block J will accommodate the on-site energy centre.

3.2.6 The third element is the proposed new Cannon Wharf Business Centre –

Block A. This 6 storey building (plus semi-basement parking) forms the northern boundary of the site and would provide 4,083m2 of unrestricted B1 space. Adjoining this building to the east is a 6 storey residential block that fronts onto the former canal providing 33 1 and 2 bedroom flats. 32 parking spaces for the Business Centre are provided in a semi-basement of Block A.

3.2.7 The fourth element is two 7 storey perimeter blocks (including two tall

buildings 20 and 23 storeys in height) – Blocks B and C – which front onto the main south-north route through the site and onto the former canal to the east and the former railway embankment to the south. These blocks provide a total of 459 flats comprising a mix of studios 1 2 and 3 bed units and 3 bed duplex flats. Block B has two levels of parking and C one level of parking providing a total of 242 parking spaces. The ground floor space provides a total of 982m2 of commercial floorspace. The two tall buildings on the site are located at the southern end of the south-north route (visible also from the western site access onto Evelyn Street) and on the southern of the two west-east pedestrian routes.

3.2.8 A mix of hard and soft landscaping is provided within the site with a mix of

brown and green roofs providing additional habitat. Children’s play space is provided at ground level in front of the proposed houses (Block F) and within the communal amenity space within Blocks B and C.

3.3 Residential Accommodation 3.3.1 The proposed development would provide a total of 696 residential units of

which 117 are proposed to be affordable homes representing 83% private sale and 17% affordable by unit (80% private sale to 20% affordable by habitable room). The application states that 74% of the affordable housing would be shared ownership with the balance, 26%, described as ‘social rented’. Under recent Government announcements regarding affordable housing, ‘social rented’ housing (providing accommodation at target rents) is to be replaced with ‘affordable rent’ (with rental levels at up to 80% of market rents) however given the fact that the original application was submitted before these changes were announced and consultation responses have been on this basis, for consistency the term ‘social rented’ is used in this report. The social rented units would be provided within the houses (Block F) and the shared ownership units in Block E and the houses. The delivery of the affordable housing is not dependent on central government grant.

3.3.2 The detail of the proposed housing by unit size is summarised in the table

below.

Total

Flats Units Habitable Rooms

Studios 31 31

1-bed 265 530

2-bed 321 963

3-bed/Duplex 63 260

Houses

3-bed 5 15

4-bed 7 35

5-bed 4 24

Total 696 1,858

3.3.3 The affordable housing comprises:

Social Rented* Shared Ownership

Flats Units Habitable Rooms

Units Habitable Rooms

Studios

1-bed 30 60

2-bed 4 12 44 132

3-bed/Duplex 2 8 21 84

Houses

3-bed 5 20

4-bed 7 35

5-bed 4 24

Total 22 99 95 276

3.3.4 All units are designed to Lifetime Homes standard and 10% will be

wheelchair accessible or easily adaptable, designed to South East London Housing Partnership standards.

3.4 Non-Residential Uses 3.4.1 The application also includes a mix of non-residential space including B1

(business) A1, A2, A3, A5 (retail, professional services, restaurant/café and takeaway) and D1 (intended as a nursery). The majority of the B1 space is to be provided in Block A in the new Business Centre with other uses located in ground floor units along the main routes through the site.

3.5 Open Space, Playspace and Landscaping

3.5.1 The application site boundary includes the route of the former Grand Surrey

Canal, although this land is currently owned by a third party that also owns the Marine Wharf West site. The Cannon Wharf application proposes that the canal is landscaped to provide public open space, works that also form part of the planning application for the Marine Wharf West site. In the circumstances, should this area be landscaped as part of the Marine Wharf West development then the Cannon Wharf development would make a financial contribution, equivalent to the cost of these works, towards the landscaping of the canal to the south between the application site and Oxestalls Road.

3.5.2 Raised private communal podium gardens are proposed within the courtyard

blocks. These areas would feature hard and soft landscaping with further communal space proposed along the southern side of Block F. A variety of smaller private amenity spaces are proposed comprising roof terraces and small rear gardens to the houses, and private balconies and terraces to flats within the development. Shared surfaces, street trees and limited on-street parking is proposed within the site.

3.5.3 Living roofs would be provided on the majority of the larger buildings but not

on the houses.

3.5.4 A dedicated play space totalling 453m2 located close to the proposed houses (Block F) would be provided in Phase 7.

3.6 Parking and Movement 3.6.1 A total of 401 car parking spaces are proposed on the site, 282 residential

car parking spaces (at a ratio of 0.4 per unit), 113 commercial parking spaces plus 6 bays for a Car Club. Of these 401 spaces, 33 would be bays for disabled users (28 for the residential units and 5 for commercial uses).

3.6.2 A total of 39 motorcycle parking spaces are proposed with 28 for residential

units and 11 for the commercial space.

3.6.3 749 cycle parking spaces are proposed (696 for residents, 53 for the commercial uses. Most of this would be provided in dedicated indoor stores associated with the residential blocks B and C.

3.6.4 The main vehicle access into the site would utilise the existing access from

Evelyn Street and Yeoman Street. Vehicles entering the site from Evelyn Street (serving Blocks C, D, E, F, G and the houses) would exit via Rainsborough Avenue. Vehicles would use the (existing) eastern gap in the railway embankment and the western gap would be closed to vehicles. It is proposed that an existing 7-8m wide route adjacent to the former railway embankment and separated from Rainsborough Avenue by a 3m high wall would be retained but not used for vehicle traffic.

3.6.5 Vehicles entering the site from Yeoman Street (serving Blocks A, B, H and J)

would exit via Yeoman Street. Only refuse vehicles would be able to travel through the site between Evelyn Street and Yeoman Street. Goods vehicles serving the Business Centre would enter and exit the site via Yeoman Street.

3.7 Servicing and Refuse 3.7.1 A dedicated space for internal recyclable material storage is proposed for

the flats and wheeled bins provided for the houses. The application does not provide details of servicing and refuse collection arrangements for the residential units or commercial space however it notes that the Council offers door-to-door collection of waste and recyclables and it is anticipated that the commercial businesses will contract out refuse collection to private waste management companies or the Council.

3.8 Highways Works 3.8.1 The only junction highway works proposed are minor works to the

Rainsborough Avenue access arrangement to improve pedestrian and cyclist access to the site. The proposals include widening the existing footway provision and allowing for a contraflow cycle lane.

3.9 Implementation and Phasing 3.9.1 Section 8 of the ES sets out a construction programme for the proposed

development comprising 8 phases over a 6-7 year period. The construction sequence splits the site into two main phases; the Salters and Insulcrete sites on the northern/eastern half of the site followed by the Business Centre site on the west. Each main phase comprises a number of sub-phases.

3.9.2 Following site preparation, demolition and remediation of the Salters and

Insulcrete sites in the first 6 months, construction would commence on Block A (the new Business Centre) followed by buildings on the western side of the south-north access road (Blocks H and J) and then buildings along the eastern side of this road (Blocks B and C including the two tall buildings) but excluding the buildings fronting the canal and then Block G on the western side of the access road. This stage of the development is estimated to take 5 years from commencement.

3.9.3 The second main phase would involve the redevelopment of the existing

Business Centre site with site preparation, demolition and remediation preceding the construction of the flats to the south of the west-east access road (Block D) followed by the houses and flats to the north (Blocks E and F). The final stage of the construction comprises the residential blocks fronting onto the canal. The second main phase of the development would take around 1½ to 2 years to complete.

Phase Zone/Block Start (month)

End (month)

Duration (months)

Site Prep. / Demolition / Remediation

Salters / Insulcrete

1 6 6

Sub-structure Salters / Insulcrete

7 10 4

Phase 1 A 11 23 12

Phase 2 H & J 11 21 10

Phase 3A B2, B3, B4 22 34 12

Phase 3B B1 30 40 10

Phase 4A C2, C3 38 50 12

Phase 4B C1 45 60 15

Phase 5 G 50 60 10

Site Prep. / Demolition / Remediation

Existing Business Centre

45 46 2

Sub-structure Existing Business Centre

47 50 4

Phase 6 D 51 63 12

Phase 7 E, F, Houses 60 70 10

Phase 8 A, B5, C4 65 80 15

3.10 Application Documents 3.10.1 The planning application is accompanied by several supporting documents

including an Environmental Statement. Details of these are set out in the following paragraphs.

Planning Statement 3.10.2 The Revised Planning Statement (March 2011) describes the proposed

development, the site and its surroundings and the site’s history, and lists what the applicant considers to be the relevant national, regional and local planning policy context. The statement discusses relevant planning considerations and the merits of the proposed development against the identified planning policy context, drawing on the findings of the ES and other submission documents.

Design and Access Statement 3.10.3 A revised document was submitted in March 2011. This provides an

explanation of the design process leading to the proposed application including how the scheme has been amended in response to comments from the Council, Lewisham Design Panel and CABE. The document describes the design and materials of the various elements of the scheme and their rationale. It includes a summary of an assessment of the impact of the development on the protected view of St Paul’s Cathedral from Greenwich Park. The document also explains how the scheme will ensure mobility access within the site and the design standards that are to be committed to.

Planning Energy Statement

3.10.4 This report was fully revised in March 2011 setting out how the proposed

development responds to the Mayor of London’s energy hierarchy, and explores options for reducing CO2 emissions through energy efficiency measures, the use of heat and power generation, and the inclusion of renewable technologies.

3.10.5 The report estimates the proposed development would achieve a reduction

in CO2 emissions (compared with a baseline of the scheme built in compliance with Part L of the Building Regulations 2006) of 71% overall through a combination of building fabric specification, energy efficiency measures, a gas-fired CHP (combined heat and power) and use of photovoltaics. A commentary on a connection to SELCHP is also included.

3.10.6 The report confirms that all residential units will be designed and constructed

to meet the Code for Sustainable Homes (CfSH) Level 4 and the commercial space will achieve BREEAM ‘Excellent’.

Statement of Community Consultation 3.10.7 A report was submitted with the original application in March 2008 which

covered pre-submission consultation. A further document was submitted in March 2010 which reported on post-submission consultation events. Feedback on the pre- and post-submission consultation events is recorded. The applicant did not undertake further consultation on the amended (March 2011) scheme.

3.10.8 This consultation was separate from the Council’s own notification to local

residents of the application (April 2008) and the amendments (April 2011) and the Local Meeting held in May 2011.

4. Environmental Impact Assessment (EIA) 4.1 EIA Screening Assessment 4.1.1 The relevant regulations are the Town & Country Planning (Environmental

Impact Assessment) (England & Wales) Regulations 1999 (the Regulations), as amended by the Town and Country Planning (Environmental Impact Assessment) (Amendment) Regulations 2006, and the Town and Country Planning (Environmental Impact Assessment) (Amendment) Regulations 2008. Guidance on procedures under the Regulations was issued in DETR Circular 02/99, and the Government has also published a booklet entitled “Environmental Impact Assessment: A Guide to Procedures” (November 2000).

4.1.2 It is necessary for the Council to consider the proposals against the

Regulations and make its own conclusion as to whether or not an Environmental Impact Assessment (EIA) is required.

4.1.3 The Regulations identify two types of development projects: Schedule 1

developments, for which an EIA is mandatory, and Schedule 2 developments, for which EIA may be required. The proposed development at Cannon Wharf is not Schedule 1 development, but is a Schedule 2 development (under paragraph 10(b)), being an “urban development project” with a site area of more than 0.5 hectares. Determination of whether EIA is required is then based on a judgement as to whether the proposed Schedule 2 development is likely to have significant effects on the environment by virtue of factors such as its nature, size or location. When considering the characteristics of the proposed development regard should be had in particular to the size of the development and cumulatively with other development. In relation to location, the existing use of the land should be taken into account and the absorption capacity of the natural environment. Circular 02/1999 gives further guidance on when a Schedule 2 development requires EIA and advises that EIA will generally be needed in three main types of cases:

a) for major developments which are of more than local importance; b) for developments which are proposed for particular environmentally

sensitive or vulnerable locations; and c) for developments with unusually complex and potentially hazardous

environmental effects.

4.1.4 With regard to criteria (b), the site includes part of a Site of Nature

Conservation Importance, is located within the Thameside Policy Area and is entirely within an Area of Archaeological Priority defined in the Lewisham’s Adopted UDP. The north east area of the site falls within a Strategic Viewing Corridor (Greenwich Park to St Paul’s Cathedral) set out in the London Plan. The site does not include any listed buildings, is not within (and does not abut) a Conservation Area, and is located a significant distance from the nearest part of the Greenwich World Heritage Site. Paragraph 39 of Circular 02/99 states that “other statutory and non-statutory designations which are not included in the definition of 'sensitive areas', but which are nonetheless environmentally sensitive, may also be relevant in determining whether EIA is required”. In this case it is considered that, notwithstanding the designations outlined above the site has limited environmental sensitivity and vulnerability and that it does not constitute EIA development under criteria (b).

4.1.5 It is considered that the proposed development would not have unusually

complex and potentially hazardous environmental effects and accordingly it is considered that criteria (c) does not apply.

4.1.6 In terms of criteria (a) Paragraph 35 of Circular 02/1999 refers to the scale of

development having ‘wide-ranging environmental effects’. Further advice on the need for an EIA for an Urban Development Project is given at Annex A18 of the Circular. This states that in addition to the physical scale of such developments “particular consideration should be given to the potential increase in traffic, emissions and noise. EIA is unlikely to be required for the redevelopment of land unless the new development is on a significantly greater scale than the previous use, or the types of impact are of a markedly different nature or there is a high level of contamination.”

4.1.7 Notwithstanding the fact that the site has already been developed in the past

it is considered that given the location of the site, the mix of uses and scale of the proposed development and its potential for cumulative impacts with other development nearby, it is considered that the proposals are ‘major’ and of ‘more than local importance’. Accordingly EIA is required for the proposed development.

4.1.8 In such situations where EIA is required, the Regulations require submission

of an Environmental Statement (ES) to assess the likely significant environmental effects of a proposed development. Such a statement must provide an outline of any alternative sites/schemes which have been considered and the reasons for selecting the proposed development site. In terms of the effects of the scheme it must identify the baseline situation, the nature of the impact both direct and indirect, whether it is temporary (demolition and construction) or permanent (operation) and measures to mitigate the likely adverse impacts in each case and the residual effects after assumed mitigation. An EIA must also take account of relevant “committed schemes” to ensure that it assesses the likely significant cumulative impacts of proposed and committed schemes. Committed schemes are normally considered to be those that have planning permission, however, given current applications on other nearby Strategic Sites at Marine Wharf West (application ref: DC/10/73437), Oxestalls Road

(application ref: DC/09/73189) and Convoys Wharf (application ref: DC/02/52533) plus other major development sites in LB Southwark, it is appropriate that these are included in the assessment in accordance with Schedule 3 of the Regulations and paragraph 46 of Circular 02/1999).

4.1.9 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. "Environmental information" means the ES, including all of the ES volumes, any representations made by any consultee bodies and any representations made by any other person about the environmental effects of the proposed development, together with any further information requested from and/or provided by the applicant.

4.1.10 An ES was submitted with application and was amended and supplemented

in the light of consultation responses and the revised proposals. The Council appointed independent consultants (Capita Symonds) to provide advice on EIA issues and to help officers scrutinise technical material prepared by the applicant.

4.2 EIA Scoping Assessment

4.2.1 In November 2006 the applicant submitted a Screening and Scoping request

to the Council. This stated that, in their view, the need for an EIA was not clear cut and that as a very contained ‘backland’ site it was debatable whether the development was of more than local importance. Although described as a Scoping request the document did not provide any details on the likely significant effects of the proposed development or the scope of an EIA.

4.2.2 The Council responded in February 2007 with a Screening Opinion

confirming that an EIA was required as, in the Council’s opinion, the proposed development was of a significantly greater scale than the previous use of the site; that the types of impact that the proposed development may give rise to would be of a markedly different nature from those associated with the current use of the site; that given the site’s previous and existing industrial uses there was the potential for contamination; and that there was the potential for significant cumulative impacts with other development nearby. Accordingly it was considered that the proposals were ‘major’ and of ‘more than local importance’ and that the proposals constituted EIA development.

4.2.3 In February 2007 the Council also issued advice to the applicant on the likely

topics to be included in an ES listing the likely topics that needed to be addressed, and issues to be covered under each topic. These were: air quality, archaeology, ecology, ground conditions, noise and vibration, social and economic impacts, townscape and visual impact, transport, waste, water resources, drainage and flooding, cumulative effects, microclimate, daylight and sunlight, electronic interference.

4.2.4 The applicant subsequently submitted a formal Scoping Opinion request on

12 March 2007 setting out the proposed approach on each subject matter. The proposed development was described as having the potential to deliver approximately 730 residential units and approximately 9,450m2 of

commercial floorspace. A brief description was given of the proposed site layout but limited information was provided about building heights. In the light of the earlier advice on the likely scope of an EIA no formal Scoping Opinion was issued by the Council.

4.3 Environmental Statement (ES) Documents

4.3.1 The ES comprises a number of documents that have been revised and

updated following feedback from the Council and consultees on the content of the original ES and in the light of amendments to the proposed development. The documents listed below comprise those documents on which the application is to be determined and have been the subject of public consultation in accordance with the statutory requirements. The ES comprises the following volumes:

• Environmental Assessment (March 2008)

• Updated Flood Risk Assessment (CgMs, June 2009)

• Revised Non Technical Summary (CgMs, April 2011)

• Revised Environmental Assessment: Text Only (CgMs, March 2011) including Transport Assessment (Colin Buchanan & Partners, updated March 2011)

• Revised Environmental Assessment: Technical Appendices Part 1 (CgMs, March 2011 BVP letter dated 1st June 2011, Appendix 64c dated 13th June 2011)

4.3.2 A summary of the key findings of the applicant’s ES is set out below. This

describes the conclusions of the ES as presented by the applicant and does not represent the Council’s assessment of the document which are set out in Section 8 of this report and form an integral part of the Council’s consideration of the proposed development.

Environmental Statement Non Technical Summary

4.3.3 This report sets out a brief summary of the findings and content of the

Revised ES (March 2011). The document provides a description of the site and of the revised proposals. Following a brief summary of the site, proposals and legislative context the document summarises the environmental effects of the proposed development under each of the topic headings.

Revised Environmental Assessment: Main Text Only

4.3.4 This document provides detail of the site, its context and history (including

details of the main characteristics of the physical, natural and built environment of and surrounding the site), detail of the proposed development (including its phasing and construction) and sets out in detail the applicant’s findings in respect of the likely significant environmental impacts of the proposed development. The report also details the mitigation measures that the applicant proposes to adopt to avoid, reduce or control any significant impacts and the main resulting (or residual) impacts. Assessment methodologies used by the applicants are explained.

4.3.5 Sections 1-5 of the ES explain the regulations relevant to an ES, provide a description of the proposed development to be assessed, consider the main alternatives to the proposed development, outline the Screening and Scoping process, and the approach to significance criteria. Each relevant environmental impact topic is then addressed in chapters 6 to 19 of the ES (as revised) and are summarised below. The document also includes an assessment of the cumulative effects of the proposed development.

Air Quality

4.3.6 Chapter 6 of the ES describes baseline air quality at the site and identifies sensitive receptors (namely the members of the public who may be exposed to pollutants from the site and sensitive uses) and properties that are likely to be affected. Existing pollutant sources are identified and the site’s location in an Air Quality Management Area (AQMA) is noted. The ES focuses on pollutants NO2 and PM10.

4.3.7 The ES states that, with mitigation, residual effects of construction traffic will

keep the impacts of dust and emissions of PM10 to a minimum. In terms of the completed development, the ES notes that the development will introduce sensitive (residential) receptors into an AQMA and therefore air quality is a major consideration. Mitigation measures to reduce exposure include Travel Plans to reduce vehicle movements to/from the site and a financial contribution to the Council to support the implementation of its Air Quality Action Plan.

Archaeology 4.3.8 Chapter 7 of the ES notes the relevant policy designations and the proximity

of the site to heritage assets. The ES states that the site has been heavily truncated and contaminated and only a localised presence of peat deposits have survived and that, as a consequence, the site has a low palaeoenvironmental potential. The former 19th century buildings, their related industrial processes, the construction of the Surrey Canal and the associated timber pond (West Pond) have been assessed as being of local importance. Mitigation is proposed in the form of a detailed documentary record of the 19th century industrial features at the application site.

Construction

4.3.9 Chapter 8 of the ES sets out the construction programme for the development (over a 6 ½ year timescale) and the expected activities such as site preparation, demolition of existing structures and remediation, construction of substructure, construction of superstructure, fit-out and public realm works.

4.3.10 The ES notes the Council’s Code of Practice for the Control of Pollution and

Noise from Demolition and Construction Sites and proposes that the applicant develop and implement a Construction Environmental Management Plan (CEMP) to address environmental issues during the works. This will manage and minimise environmental impacts resulting from the demolition and construction works by specifying detailed working arrangements.

Daylight and Sunlight 4.3.11 The assessment of daylight and sunlight in Chapter 9 has been undertaken

in accordance with the BRE Report, “Site layout planning for daylight and sunlight. A guide to good practice” (1991) and BRE Information Paper IP3/87 on Solar Dazzle (glare) also forms the basis for part of the analysis.

4.3.12 The ES concludes that there will be a minor adverse impact on daylight. In

the case of sunlight, there are 2 windows in adjoining properties were an adverse impact as defined by BRE is identified. The applicant considers that shade will have a relatively neutral impact on neighbouring residential amenity space when compared to existing buildings. In terms of glare, due to the shape of the site layout, buildings and choice of materials, glare would have a negligible adverse effect. The ES concludes that no mitigation measures are required.

Ecology

4.3.13 Chapter 10 of the ES describes the existing ecological importance of the site and surrounding area. It notes that the most notable habitats are on the former railway embankment and the route of the former Grand Surrey Canal, both designated as a Site of Local Importance for Nature Conservation. It notes the rare or protected species in and around the site and that the development has the potential to provide habitat suitable for rare and protected flora and fauna.

4.3.14 In terms of mitigation the proposed CEMP will include measures relevant to

ecology – tree protection, measures to control dust, noise etc, and eradication of the Japanese knotweed found of the site as well as contingency procedures if protected species are found. The applicant concludes that following mitigation measures (namely green/brown roofs, tree planting, planting on podiums amenity areas and scrub removal) the effects of the proposed development would be positive. In terms of disturbance to birds, after mitigation a negligible effect is identified.

Ground Conditions and Contamination

4.3.15 Ground conditions and contamination is addressed in chapter 11 of the ES where the historic uses and existing ground conditions of the application site are described. The results of land gas monitoring and soil and groundwater quality assessments are discussed in detail.

4.3.16 Further investigation and assessment work is recommended by the applicant

to inform the detailed mitigation measures. Residual effects following mitigation are assessed as being negligible and that overall the final site conditions will represent an improvement on existing conditions.

Microclimate (Wind)

4.3.17 The micro-climatic effects of the proposed development are set out in chapter 12 of the ES. The March 2011 document sets out the findings of wind tunnel tests that supplement the assessment using computational fluid dynamics (CFD) in the original ES. The impacts of the proposed development have been assessed with and without the adjacent Marine Wharf West scheme for which there is a resolution to grant planning permission.

4.3.18 The ES states that the proposed development would have negligible to moderate beneficial effect on the local wind environment in most locations although there are 4 locations where the impact is minor to moderate adverse. Mitigation comprises planting, landscape enhancements and 2-2.5m high screening to increase shelter and reduce wind speed. In terms of residual impacts the impact is considered to be negligible to moderate beneficial when the mitigation measures are implemented.

Noise and Vibration

4.3.19 Chapter 13 describes the baseline noise levels with the existing dominant sources of noise (that would affect occupants of the proposed development) being from traffic on surrounding roads. The ES notes that the Salters Paper Mill site (which forms part of the application site) was vacant at the time of the baseline survey (in 2007).

4.3.20 During demolition and construction exceedance of certain noise criteria is

expected during noisier activities although with the adopted of mitigation measures the impact is expected to result in temporary minor adverse impact. In terms of the completed development the is assessed as falling within noise exposure category (NEC) B on the most exposed boundaries of the site with all remaining parts of the site falling within NEC A.

4.3.21 The applicant recommends that the development is constructed using

glazing and ventilation systems to meet specified acoustic performance to achieve an appropriate level of protection against noise. The applicant considers that existing residents adjacent to the site should experience an improvement in their noise environment compared to the potential impact from existing authorised industrial uses.

Socio-Economics

4.3.22 Chapter 14 of the ES examines the likely socio-economic effects of the proposed development. The ES estimates the population of the proposed development to be 1222 people (including 129 children). Existing facilities, population, housing, economic activity, education and skills, health, deprivation, crime and open space provision are described and the impact of the proposed development on each of these topics is assessed. The ES concludes that the effects of the proposed development are generally positive.

Telecommunications and Interference

4.3.23 Chapter 15 examines the impact on telecommunications interference. It notes that analogue television is the medium most susceptible to interference by structures. The proposed development will cast shadows on signals from the Crystal Palace and Croydon transmitters for approximately 2.9km to the north east however with the change over to digital the signal is expected to be turned off permanently by 2012. The ES concludes that with mitigation the impacts will be negligible.

Transport 4.3.24 Chapter 16 of the ES presents the findings of the Transport Assessment. It

notes relevant baseline data including existing movements associated with the site and predicts development generated trips and the impacts of these on different modes of transport. The assessment notes that the proposed

parking levels are in line with current standards. The ES concludes that the development proposes sufficient on site servicing and parking, and that the proposed site access and servicing strategy will simplify existing arrangements. Overall, the impact on surrounding roads is assessed as negligible.

Waste 4.3.25 Chapter 17 of the ES identifies the like waste arisings generated by the

proposed development during construction and operation. Mitigation measures aim to minimise the amount of waste generated during construction and by the proposed residential and commercial uses on completion of the development.

Water Resources, Drainage and Flooding 4.3.26 Chapter 18 of the ES sets out the legislative and policy background, site

conditions and potential sources of flooding. The ES includes a residual flood risk assessment covering extreme events and climate change, flood defence risk, flood defences, consequences of the failure of infrastructure, flood evacuation plan, flood warning and resilience. It concludes that the site is not deemed to be at significant risk of flooding, that safe access and egress from the site can be achieved, the proposed drainage strategy would not exacerbate flood risk and the effects of climate change will be mitigated by underground attenuation and above ground storage.

Groundwater 4.3.27 Chapter 18a covers geology, hydrogeology, hydrology, soil and groundwater

quality. The ES notes that in the northern part of the site there was a tar, pitch, naphtha and creosote works, that in the central area of the site there was a tar and whiting works and that there is also contamination in the eastern part of the site. The sensitivity of the groundwater is assessed as being high although with mitigation during the construction phase it would be low. The ES proposes mitigation in the form of soil removal and capping during the operational phase. In terms of residual effects the ES concludes that there will be a permanent, direct, long term effect on ground water post development of minor to moderate positive significance following the implementation of mitigation. The ES concludes that there will be no cumulative effects as a result of the development of the site.

Townscape and Visual

4.3.28 Chapter 19 of the ES provides separate assessments addressing the impact of the proposed development on specific townscape character areas, and on identified views. 72 views are photographed, and Verified Visually Montages have been prepared for 16 of these. The ES also includes consideration of the protected strategic view from Greenwich to St Paul’s Cathedral and concludes that there would be a minor-moderate impact as the development would be on the periphery of the view and the scale of impact would be low. The ES concludes that whilst the overall significance of these proposals is moderate the receptors are of high sensitivity but that the overall impact on the area would be beneficial.

Cumulative Effects 4.3.29 All of the ES topics listed above are considered together in Chapter 20. The

combined effects of individual impacts as well as the cumulative effects of

the construction and operation of the proposed development together with the other committed or proposed developments have been assessed. The ES concludes that the overall environmental impact would be major beneficial. The construction phase will be temporary with both beneficial and adverse effects. Both positive and negative effects are predicted at the operational phase.

Residual Effects

4.3.30 Chapter 21 of the ES provides a summary table of the residual impacts of the proposed development during the demolition/construction phase and for the completed/operational development taking account of the proposed mitigation.

Environmental Statement Volume 2: Technical Appendices 4.3.31 These appendices provide the detailed data, diagrams and other information

referred to in the main ES report, and include Daylight And Sunlight Analysis, Car Parking Strategy, Geo-Environmental Site Assessment, Micro-climate Assessment and Noise survey results.

5. CONSULTATION

5.1 Introduction 5.1.1 This section outlines the consultation carried out by the Council following the

submission of the application and amendments as required by the Council’s adopted Statement of Community Involvement. It summarises the consultation responses. Comments made in response to the proposals are referred to, where appropriate in Section 7 of this report and have been addressed by officers as an integral part of considering the merits of the proposals. In addition, Section 7 of this report responds to the key objections to the proposals.

5.1.2 In addition to carrying out consultation relating specifically to the Cannon

Wharf planning application, the Council organised a series of consultation workshops in October and December 2008 targeted at residents of the North Deptford area, local public and voluntary sector stakeholders, local businesses and young people, and it aimed to gather local views about potential major developments in North Deptford (including Cannon Wharf), as well as to reveal any significant planning issues which could be addressed by the Council. An exhibition relating to the future development of the north Deptford area was held at the Evelyn Children’s Centre on Grove Street in February 2010, and in March 2010 the Council distributed 8,000 letters informing residents and businesses of the various developments coming forward in the north Deptford area, and to update them on the “bigger picture”. A map of north Deptford was attached to this letter, outlining the location and main elements of the proposals for the Plough Way (including Cannon Wharf), Oxestalls Road and Convoys Wharf sites. A website dedicated to the projects in North Deptford has been maintained by the Council throughout the consultation period.

5.2 Consultation Process Statutory Advertisements

5.2.1 The original application was advertised in the press on 21st May 2008 (giving

21 days for the submission of representations), as an EIA application in accordance with the EIA Regulations, and as a departure from the provisions of the Unitary Development Plan.

5.2.2 Following the receipt of amended drawings and additional information in

March 2011, a second press notice was published on 6th April 2011 (giving 21 days for the submission of representations). The consultation period was extended to 7th May 2011 following receipt of the Environmental Impact Assessment Revised Non-Technical Summary on 15th April 2011.

Local Residents and Businesses

5.2.3 An extensive mailing exercise was undertaken in relation to the application

as originally submitted, with 3,000 letters hand-delivered to properties up to approximately 100 metres of the site as shown in Appendix 2. Letters dated 8th May 2008 were delivered on and before that date, and gave people at least 21 days to comment on the proposals. Following the receipt of amended drawings and additional information in March 2011, a second formal consultation exercise was undertaken, with 3,000 re-consultation letters dated 30th March 2011 being hand-delivered, giving people at least 21 days to comment on the proposals. As noted above the consultation period was extended to 7th May 2011.

5.2.4 People who objected to the proposed development in response to the

Council’s first and/or second round of consultation were invited to a local meeting held at the Cannon Wharf Business Centre on 19th May 2011.

5.2.5 Copies of all application documents were published on the Council’s

website.

Local Societies, Groups and Organisations

5.2.6 The following local societies and groups were consulted:

• Pepys Community Forum

Statutory Agencies and Organisations

5.2.7 The following statutory agencies and organisations were consulted:

• Commission for Architecture and the Built Environment

• Corporation of London

• Environment Agency

• Fire Prevention Group

• Greater London Authority

• Lewisham Primary Care Trust

• London Borough of Southwark

• London Borough of Greenwich

• London Borough of Tower Hamlets

• Natural England

• Metropolitan Police Crime Prevention Unit

• Metropolitan Police Property Services Department

• Natural England

• SUSTRANS

• Thames Water

• Transport for London Road Network Development (South)

Elected Representatives 5.2.8 The local MP and ward councillors were consulted.

5.3 Consultation Responses

Written Responses from Residents and Local Organisations

5.3.1 Written comments from were received from a total of 56 addresses in response to the initial consultation (2008) and reconsultation (2011). In total 34 written objections were received (including 4 which did not object to the principle of redevelopment but raised specific areas of concern) and 20 letters of support. 13 letters/emails of support were received from the 2011 reconsultation and 4 letters/emails of objection. In addition to site specific issues, some letters of objection included comments on the cumulative impacts that the development of the Strategic Sites in Deptford and New Cross (including the Cannon Wharf development) may have on the area.

5.3.2 2 petitions were received one from a resident in Pendennis House and from

the Pepys Community Forum in response to the original consultation with over 500 signatories. The petitions include a statement that objection is made on the following grounds:

• lack of consultation

• potential increase in traffic in Rainsborough Avenue and Evelyn Street and associated access and parking issues

• impact of tower blocks on residents owing to density and residential amenity, and on existing homes in Rainsborough Avenue due to loss of light and overshadowing

• existing GP practices will not be able to cope with the additional people

• demand for additional school places which cannot be met

• no confidence that the environmental impact proposed for this development and the impact on our overall quality of life has been fully considered as they have not been discussed with us

5.3.3 All letters received up to the time of writing have been recorded, and noted

below are the issues raised (ranked in order of the number of instances they occurred):

• Neighbour amenity loss of daylight, overshadowing, overlooking, loss of privacy (22)

• Transport, including parking (16)

• Building heights (16)

• Density (9)

• Design (7)

• Business issues (6)

• Environmental impacts (5)

• Impact during demolition and construction (4)

• Landscaping (4)

• Local facilities (3)

• Social Impacts (3)

• Tenure (2)

• Cumulative Impact (2)

• Wildlife (2)

• Land use (1)

• Effluent Waste (1)

• Objections to other development proposals (1)

• Other (3)

5.3.4 The individual issues and the Council’s response are summarised in Appendix 3.

5.3.5 As noted above, 20 letters were received in support of the proposed

development. A letter was also received from the owners of the adjoining Marine Wharf West site (including the route of the former canal supporting the principle of mixed use redevelopment and the appropriate mix and balance of uses but raising concerns about aspects of the scheme). These comments were made in response to the application documents in March 2008 since when an application to redevelop the Marine Wharf West site has been submitted and for which the Council has resolved to grant permission). The concerns of relevance to the current circumstances were:

• the design response fails to meet challenges of an awkwardly shaped site resulting in a loose urban grain with no central focus or hub. Proposed routes and networks do not adequately enhance permeability and legibility

• the route of Grand Surrey Canal is not under the control of the applicant but its delivery as a linear park is a key component of the submission with significant planning gain arising from the scheme for access and amenity space. As there is no mechanism in place for the applicant to deliver this element of the proposed scheme it should be presented as an aspiration only and should not form any calculations in regard to amenity or open space to justify density.

• the masterplan turns its back on the park and fails to properly front or enclose the space

5.3.6 Individual letters and e-mails are available to Members.

Local Meeting

5.3.7 Due to the level of response, in accordance with the Council’s Statement of

Community Involvement a local meeting was held on 19th May 2011. All those who had objected to the application (in response to either the first or second consultation exercise) were invited to the meeting, as were Ward Councillors. The public meeting was attended by 16-20 local residents and

was a drop-in session where Council officers and advisers and the representatives from the applicant’s team were present. The main points of objection raised were:

• Scale of buildings, particularly the tall buildings, and their impact on adjoining residential properties in terms of their height and overbearing form, loss of daylight/sunlight, overlooking, overshadowing

• Traffic impacts and lack of capacity on local roads to accommodate the development traffic, and impacts on Rainsborough Avenue

• Lack of affordable housing

• Poor quality of the architecture and concern at proposed materials

• Impact on local services and lack of available school places

5.4 Local Societies, Groups and Organisations

Pepys Community Forum 5.4.1 The key issues raised and the number of people who raised them:

• Traffic (6)

• Density (5)

• Pressure on local services (5)

• Overcrowding (4)

• Loss of light/privacy/overlooking (4)

• Building Heights (3)

• Visual impact (3)

• Views (2)

• Lack of consultation (1)

• Mobile phone coverage (1)

• Lack of green spaces (1)

• Other (4) The Tenants Action Group 5.4.2 TAG (representing tenants and residents on the Pepys estate) raise a

number of concerns about the statements made in the original 2008 application documents, challenging their validity and/or lack of evidence to substantiate them and highlighting contradictory aspects of the submission. In brief the following summarises the key issues raised:

• ES – townscape/visual assessment downplays impact of tower blocks given they are also described as “prominent … visible as markers to announce the scheme in this (current) back land location”.

• ES – little or no evidence produced to support assertions e.g. increased employment, a more balanced mix of public and private housing residential housing in Evelyn Ward, potential for community facilities like a Nursery School

• ES – “negligible effect on traffic in the area” not substantiated by surveys

• Community Consultation Focus Group comments (November 2005) appear to have a lot of common sense, yet have been ignored in the application

• Statement of Community Consultation – very limited consultation actually taking place with very low response rate and limited feedback

• Energy Statement – sustainable/renewable energy solutions appear to have been discounted, one by one and limited view taken on use of alternative energy sources is disturbing

• Design – overall architectural style reminiscent of 1960’s blocks and towers of flats that are now “out of favour”. Style looks like a scheme for a College campus or Civic centre, not a mixed use scheme related to the local context and to its community. The build has an oppressive feel with a very bland face/frontage to all buildings, a dull and grey scheme. Three high density ‘courtyard’ blocks” is medieval in layout concept, and is objected to as it mitigates against open access for all. There has been several, ongoing negative comments regarding the scheme from CABE and LBL Urban Design Panel

• Density – disturbing, as it lacks open spaces and permeability for new residents and the local community

• Scale – Eddystone Tower is atypical of the immediate area. Elsewhere the highest buildings are the 8 storey of Rainsborough Avenue, Pepys estate. The high towers present a dire presence and view for immediate neighbours, are ugly and unwanted and are objected to for being out of character to the surrounding site location and being too prominent for near neighbours and others. The view from Daubeny Tower will be impaired and loss of skyline in view from Carteret Way.

• Residential mix – predominance of one and two bed flats “dormitory housing to well-off city workers”

• Affordable Housing – only 35% not the 50% that the Mayor of London advocates under his Housing Policies

• Land-use mix – the site re-designation as mixed use from employment, as part of the LDF, has received objections from the GLA due to loss of strategic employment sites. Deptford / Lewisham is losing real designated local employment sites – which is a concern for the future.

• Surrey Canal – should stay as an enclosed facility owing to the contamination of the infill until a full redevelopment is funded to clean up the route of the Canal. The route of the canal has been identified as an important local habitat for wildlife with a variety of bird, plants and small mammals in the PCF commissioned Common Ground study which has been integrated in to the Lewisham Green Spaces strategy.

• There are no direct community benefits that are justifiably funded in the application

Canada Water Consultative Forum 5.4.3 Object on the following grounds:

• Statement of Community Consultation is wholly inadequate

• there is no affordable housing

• a business centre would exacerbate the already intolerable traffic congestion in the area

• there are no green or eco provisions in the proposal

• planned location is not suitable for development of this size

• no commercial units will be affordable

• scale will have detrimental impact on quality of life

• lack of proper long term traffic planning could lead to accidents

• 354 cycle spaces are proposed but where are the cycle routes

• the two access roads are small residential accesses and entirely unsuitable for the large volume of traffic a development of this size will generate

• there will be 30,000 new homes in Deptford and Rotherhithe in next few years and there are not proposals to improve the already serious transport problems

• proposals should only be considered once Southwark and Lewisham Councils have a clear plan to create a transport structure that works

Leaseholders and Tenants Association of Baltic Quay 5.4.4 Representing 163 flats the Association object on the following grounds:

• consultation process is flawed as insufficient people who will be affected have been notified

• residents Southwark adjoining Plough Way will be affected, overshadowed by the development with a loss of light and privacy and will experience noise disturbance and a change of their environment

• scale, height and proximity will have unacceptable adverse impact on residential amenity of residential occupiers

• unacceptably poor response to its context by a dominant relationship to existing buildings and fails to make a positive contribution to the environment

• exceeds density maximum

• extremely close to Greenland Dock and area of character and environmental importance in the Thames Special policy area where there are additional policy requirements to satisfy

• Development fails to comply with LB Southwark UDP policies which must be considered as the site bounds LB Southwark – 3.36 [not a Saved policy]; 3.13 (the development is not of high architectural design, could not be classified as a landmark building, makes no positive contribution to the area being of such a mass as to dominate the landscape and not in keeping); 3.20 (the building will be out of place and cause unpleasant environmental effects. The buildings are not located at a point of landmark significance to warrant such as development. Fail to relate well to their surroundings; 3.22 (it will damage views towards Greenwich and across the many docks in the area as well as changing the panorama of the dock area)

• consideration has not been taken of the adverse amenity affect i.e. the natural and physical qualities that make the environment pleasant and enjoyable and the harm to the environment through pollution and excessive consumption

• the tranquillity of the dock area will be lost as will vistas afforded across the same

• permission to change from light industrial to residential will result in noise from visitors, deliveries and waste collections

• height, bulk and silhouette of the development (massing) is huge – surrounding buildings are mainly 4-5 storeys

• contrary to London Plan policy 4C.23 (Docks) as scheme doesn’t protect or enhance character of the dock area

• the need for the development in an area which is already stretched in terms of school places, doctors and traffic

LB Southwark Councillors (01/07/08) 5.4.5 3 Councillors from Surrey Docks Ward in LB Southwark object on the

following grounds

• severe and inverse impact on transport infrastructure (local roads and public transport)

• severe impact on two strategic viewing corridors

• increased noise and air pollution

• loss of employment land and quality of environment for new residents

• concern at apparent lack of consultation on application in Southwark 5.5 Statutory Agencies and Organisations

Mayor of London (GLA including Transport for London – Stage 1 Report, 25/06/08)

5.5.1 The application is referable to the Mayor of London under Categories 1A

(“development which comprises or includes the provision of more that 150 houses, flats or houses and flats”), 1B (“development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings outside Central London and with a total floorspace of more than 15,000 square metres”), 1C (“development which comprises or includes the erection of a building of one or more of the following descriptions – the building is more than 30 metres high and is outside the City of London”) and 3E (“development which does not accord with one or more provisions of the development plan in force in the area in which the application site is situated; and comprises or includes the provision of more than 2,500 square metres of floorspace”) of the Schedule to The Town and Country Planning (Mayor of London) Order 2008.

5.5.2 The GLA Stage 1 report was prepared based on the original application and

a number of the comments made have been addressed in subsequent amendments to the application and/or supplementary information submitted by the applicant. The GLA were re-consulted on the amended proposals in April 2011 and their further observations in regard to the extent to which these changes have addressed their original comments are covered in Section 7 of this report. The following is a summary of the key points raised by the GLA in its Stage 1 report which was prepared based on the original 2008 application. Below that is a summary of the GLA’s second response which was made in response to the March 2011 revised submission.

5.5.3 The GLA considers that the applicant should provide additional detail on:

• layout and access to the lower grade commercial units

• the submitted Three Dragons toolkit

• the proposed cascade affordable housing offer

• a range of design amendments

• the impact of the scheme on strategic views

• the location and design of wheelchair accessible units

• the delivery of the Surrey Canal as a public open space

• a requirement to provide an off-site play space contribution

• transport measures

• energy and climate change adaptation measures

• the provision of local employment and training strategy

• further noise modelling work 5.5.4 The GLA concludes that subject to the Council’s demonstration that the

proposed loss of local employment land is justifiable then the principle of redevelopment is acceptable in strategic planning policy terms. This though is caveated as the GLA consider there are a number of issues that will need to be addressed to ensure that this application is in line with the policies of the London Plan.

5.5.5 Principle of mixed use development of a former industrial site – the GLA

notes that whilst The London Plan does not identify this site as Strategic Industrial Land, in releasing this land from its current designation the Council must be assured that this process is managed in accordance with the guidance set out in paragraphs 4.11 to 4.13 of the SPG 'Industrial Capacity'. The Council should take account local variations for demand across the borough and is encouraged to manage, and where possible, reconfigure its industrial portfolio. Any release of employment land should follow a comprehensive supply and demand and supply of existing provision.

5.5.6 Residential density – the scheme would give rise to 253 units per hectare

(672 habitable rooms per hectare). The London Plan density matrix table 3A.2 suggests a density of 70-170 units or 200-450 habitable rooms per hectare. The GLA notes that whilst it is not unusual to grant permission for developments that promote high density levels, they must not represent an overdevelopment of the site and the layout and design must achieve a high quality internal and external built environment, high quality public realm and communal amenity spaces with a range of transport improvements to accommodate the proposed density. The GLA request additional information to ensure that a high quality development is achieved.

5.5.7 Affordable housing (30% unit / 34.5% by habitable room and a 70: 30 social

rented: intermediate tenure split by unit) – the GLA notes that the results in the toolkit appraisal need to be independently verified and evidence provided of discussions with both the GLA and LPA to ensure that the applicant is securing the maximum level of grant. Should grant funding not be secured the proposed cascade tenure split (100% intermediate) is significantly lower than the London plan strategic target of providing 35% of affordable housing as social rented and 15% as intermediate. The applicant should also address the limited provision of larger family units.

5.5.8 Design (including tall buildings) – the block layout promotes a hierarchy of

public spaces across the site, culminating in a central square with commercial and active frontages facing directly onto this space. The central square helps to create a focal point for the development and the level of active frontage facing onto this space is welcomed. Varying building heights of five, eight and ten storeys surround this space and create an interesting local townscape. The proposed building block and open space arrangements respond positively to the context of the surrounding area and help to improve permeability of this site. The proposed towers will potentially act as catalysts for further regeneration where they are also acceptable in terms of design and impact on their surroundings. The proposed locations minimise impacts from overshadowing and loss of daylight for the remainder

of the residential units, courtyard spaces, play spaces and the central square. There are serious concerns that Block A (Business centre) has a ground floor made up solely of 32 car parking spaces with servicing space and the applicant should significantly increase the level of ground floor active frontage. The ground floor arrangement of Block D should be reconsidered (moving the commercial space to the front and the rearrangement of lift cores) as it currently comprises of refuse, cycle storage, and entrances to the residential lobbies.

5.5.9 Housing Mix – the application proposes a range of unit sizes and the units

achieve reasonable space standards for the private units and good space standards for the affordable housing units. It is welcome that the scheme does not include any single aspect north facing units. The proposed balcony sizes should be increased.

5.5.10 Canal – further detail on design and delivery of works to the Grand Surrey

Canal to provide a landscaped and accessible space is required. There are concerns with elements of the ground floor arrangement, particularly at the corner of blocks C3b and B1 that face onto the canal, which present inactive building corners at a key access point to the site. Further work should be undertaken to create stronger, accessible and active corners.

5.5.11 Strategic views – the application site is visible in two strategically identified

views from Greenwich Park as set out in the London View Management Framework. Regarding View SAl (from the General Wolfe Statue (at the orientation board) in Greenwich Park towards St. Paul's Cathedral and the Greenwich World Heritage Site) a telephoto view needs to be submitted to demonstrate the location of this site in relation to the geometrically defined assessment corridor. Regarding View SA2 (from the, General Wolfe Statue (north-east of the statue) towards St. Paul's Cathedral) a verified view and detailed assessment of this view should be provided as should a geometrically defined assessment and a qualitative visual assessment of this view.

5.5.12 Access – the commitment to deliver 100% of units to meet 'Lifetime Home'

standards and that 10% of residential units will be designed as wheelchair accessible units is noted. The scheme will be designed with level gradients throughout and sufficient lighting and way-finding signage will be provided across the site but further consideration must be given to the access arrangements for the entrances to blocks B3, C1 and C3b and information on existing and proposed pedestrian crossings to Deptford Park should be provided.

5.5.13 Play space – the development should make a total provision of

approximately 3,020m2 of play space which should take account for the varying play needs of children of different ages that will live in this development. The applicant should examine the potential to incorporate private garden spaces for ground floor residents within the courtyard podiums of block B and (to increase passive surveillance). The dedicated child play area of 453m2 is well located and well overlooked but further design detail is required.

5.5.14 Energy assessment and sustainable design and construction – the applicant must carry out modelling work for the commercial element and further detail on the energy efficiency measures and on how cooling measures will be provided for the commercial spaces and the consequent impacts on energy demand and carbon dioxide emissions are required in an appendix to the energy statement. The applicant has satisfactorily demonstrated that there is no potential to SELCHP and that the use of a tri-generation system on-site would be unfeasible. Additional detail is required on the heat network including information on the district-heating scheme is to be operated across the site. The applicant should examine the potential to further maximise the size of the proposed CHP, review the choice of technology currently being examined, fully optimise the size of the CHP before assessing the viability of renewable energy systems, analyse the sizing of the CHP and provide detail on how this system would be managed on-site in conjunction with the district heating network.

5.5.15 Renewable energy – the applicant is asked to examine the sizing of the

biomass boiler, including evaluating how it would operate with the CHP plant. The applicant should also review the potential to introduce additional renewable energy technologies.

5.5.16 Overheating – further detail needs to be provided to demonstrate what

measures are included within the scheme to reduce the impact of overheating for the single aspect south-facing units and on the energy efficient measures that will be incorporated into the scheme to reduce overall carbon dioxide emissions and energy demand.

5.5.17 Flood risk – the FRA is deficient in that it does not demonstrate how the

proposed buildings would be affected in the event of a flood. 5.5.18 Living roofs, sustainable drainage and water conservation – further details

should be provided on the location, type and quantum the green/brown roofs. Surface water attenuation measures should be secured by appropriate planning conditions.

5.5.19 Transport – TfL recommend that the parking level (0.54) should be reduced

given the congested nature of the adjacent Strategic Road Network, particularly during peak times. The proposed level of parking for the commercial aspect of the development exceeds London Plan standards and the applicant should demonstrate that this proposed level is justified. TfL questions the need for retaining the Rainsborough Avenue vehicle access point given that additional vehicles will need to turn right across Evelyn Street. The data presented for the business uses trip generation is 16 years old and more recent data is requested. TfL requests that a sensitivity test be undertaken to ensure that the trip generation presented as part of the report is robust. It is accepted that the development’s impact on the Strategic Road Network is likely to be low however the highway network is already congested and therefore new development should seek to limit potential traffic impact and encourage sustainable travel. Junction impact assessments carried out for all the nearby critical junctions other than the Evelyn Street junction with Plough Way should be submitted. Comprehensive details of the existing traffic conditions and operations on

both the local and strategic road network should be provided and junction models must be supported by a robust calibration and validation.

5.5.20 Transport (public transport and non-car modes) – the applicant is requested

to carry out a condition survey of all bus stops, and associated walking routes, located within a 400~metre radius of the site to enable TfL to identify the level of contributions required for those stops and walking routes. The proposal to widen the footway on Rainsborough Avenue to improve pedestrian access to the site is noted and supported. TfL requests confirmation that all footways in the vicinity of the site meet the 2m minimum width requirement. TfL seeks confirmation that the pedestrian crossings in the vicinity of the site serve pedestrian desire lines, comply with all relevant standards and are fully accessible to pedestrians with disabilities. The proposal to allow pedestrian and cycle access from the east of the site through the rejuvenation of the canal front is welcomed. Cycle parking for the residential element (at one space per unit) is acceptable. Cycle parking for the commercial aspect of the development also complies with TfL's cycle parking guidance and is welcomed. The proposal to provide a contra-flow cycle lane along Rainsborough Avenue in order to improve cycle access to the site and the provision of shower and changing facilities on site for employees cycling to work are all supported. The travel plan framework is weak and requires further work on providing more specific objectives including targets, management, marketing and monitoring measures, which should then feed into the final travel plan.

5.5.21 Transport (freight) – the site lies near a very congested link for freight

movements and the proposal for a construction environmental management plan could be expanded to investigate the feasibility of modal shift, particularly using the nearby Thames wharves (e.g. Convoy's Wharf).

5.5.22 Noise – complaints are likely from residents in flats on the northern side of

the development resulting from the noise of the Jet industrial site nearby, especially at night. The applicant should place habitable rooms on quieter facades.

5.5.23 Air quality – the development is likely to cause marginal increases in both

nitrogen dioxide and fine particles at nearby sensitive or relevant receptors, but of greater concern is the introduction of exposure into an area of poor air quality. There is a high risk that the construction phase will significantly impact on nearby residents and mitigation impacts.

5.5.24 London Development Agency – recognises the economic and regeneration

benefits associated with the proposal but the release of employment land requires further justification. The applicant must demonstrate how the equivalent cluster of businesses can be re-established within the proposed mixed-use development. Concern over the method used to quantify improvement in job numbers and taking account of the average vacancy rate for the general employment space, the undefined retail, food and drinking uses, as well as the employment potential from the energy centre, the net gain of jobs may be less than the identified 186 workers. The proposal to relocate the existing businesses at Cannon Wharf Business is welcomed and should be secured as part of a S106 Agreement and should be provided on a Iike-for-like basis in terms of cost, space and locations with realistic

options. A training and employment strategy to be prepared which should be included as part of a Section 106 Agreement. A condition should link the provision of childcare facility with the phasing of the development.

5.5.25 In May 2011 the GLA issued an updated response to the amended

application follows:

5.5.26 Housing provision – the applicant states that due to the significant downturn in the market and the lack of available grants, the level of affordable housing has been reduce from 35% to 20.2% by habitable room. A viability assessment has been carried out by Lambert Smith Hampton at the request of Lewisham Council however officers have not received this information and therefore are unable to comment on the acceptability of the affordable housing offer at this stage. This information is required. The Council should ensure that an appropriate review mechanism is placed within the S106 to allow the capture additional funding towards affordable housing if the market recovers and the value of the development increases. Details of this mechanism should be provided to the GLA and a draft copy of the S106 heads of term should be sent with the stage II referral documents or we will be unable to validate the referral.

5.5.27 Space standards – draft replacement London Plan Policy 3.5 ‘Quality and

design of housing developments’ states that all new residential developments should meet the dwelling space standards set out in table 3.3 of the draft replacement London Plan and have adequately sized rooms with convenient and efficient room layouts. A number of the proposed units do not meet the minimum space standards set out in the draft replacement London Plan. Most of the private one-bed units and all of the studios do not meet the minimum space standards. The draft replacement London Plan is a material consideration with significant weight following publication of the inspectors report. However, it is appreciated that the policy is still in draft form and the scheme was design some time ago to comply with Lewisham’s own space standards which have now been superseded by the draft replacement London Plan standards. Given the length of time the length of time the scheme has been at the planning stage and the considerable work that would be required to redesign the scheme to meet the draft replacement London Plan standards, in this instance, the applicant is not required to comply with this policy.

5.5.28 Design - the overall design approach is acceptable. The design amendments

are broadly supported, in particular the reduction in the heights of the buildings surrounding the central square, along with the additional detail on the elevations of the lower rise buildings. However, there are some aspects of the design that could be amended to further improve the scheme and a further discussion on the points below would be welcomed. The west facing elevation of the tower in block C appears overly blank. Is there scope to add additional windows into this elevation. This could be achieved by wrapping the windows around from the south facing balcony onto this west facing elevation. This would improve views out of these units, and would also increase daylight into the rooms behind. Additional windows would help break down this potentially large blank elevation. What materials are being used on this elevation? It is important that these materials are robust enough to withstand weathering so that in 10 years they do not look worn. There is

a concern that the treatment of the taller residential towers in blocks B and C appear overly commercial. Whilst the familial design approach to the two towers is welcomes, the towers could benefit from introducing further depth into the elevations, making the buildings appear more accessible and allowing residential life to animate the edge of the building. The red fins included in the elevation do create some depth to the elevation, however, more could be done to express the residential nature of the building i.e. emphasising balconies and window reveals to help achieve this depth and softness, which would be more residential in feel than the current commercial feel. This would not require internal re-arrangements of the buildings, but rather amendments to the treatment of some aspects of the elevations. The ground floor edge of building D includes a mix of commercial space. The applicant should be convinced of the need for this level of commercial space in this location. There is a concern that the potentially limited footfall along this route could impact on the ability to let these units in particular. There may be benefit in considering the ability to prepare a plan B for these units, so that they could potentially accommodate an alternative use if required (including residential) should these units remain vacant. It is most important that this route be animated with uses along it.

5.5.29 Access – the applicant’s commitment to 100% lifetime homes is welcomed.

The applicant has now provided detailed plans demonstrating how wheelchair accessible units will be designed and their location with the development as requested as Stage I. As set out in the stage I report, the applicant should clarify the situation regarding the existing and proposed pedestrian crossing to Deptford Park.

5.5.30 Children’s play space – the £53,746 off-site contribution towards children’s

playspace is welcomed.

5.5.31 Amenity space – it is understood that the canal is not part of the site and is owned by the neighbouring site (to be developed by Berkeley Homes.) Whilst it is expected that Berkeley Homes will deliver the Linear Park on this site, if this does not occur, the mechanism in the S106 agreement which requires the applicant to underwrite the cost of compulsory purchasing the park site and delivering the park is welcomed.

5.5.32 Climate Change mitigation (Energy efficiency) – London Plan Policies clearly

establish that development proposals should make the fullest contribution to minimising carbon dioxide emissions in accordance with the hierarchy be lean/be clean/be green. This effectively means that carbon savings achieved as a result of each of the elements of the energy hierarchy should be maximised before the next element of the energy hierarchy is evaluated. Being energy efficiency the first element of the energy hierarchy and given that it is possible to achieve Building Regulations 2010 compliance with energy efficiency measures alone, developments are expected to comply with BR 2010 with demand reduction/energy efficiency measures alone , i.e. before carbon savings achieved with either CHP/renewables are factored in. However, bearing in mind that the stage 1 report of this application was prior to the introduction of Building Regulations 2010 we are, in this instance content to accept the energy efficiency measures currently proposed by the applicant.

5.5.33 District heating and CHP – the recalculated carbon savings submitted by the

applicant are more in line with what is expected and no further information is required.

5.5.34 Renewables – officers are disappointed that the applicant is resisting the use

of renewable technologies to achieve further carbon savings. However, in light of the recalculated carbon savings, when energy efficiency and CHP are taken into account, carbon savings equivalent to 25% beyond 2010 building regulations are achieved and we are content with the current proposals and no further carbon measures are required. The energy strategy and its implementation should be secured by condition.

5.5.35 Transport – the issues originally raised have now been broadly dealt with.

However, since the application was first submitted a number of other major developments in the area have now come forward, including Cannon Wharf and Marine Wharf etc, alongside the nearby Surrey Canal Road development, all of which are going to put increased pressure on the local highway and public transport networks. As a result of all the development planned for the area, LB Lewisham commissioned the ‘Deptford and New Cross Cumulative Impact Study’ at the end of last year. The aim of this was to highlight what the key issues in the area are, with the next stage being to come up with an appropriate package of mitigation measures. As such, while it is appreciated that this application was submitted in advance of the above work being undertaken, the application was submitted 3 years ago and the conditions on the transport network have changed since then. This should therefore be taken into consideration by Lewisham when they are determining the application.

Commission for Architecture and the Built Environment (19/07/2010)

5.5.36 Supports the principle of introducing a residential-led, family focused mixed-

use development in this location whilst retaining a presence for the London Business Centre on the site. A case could be made for this quantum of development and do not object to the principle of tall buildings on this site however, the proposals do not appear to be based on a clear enough vision of the place being created. As a result the approach to the diagram, scale, massing and detailing of the blocks fails to convince as a fitting solution to this site. Whilst the site could accommodate tall buildings, the rationale for their presence as part of this proposal unconvincing and not confident that the tall buildings will be of sufficient architectural quality to meet CABE/English Heritage Guidance on tall buildings. Neither tower appears to act as a marker for anything in particular and seem quite arbitrary in their positioning. This could potentially confuse rather than help people orientate themselves when passing through the area.

5.5.37 Proposed block layout does not appear to be based on a clear hierarchy of

routes and spaces within the site. If a development of this density is to succeed here, it will be crucial to generate a layout that distributes the blocks more successfully across the site and provides a balance of spaces with a character and quality more suited to this location and the business uses proposed. The opportunity exists to create a vibrant, stimulating and flexible

environment for start-up businesses that works with, and is not overwhelmed by, the residential presence on the site.

5.5.38 Positioning Cannon Wharf as a hub for enterprise could be the unique

selling point for this development and help to define its character and sense of place but this proposal fails to recognise this in its approach to the buildings, public space and vehicular access. Question whether the accommodation itself would be flexible enough to adapt to the needs of start-ups requiring premises, and therefore be attractive to such occupiers. As proposed, the configuration of these employment spaces appears to be dictated by the needs of the residential accommodation, rather than from an understanding of what makes the best space for young companies.

5.5.39 If the central public space is to work in this location as an effective stage for

community life and a place for servicing business occupiers on its perimeter the intention to preserve it as a pedestrian priority area is questioned. Allowing some slow moving traffic through this central space will far outweigh the risks and help to make it feel lived in and active and help integrate Cannon Wharf’s public spaces into the local network of streets and spaces. This should also help to determine a more convincing public realm and landscape strategy for the site that is better informed by the site’s surrounding green spaces.

5.5.40 Scale and massing approach to blocks E and F is sound and consider that

blocks G, H and J to could potentially work in the current configuration, blocks A, B, C and D are less successful and should be re-examined. Block D is ungainly and unnecessarily complex and unconvinced that Blocks B and C will be attractive places to live, work and play in their current form. The combination of U-shape blocks of nine stories with towers up to twenty three stories overlooking podium courtyards above two levels of car parking makes for a particularly complex built form which has little justification in this context. Concerned that apartments on the internal corners will suffer from poor daylight and privacy. The very long internal corridors, some of which will not benefit from natural daylight, will lend an institutional feel to the buildings.

5.5.41 Concerns about the quality of the podium roof terraces where the

environment could be made significantly worse by the tall buildings which will overshadow them and create a windy microclimate.

5.5.42 The absence of a common language of materials for the buildings works

against the creation of a coherent neighbourhood or an identifiable character for the site. The family housing in blocks E and F benefit from the restrained approach to its architecture and approach to materials. Different approach to Block G is justified but would urge caution in the use of red aluminium cladding which is vulnerable to vandalism and costly to replace. Remaining blocks try too hard to express their individuality by employing an indulgent mix of materials which only serves to emphasise their sameness. In the case of block A, the use of numerous materials results in a confused building which lacks integrity. Consider the tall buildings to be of poor design quality for the same reason.

5.5.43 In conclusion CABE does not support the planning application in its current [July 2010] form. The approach to redeveloping the site misses a key opportunity to secure an employment-led mixed-use neighbourhood on this site. Consider the design quality of the current scheme to be inadequate and suggest that planning permission should be refused.

Primary Care Trust (19/06/2008)

5.5.44 Planning Obligations are required for health services and facilities to meet

the increased need for health services generated by this proposal. Calculates £3,606,427 to address health needs. Object in the absence of a clear commitment by the developer to assist in meeting this funding gap.

Environment Agency (05/05/2011)

5.5.45 No objections subject to conditions being imposed regarding flood risk

measures, green roofs and groundwater and pollution prevention. Note that further material has been submitted with reference to the groundwater risks that addresses some of the issues highlighted in previous response including need for further assessment of these risks which with the resulting remedial strategy will need to be submitted to the local planning authority for approval in consultation with the Environment Agency.

Natural England (08/04/2011)

5.5.46 Any potential adverse effects to the Rainsborough Avenue Embankments

Site of Importance for Nature Conservation (SINC) should be avoided as far as possible. Unable to comment on the specifics of the ecological surveys which were not submitted and therefore the council must be confident that appropriate surveys have been completed and that the findings in the ES reflect the survey findings. A Construction and Ecological Mitigation Plan (CEMP) has been proposed as a formal measure to outline and secure ecological mitigation and enhancement and should be produced prior to planning approval and not produced as condition of development. Recommend that the proposed landscape plan should form part of the appendix of the CEMP so that there is a clear alignment between the landscape enhancement proposals and CEMP delivery targets. Recommend that trees be retained where possible which is especially important with regards to existing tree lines which provide valuable commuting and foraging routes for certain species.

Thames Water (13/04/2011)

5.5.47 No objection with regard to sewerage infrastructure. The existing water supply infrastructure has insufficient capacity to meet the additional demands for the proposed Plough Way site and recommend a condition be imposed that development should not be commenced until impact studies of the existing water supply infrastructure have been approved. Recommend liaison with Environment Agency regarding boreholes and aquifer protection.

5.5.48 Regarding the Thames Tunnel proposal, note that Earl Pumping Station and

land to the south of it are together the preferred site for works to capture flows from the local CSO which intercepts a number of sewers in the area

and currently discharges into the foreshore adjacent to Helsinki Square. Note intended timing of works (up to three years from 2013) and raise no objection to the Cannon Wharf application subject to it being clearly demonstrated that there would be no detrimental impact on either the current operational use or the proposed tunnel works.

London Borough of Southwark (03/11/2008)

5.5.49 Object on the following grounds:

• Proposal fails to demonstrate that the proposed level of retail would not impact on the vitality and viability of Canada Water town centre

• Proposal fails to provide sufficient information to enable a full assessment of the likely transport implications

• Proposal fails to have a sufficiently high standard of design

• Proposal fails to achieve a reduction in carbon dioxide emissions of 20% from renewable generation

London Borough of Greenwich (11/05/2011)

5.5.50 Object on the following grounds:

• Excessive height of the proposed development which will be directly in line of St. Paul’s Cathedral as seen from Greenwich Park

London Borough of Tower Hamlets (23/06/2008)

5.5.51 Object on the following grounds:

• Land use implications given loss of employment generating floorspace in a Defined Employment Area

• Design of the development

• Apparent non-compliance with criteria for location of tall buildings and proximity to protected vista (Greenwich Park and Blackheath Point to St. Paul’s Cathedral)

• Dwelling mix with an over-emphasis on studio one-bedroom and two bedroom flats with a low provision of family accommodation

• Sustainability of the development with particular regard to the high level of car parking proposed

Lewisham Design Panel (03/05/2008)

5.5.52 Scale, massing and layout – while the difficulties of the site layout and form

were acknowledged the spaces created by the proposed building layouts are considered poor. The central 'square' lacked a convincing geometry (partly as result of the weak orientation of Block G) and failed to create a space of celebration. The quality of the public space at the bottom of the towers was questioned. The elevated podium gardens, made necessary by the lack of underground parking, were considered too small in relation to the height of the buildings enclosing them. The relationship and appearance of the lower rise buildings to the existing houses in Woodcroft Mews is not well integrated with its existing neighbours. The new buildings on the western flank create a barrier ‘wall’ against the existing community which is architecturally and socially inappropriate. The poor quality of public space and the unsatisfactory relationships between masses is in large part due to an

excessive density which is not appropriate to the site. The proposal to control through traffic by a concierge or lowering bollards was considered a failure of control by design and planning. The overall design response to the strong industrial / natural landscape qualities of the canal and embankment lacks inspiration or design quality. The urban design rationale for the towers was weak. The viability of a high density node in a location with relatively poor public transport is a significant concern.

5.5.53 Architecture – concerned at the inelegance of the building designs and the

lack of complementarity between different buildings, notably the towers and their neighbours. The treatment of the towers is particularly incongruous, with an incoherent combination of solid and translucent planes. The design explanation for the language was weak. Concerned that the strong natural qualities of the site had not received a sensitive response in the design proposals. This concern extended from the large scale planning to the individual building scale. Certain car park decks face onto the rich visual amenity of green space, negating the value of the green space as an outlook for living or working spaces.

5.5.54 Overall the scheme still lacks a clear design rationale. The key objective of

bringing this isolated urban ‘island’ into a more dynamic and integrated relationship to its surroundings has not succeeded. The qualities of urban design and architecture were not considered sufficient to justify this level of density and height of development in a location such as this with its modest levels of public transport provision.

5.6 Internal Consultee Responses

Environmental Health (10/05/11, 16/05/11)

5.6.1 Air Quality – following clarification of the ES assessment methodology, no

comments. 5.6.2 Noise – further clarification sought on the ES assessment methodology

including background levels used for the night-time assessment and recommend that for the purpose of construction noise the developer make the issuing of an application for S61 consent to the Council a contractual requirement to ensure that Best Practicable Means is adopted, and where details of construction are better known will allow for better management and control over noise levels.

Highways and Transportation (13/06/11)

5.6.3 The proposed level of off-street car parking provision complies with

Lewisham’s UDP parking standards and is considered acceptable subject to:

• the provision of 6 Car club vehicles/bays within the site – the vehicles/bays should be in accessible locations to allow use by the wider community

• a s.106 contribution towards a Controlled Parking Zone in the vicinity of the site – to meet the cost of consultation & implementation

• the provision of a parking management plan – the plan should provide details of measures to prevent parked vehicles from obstructing the vehicle routes through the site and should also include details relating

to the allocation of parking spaces and the location of electric vehicle charging points within the site.

5.6.4 The proposed site layout improves permeability and connectivity and is

considered acceptable subject to pedestrians and cyclists having right of way across the site.

5.6.5 A S278 (1980 Highways Act) agreement with the Highway authority will be

required to secure highway reinstatement/improvement works adjacent to the site. The works shall include:

• reinstatement/improvement works to Yeoman Street (adjacent to the site)

• works to Rainsborough Avenue to improve pedestrian and cycle access to the site (including widening the footway and introducing a contra flow cycle lane)

5.6.6 The new contra flow cycle lane on Rainsborough Avenue will improve cycle

infrastructure in the vicinity of the site and provide a link to the new cycle superhighway planned for Evelyn Street (London Bridge to Woolwich).

5.6.7 Details of cycle storage is required and passive provision should be made

within the site for the future extension of the London cycle hire scheme. In the interim, the applicant should consider providing a Pool bike scheme at the site.

5.6.8 A waste management plan is required; the plan should include details of

refuse and re-cycling collection points. The plan should illustrate how bins will be brought out to collection points on collection days & returned.

5.6.9 A Construction Traffic Management Plan is required. This should be

submitted prior to the commencement of work on site and should specify how the impacts of construction activities and the associated traffic will be managed.

5.6.10 A Delivery & Servicing Plan is required. The plan should rationalise the

number and time of delivery and servicing trips to the development, with the aim of reducing the impact of servicing activity.

5.6.11 The implementation of the Travel Plan is required to encourage the use of

more sustainable forms of transport. A financial contribution is also required towards the Council monitoring the travel plan, to ensure the Travel Plan is taken forward and delivered.

Ecological Regeneration Manager (27/04/11)

5.6.12 Request copies of the surveys conducted and used to inform the EIA/ES.

Given the lack of evidenced information provided do not consider that they have effectively assessed protected species on site given wider ecological context. recommend a Construction and Ecological Mitigation Plan (CEMP) as a formal measure to outline and secure ecological mitigation and enhancement. The CEMP should be produced prior to planning approval and not produced as condition of development to provide the opportunity to

align the landscape plan with the CEMP delivery targets and give a much better understanding of what is the intended outcome.

5.6.13 Unable to identify enough detail relating to the ecological mitigation, for

example there does not appear to be any commitment to bird & bat boxes or the provision of a varied mix of habitats to benefit a range of species. One would expect in addition to sympathetic 'native' plant species that small scale ecological enhancements would feature in the landscape plan, such as, the inclusion of dead wood, or creation ponds/water bodies. The brown 'biodiverse roof' aspiration needs more detail to ensure that the Council can be confident about the quantum and that good quality biodiverse living roofs are achieved in line with our recommendations and those contained in the Living Roof and Walls Technical Report in support of London Plan Policies.

5.6.14 Lighting generally will be an issue that requires detailed consideration to

avoid unnecessary light spill. Sustainability Officer (06/05/11)

5.6.15 The Planning Energy Statement (April 2011) broadly addresses previous

concerns and queries however further clarification needed regarding the issue of connecting to SELCHP and how viable it would be for the site to be connected if the pipework does come through. It would be useful if they were addressed by the applicant so we can be clear that this option remains a genuine possibility.

5.6.16 The Energy Strategy notes that the projected output of the CHP is at the

high end of expected performance and, given their almost complete reliance on this to deliver the required CO2 emissions reductions, further clarification is sought. Support a condition which did require compliance with projected CO2 emission reductions.

Strategic Housing (12/05/11)

5.6.17 Affordable Housing Unit Mix – the amount of family sized homes needs to be

increased in the affordable housing, however, the inclusion of 3, 4 and 5 bed houses is very welcome.

5.6.18 Affordable Housing percentage – this is below current policy of 50% and the

financial viability assessment needs to be scrutinised.

5.6.19 Tenure split – this is broadly acceptable.

5.6.20 Lifetime Homes compliance – 100% across all tenures welcome. 5.6.21 Wheelchair units (10% and SELHP standard) – needs to meet SELHP

standard and rented units may be required to be fitted out for a wheelchair user. Need to ensure that the footprint of wheelchair units is large enough to meet the standard. Particularly need to ensure that kitchen/living/dining areas where combined, add together the space required under the standard for each area.

5.6.22 Code for Sustainable Homes assumed to be Level 3 – not policy compliant.

5.6.23 Space standards – particularly for 3 bed and larger, plus wheelchair units,

unlikely to be sufficient.

5.6.24 Parking – need to ensure that affordable homes, particularly family units, get a fair proportion. Wheelchair homes should be allocated their own space, ideally adjacent to the property. Also need to be clear that there would not be additional charges for the parking for affordable homes/RSL.

5.6.25 Layout of units – open plan kitchen/dining/living areas on 3 beds or larger

will not be acceptable to the Council and housing providers will not accept units like this.

5.6.26 Financial Viability Assessment required if policy is not being met. 5.6.27 Service charges – these now have to be included in the “affordable rent”

charged by a housing provider. Charges must be assessed and addressed early to ensure that they are affordable.

6. PLANNING POLICIES AND GUIDANCE

6.1 Introduction 6.1.1 In considering and determining applications for planning permission the local

planning authority must "have regard to the provisions of the development plan, so far as material to the application, and to any other material considerations" (Section 70 (2) of the Town and Country Planning Act 1990). Section 38 (6) of the Planning and Compulsory Purchase Act (2004) makes it clear that the determination of planning applications must be made in accordance with the development plan unless material considerations indicate otherwise. This approach is reflected in PPS 1, where, at paragraph 8 (and again at paragraphs 28 and 31), it is confirmed that, where the development plan contains relevant policies, applications for planning permission should be determined in line with the plan, unless material considerations indicate otherwise. The development plan for Lewisham currently comprises the saved policies in the adopted Lewisham UDP (July 2004) and policies in the London Plan (2004, consolidated with alterations 2008).

6.1.2 The UDP is however in the process of being replaced by Development Plan

Documents (DPDs) and Supplementary Planning Documents (SPDs) that will comprise the Borough’s Local Development Framework. Following an Examination in Public into the Council’s Core Strategy held in February 2011 the Council received the Inspector’s Report on 28th March 2011. This found that, subject to some amendments, the Strategy was sound. The changes required by the Inspector are all supported by the Council and indeed were suggested by the Council, and they have therefore been incorporated in the adoption version in accordance with the planning regulations. Formal adoption of the Core Strategy will require a resolution of the Full Council. A report was presented to Mayor and Cabinet on 11th May 2011 which endorsed the recommendation to adopt the Core Strategy incorporating all the associated amendments outlined in the Planning Inspector’s report, and recommend that full Council formally do the same. The full Council is due to

meet on 29th June. In the circumstances very significant weight should be given to the policies set out in the Core Strategy.

6.1.3 The draft replacement London Plan is also a material consideration in this

case. The document has been the subject of an EIP and the Panel Report has issued their report. The response from the Mayor is awaited. The draft replacement Plan is therefore at an advanced state and in the circumstances significant weight should be given to policies within it.

6.2 Planning Policy Guidance and Planning Policy Statements 6.2.1 Planning Policy Guidance and Statements of relevance to the application

are:

PPS 1: Delivering Sustainable Development (2005) Planning and Climate Change – Supplement to PPS 1 (2007) PPS 3: Housing (2010) PPS 4: Planning for Sustainable Economic Growth (2009) PPS 5: Planning for the Historic Environment (2010) PPG 8: Telecommunications (2001) PPS 9: Biodiversity and Geological Conservation (2005) PPS 10: Planning for Sustainable Waste Management (2005) PPG 13: Transport (2001) PPG 14: Development on Unstable Land (1990) PPG 17: Planning for Open Space, Sport and Recreation (2002) PPS 22: Renewable Energy (2004) Planning for Renewable Energy – A Companion Guide to PPS 22 (2004) PPS 23: Planning and Pollution Control (2004) PPG 24: Planning and Noise (1994) PPS 25: Development and Flood Risk (2006) Other National Guidance

6.2.2 The following national guidance is also considered relevant to the

application:

• By Design – Urban Design in the Planning System: Towards Better Practice (2000)

• Urban Design Compendium (2000, 2007)

• Delivering Affordable Housing – Good Practice and Guidance (2006)

• The Code for Sustainable Homes – Setting the Standard in Sustainability for New Homes (2008)

• Planning and Access for Disabled People – A Good Practice Guide (2003)

• Circular 11/1995 – The Use of Conditions in Planning Permissions

• Circular 02/1999 – Environmental Impact Assessment

• Circular 05/2005 – Planning Obligations

• Homes and Communities Agency’s Investment and Planning Obligations – Responding to the Downturn Good Practice Note (2009)

6.3 London Plan

6.3.1 The London Plan, consolidated with alterations since 2004, was published in February 2008. Together with the saved policies in the adopted Lewisham UDP (July 2004), the London Plan comprises the development plan for Lewisham. The policies that are relevant to the application are:

6.3.2 The Overall Strategy

2A.1 Sustainability criteria 2A.5 Opportunity Areas 2A.7 Areas for Regeneration 2A.10 Strategic Industrial Locations

6.3.3 Living in London

3A.2 Borough housing targets 3A.3 Maximising the potential of sites 3A.5 Housing choice 3A.6 Quality of new housing provision 3A.7 Large residential developments 3A.8 Definition of affordable housing 3A.9 Affordable housing targets 3A.10 Negotiating affordable housing in individual private residential and mixed-use schemes 3A.17 Addressing the needs of London’s diverse population 3A.18 Protection and enhancement of social infrastructure and community

facilities 3A.21 Locations for health care 3A.23 Health impacts 3A.24 Education facilities 3A.28 Social and economic impact assessments

6.3.4 Working in London

3B.1 Developing London’s economy 3B.2 Office demand and supply 3B.4 Industrial Locations 3B.5 Supporting innovation 3B.8 Creative industries 3B.11 Improving employment opportunities for Londoners

6.3.5 Connecting London – improving travel in London

3C.1 Integrating transport and development 3C.2 Matching development to transport capacity 3C.17 Tackling congestion and reducing traffic 3C.18 Allocation of street space 3C.20 Improving conditions for buses 3C.21 Improving conditions for walking 3C.22 Improving conditions for cycling 3C.23 Parking strategy

6.3.6 Enjoying London

3D.1 Supporting town centres 3D.8 Realising the value of open space and green infrastructure 3D.13 Children and young people’s play and informal recreation strategies

3D.14 Biodiversity and nature conservation 3D.15 Trees and woodland

6.3.7 Climate change and London’s metabolism

4A.1 Tackling climate change 4A.2 Mitigating climate change 4A.3 Sustainable design and construction 4A.4 Energy assessment 4A.5 Provision of heating and cooling networks 4A.6 Decentralised Energy: Heating, Cooling and Power 4A.7 Renewable energy 4A.9 Adaptation to Climate Change 4A.10 Overheating 4A.11 Living Roofs and Walls 4A.13 Flood risk management 4A.14 Sustainable drainage 4A.16 Water supplies and resources 4A.19 Improving air quality 4A.20 Reducing noise and enhancing soundscapes 4A.21 Waste strategic policy and targets

6.3.8 Designs on London

4B.1 Design principles for a compact city 4B.2 Promoting world-class architecture and design 4B.3 Enhancing the quality of the public realm 4B.5 Creating an inclusive environment 4B.6 Safety, security and fire prevention and protection 4B.10 Large-scale buildings – design and impact 4B.14 World Heritage Sites 4B.15 Archaeology 4B.16 London View Management Framework 4B.18 Assessing development impact on designated views

6.3.9 Blue Ribbon Network

4C.4 Natural landscape 4C.20 Development adjacent to canals 4C.21 New canals and canal restoration 4C.23 Docks

6.3.10 The sub-regions

5D.1 The strategic priorities for South East London 6.3.11 Implementing the London Plan

6A.4 Priorities in planning obligations 6A.5 Planning obligations

6.3.12 The Mayor of London published a draft replacement London Plan for

consultation in October 2009. The consultation draft was open for public comment until 12th January 2010. An Examination in Public, led by an independent panel, took place throughout the summer and autumn of 2010 and the Panel report was published on 3rd May 2011. The Mayor of London will prepare a final version for approval or further amendment by the Secretary State. The new London Plan is expected to be published in late

2011. Relevant emerging policies – which are referred to in this report where appropriate – are listed below and should be given significant weight in the determination of planning applications.

6.3.13 Context and Strategy

1.1 Delivering the strategic vision and objectives for London

6.3.14 London’s Places 2.3 Growth Areas and Co-ordination Corridors 2.13 Opportunity Areas and Intensification Areas 2.14 Areas for Regeneration 2.15 Town Centres

6.3.15 People

3.1 Ensuring equal life chances for all 3.2 Addressing health inequalities 3.3 Increasing housing supply 3.4 Optimising housing potential 3.5 Quality and design of housing developments 3.6 Children and young people’s play and informal recreation facilities 3.7 Large residential developments 3.8 Housing choice 3.10 Mixed and balanced communities 3.11 Definition of affordable housing 3.12 Affordable housing targets 3.13 Negotiating affordable housing on individual private residential and mixed use schemes 3.14 Affordable housing thresholds 3.17 Protection and enhancement of social infrastructure 3.18 Healthcare facilities 3.19 Education facilities

6.3.16 Economy

4.1 Developing London’s economy 4.2 Offices 4.3 Mixed use development and offices 4.4 Managing industrial land and premises 4.7 Retail and town centre development 4.12 Improving opportunities for all

6.3.17 Climate Change

5.1 Climate change mitigation 5.2 Minimising carbon dioxide emissions 5.3 Sustainable design and construction 5.5 Decentralised energy networks 5.6 Decentralised energy in development proposals 5.7 Renewable energy 5.9 Overheating and cooling 5.10 Urban greening 5.11 Green roofs and development site environs 5.12 Flood risk management 5.13 Sustainable drainage 5.14 Water quality and sewerage infrastructure

5.15 Water use and supplies 5.16 Waste self-sufficiency 5.18 Construction, excavation and demolition waste 5.21 Contaminated land

6.3.18 Transport

6.3 Assessing transport capacity 6.4 Enhancing London’s transport connectivity 6.9 Cycling 6.10 Walking 6.11 Smoothing traffic flow and tackling congestion 6.12 Road network capacity 6.13 Parking

6.3.19 Living Places and Spaces

7.1 Building London’s neighbourhoods and communities 7.2 An inclusive environment 7.3 Secured by design 7.4 Local character 7.5 Public realm 7.6 Architecture 7.7 Location and design of tall and large buildings 7.8 Heritage assets and archaeology 7.10 World Heritage Sites 7.11 London View Management Framework 7.12 Implementing the London View Management Framework 7.13 Safety, security and resilience to emergency 7.14 Improving air quality 7.15 Reducing noise and enhancing soundscapes 7.18 Protecting local natural space and addressing local deficiency 7.19 Biodiversity and access to nature 7.21 Trees and woodlands

6.3.20 Monitor and Review

8.2 Planning obligations 8.3 Community infrastructure levy

6.3.21 The Mayor of London has also published a number of strategies, Supplementary Planning Guidance (SPG) and Best Practice Guidance (BPG) notes in order to help implement London Plan policies. The following strategies, SPGs and BPGs are particularly relevant to this application:

• Transport Strategy (2010)

• Housing Strategy (2010)

• Air Quality Strategy – Cleaning London’s Air (2002) and second draft Air Quality Strategy (2010)

• Biodiversity Strategy (2002)

• Energy Strategy (2004) and draft Climate Change Mitigation and Energy Strategy (2010)

• Draft Water Strategy (2009)

• Interim Housing SPG (2010)

• London View Management Framework Revised SPG (2010)

• Sustainable Design and Construction SPG (2006)

• Accessible London SPG (2004)

• Providing for Children and Young People’s Play and Informal Recreation SPG (2008)

• Planning for Equality and Diversity in London SPG (2007)

• Mayor of London’s Economic Development Strategy for London (2010)

• Mayor of London’s Industrial Capacity SPG (2008)

• Living Roofs and Walls – Technical Report Supporting London Plan Policy (2008)

• The Control of Dust and Emissions from Construction and Demolition BPG (2006)

• Wheelchair Accessible Housing BPG (2007)

• Mayor of London’s Health Issues in Planning BPG (2007)

• London Housing Design Guide Interim Edition (2010)

6.3.22 The South East London Housing Partnership's Wheelchair Homes Design Guidelines (August 2009) do not set out planning policy and are not referred to in the Council’s Core Strategy or Residential Standards SPD however they have been adopted by the Council as the housing standards for accessible housing.

6.4 Adopted Unitary Development Plan

6.4.1 The relevant saved policies of the UDP (adopted July 2004) are set out below.

6.4.2 Urban Design And Conservation

STR.URB 1 and STR.URB 4 URB 1 Development Sites and Key Development Sites URB 3 Urban Design URB 4 Designing out Crime URB 12 Landscape and Development URB 13 Trees URB 14 Street Furniture and Paving URB 21 Archaeology URB 22 Important Local Views and Landmarks URB 24 Thames Policy Area URB 29 Art in Public Places

6.4.3 Open Space

STR.OS 1, STR.OS 2 and STR.OS3 OS 7 Other Open Space OS 8 Areas of Public Open Space Deficiency OS 10 Trees in Open Space OS 12 Nature Conservation on Designated Sites OS 13 Nature Conservation OS 17 Protected Species

6.4.4 Environmental Protection

STR.ENV PRO 1 and STR.ENV PRO 3 ENV.PRO 10 Contaminated Land

ENV PRO 11 Noise Generating Development ENV.PRO 12 Light Generating Development ENV.PRO 13 Aggregates ENV PRO 15 Sustainable Surface Water Drainage in New Development ENV PRO 17 Management of the Water Supply

6.4.5 Housing

STR.HSG 3 HSG 2 Housing on Previously Developed Land HSG 4 Residential Amenity HSG 5 Layout and Design of New Residential Development HSG 6 Dwelling Mix HSG 7 Gardens HSG 14 Provision of Affordable Housing HSG 15 Creating Viable and Balanced Communities HSG 22 Consultation on Housing Developments

6.4.6 Sustainable Transport and Parking

STR.TRN 1, STR.TRN 3 and STR.TRN 4 TRN 1 Location of Development TRN 2 Travel Impact Statements TRN 3 Developer Contributions TRN 4 Access for Public Transport TRN 5 Green Travel Plans TRN 6 Employment Areas TRN 10 Protection and Improvement of Public Transport TRN 14 Cycle Parking (and related Table TRN2) TRN 15 Provision for Cyclists and Walkers TRN 16 Developing Pedestrian and Cycle Networks TRN 20 Improving Road Safety TRN 22 Home Zones TRN 23 Car Free Residential Development TRN 25 Controlled Parking Zones TRN 26 Car Parking Standards (and related Table TRN1) TRN 28 Motorcycle Parking

6.4.7 Employment

STR.EMP 1 and STR.EMP 3 EMP 1 Land and Premises for Employment Purposes EMP 2 Promotion and Retention of Creative Industries EMP 3 Defined Employment Areas EMP 6 New Office Development

6.4.8 Shopping And Town Centres

STC 1 The Shopping Hierarchy STC 2 Location of New Stores (Sequential Test) STC 9 Restaurants, A3 Uses and Take Away Hot Food Shops STC 12 Mixed Use Development

6.4.9 Leisure, Community Facilities And Education

STR.LCE 1 and STR.LCE 2 LCE 1 Location of New and Improved Leisure, Community and Education

Facilities

LCE 4 Places for Children to Play LCE 5 Day Nursery and Child Care Facilities

6.4.10 Implementation, Resources And Monitoring

STR.IRM 2 and STR.IRM 3 IRM 2 Implementation IRM 3 Community Benefit and Planning Loss IRM 4 Consultation

6.4.11 The following UDP Proposals Map designations are also relevant:

• Defined Employment Area (all of the site);

• Area of Archeological Priority (all of the site);

• Thameside Policy Area (all of the site);

• Site of Nature Conservation Importance (part of the site);

• Area of Public Open Space Deficiency (all of the site);

• Area of Nature Conservation Deficiency (all of the site); and

• Strategic Viewing Corridor and Strategic Wider Viewing Corridor (crosses the site).

6.4.12 In August 2006 the Council adopted the Residential Standards

Supplementary Planning Document. 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, backland development, 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.

6.4.13 Lewisham’s Housing Market Assessment 2007-8 (2009) and the Lewisham

Leisure and Open Space Study Final Report (2010) are also considered relevant to this application as they provide the evidence base for the Local Development Framework.

6.5 Local Development Framework 6.5.1 The Core Strategy includes three different types of policies: Spatial Policies

(1 to 6), Cross Cutting Policies (1 to 21), and Strategic Site Allocation Policies (1 to 6). Emerging Policy SSA5 identifies a Strategic Site at Plough Way and sets out specific requirements for mixed-use development. This and other policies of relevance to this application are:

6.5.2 Spatial Policies

SP1 – Lewisham Spatial Strategy SP2 – Regeneration and Growth Areas

6.5.3 Cross Cutting Policies CS1 – Housing provision, mix and affordability CS3 – Strategic Industrial Locations and Local Employment Locations CS4 – Mixed Use Employment Locations

CS5 – Other employment locations CS6 – Retail hierarchy and location of retail development CS7 – Climate change and adapting to the effects CS8 – Sustainable design and construction and energy efficiency CS9 – Improving local air quality CS10 – Managing and mitigating the risk of flooding CS11 – River and waterways network CS12 – Open space and environmental assets CS13 – Addressing Lewisham’s waste management requirements CS14 – Sustainable movement and transport CS15 – High quality design for Lewisham CS16 – Conservation areas, heritage assets and the historic environment CS17 – The protected vistas, the London panorama and local views, landmarks and panoramas CS19 – Provision and maintenance of community and recreational facilities CS20 Delivering educational achievements, healthcare provision and promoting healthy lifestyles CS 21 – Planning obligations

6.5.4 Strategic Site Allocation Policies SSA1 – Requirements for strategic site allocations SSA5 – Plough Way

6.5.5 In order to support the Core Strategy the Council is working closely with

other local partners to prepare and implement an Infrastructure Delivery Plan (IDP), relating to physical, social and green infrastructure in Deptford and New Cross. The IDP is overseen by the Sustainable Development Partnership (one of the thematic partnerships that reports to the Local Strategic Partnership Board) and is being driven forward by Lewisham’s Asset Management Board (comprising senior officers from the Council and local partners – including the Primary Care Trust and Hospital Trust).

6.5.6 As noted in 6.1.2 above the Core Strategy was the subject of an

Examination in Public in February 2011 and has been found sound by the Inspector. A report was presented to Mayor and Cabinet on 11th May 2011 which endorsed the recommendation to adopt the Core Strategy incorporating all the associated amendments outlined in the Planning Inspector’s report, and recommend that full Council formally do the same. The full Council is due to meet on 29th June. Once adopted, the Core Strategy will form part of the statutory development plan for the borough. In the circumstances very significant weight should be given to the policies set out in the Core Strategy as a material consideration in the determination of this application and should be given equal or greater weight than policies in the UDP.

7. PLANNING CONSIDERATIONS

7.1 Introduction 7.1.1 The key planning considerations relevant to the proposed development are

considered to be:

• Principle of Development

• Land Use: Employment

• Land Use: Housing

• Land Use: Retail

• Urban Design

• Transport

• Environmental Sustainability

• Other Planning Considerations

• Environmental Impact Assessment

7.1.2 Each of the topics is assessed below in relation to policies set out in the development plan and other material considerations together with the information set out in the ES (2008) and Revised ES (March 2011). The following discussion refers to the proposed development as amended by the drawings and documents submitted in March and April 2011 and supplemented by correspondence received from the applicant since the application was submitted.

7.1.3 Environmental impacts and mitigation are addressed in the applicant’s ES

are assessed at Section 8 of this report. Financial viability and delivery is also considered separately at Section 9.

7.2 Principle of Mixed-Use Development

UDP Policy

7.2.1 The application site comprises land previously in industrial use and no part is

or has recently been in residential use. The site is located within an area identified in the adopted UDP as the Plough Way Defined Employment Area (DEA) which also includes Marine Wharf West and East, 7-17 Yeoman Street, 19 Yeoman Street, Thames Water’s Earl Pumping Station and land between Yeoman Street and Croft Street. Saved UDP policy EMP 3 identifies the employment uses the Council would normally consider appropriate for land within DEAs. It also sets out the criteria against which proposals for other uses will be assessed.

7.2.2 Saved UDP policy EMP 3 states that in DEAs:

“The Council will grant planning permission for B1, B8, and (where appropriate) B2 uses of the 1987 Use Class Order, and will not normally grant planning permission for other uses within the Defined Employment Areas shown on the Proposals Map.”

7.2.3 EMP3 goes on to identify the matters that will be taken into account when considering exceptions to this Policy. Section 8.6 of the Revised Planning Statement sets out the applicant’s assessment of the Cannon Wharf site as it relates to the matters that will be taken into account when considering exceptions to policy EMP 3. Officers have reviewed this evidence and other material such as the Council’s Employment Land Survey (Roger Tym and Partners, November 2008) and an assessment of the proposed development against the criteria in Policy EMP3 is set out below.

a) Other appropriate employment generating uses, especially those supportive of the business/industrial function of the area which do not conflict with the other policies in this Plan The application includes a proportion of employment generating floorspace comprising a mix of B1, A1, A2, A3 A5 and D1 space and would increase built employment space on the site by about 25% (1,250m2). Officers consider that the B1 space, the majority of which is to be provided in a dedicated building to replace the existing Business Centre, is supportive of the business/industrial function of the area and that the amount of A and D Class space would not conflict with other policies in the UDP.

b) The number of jobs likely to be created by the proposal

The applicant estimates that employment will increase by about 25% (from 327 to 403 jobs). Given the overall financial viability of the scheme (see Section 9 below) officers consider that the number and mix of jobs that would be provided on site is acceptable.

c) The length of time the site has been vacant, and demonstration by any

applicant that the site has been actively and appropriately marketed for business/industrial reuse or redevelopment

The site is currently partly occupied and has not been marketed. The Salters Paper site was vacant from 2005 until 2009 and then let on a short term basis however the occupiers are operating without the benefit of planning permission and the use is causing significant disturbance to local residents. The existing Business Centre is occupied and around 250 people are employed in the building however it is not well-suited as modern business space. The building is a converted laundry that has poor ventilation and in parts of the building there is very limited natural light. The applicant states that it would not be economic to adapt the building or introduce air-conditioning although detailed costings of these works have not been provided. Other buildings on the site are in a dilapidated condition. Although the site is currently occupied and has not been marketed for reuse or redevelopment for business/industrial purposes from site visits (including of the existing Business Centre) officers accept that as currently arranged the site provides poor quality space and that redevelopment including the re-provision of the Business Centre provides an opportunity to provide modern B1 space on the site. The applicant has committed to making the new Business Centre available for occupation before demolishing the old building.

d) Any provision within an approved planning brief There is currently no planning brief applicable to the site however the policy set out in the Core Strategy is highly relevant in this regard and is discussed elsewhere in this report.

e) Possible conversion to modern business or industrial use

As noted above, the applicant has stated that the existing buildings are configured or in a state of repair that makes conversion to modern business space uneconomic and based on site visits this assertion is accepted by officers.

f) Significant local and regeneration objectives

The proposed development includes 6,588m2 (gross internal area) of commercial floorspace, to be provided as 4,083m2 of commercial (B1) floorspace and 2,505m2 of other employment space (retail, commercial and nursery). This represents a 20% reduction in built floorspace on the site compared with the existing situation however that does include all existing built floorspace including open-sided storage buildings and low-grade undercroft storage space in the Business Centre. When compared with the existing Business Centre (excluding the undercroft storage space) there would be a 24% increase in B1 floorspace (potentially higher if some of the other employment space being applied for was used for B1 purposes) and would provide modern business accommodation. In addition the replacement of open storage uses with modern buildings would be more compatible with adjacent residential uses than the range of uses that could be undertaken on the site given its long-established industrial use. London Plan policies listed above encourage the provision of housing and set housing targets for boroughs. To this end, the London Plan suggests that surplus industrial or commercial land be used for residential or mixed use development. Although these policies do not necessarily override other policies relating to employment in the London Plan, they are a material consideration. The role of the redeveloped site in relation to the Council’s wider objectives and strategy for north Deptford is discussed elsewhere in this report. The application proposes landscaping of the route of the former Grand Surrey Canal providing pedestrian connections north and south from the site. This forms a key part of the Council’s North Lewisham Links Strategy and together with the mixed use development of the site and potential to connect into adjacent sites, the proposals will contribute to local regeneration objectives.

g) Impact of the proposals upon the range and quality of available

employment sites

The proposed commercial floorspace has the potential to be of a much higher quality than the employment space that currently exists on the site and it is considered that the range and quality of available employment floorspace would be enhanced, rather than negatively impacted.

Saved UDP policy EMP 2 states that the Council will seek to promote

the development of new premises for the creative industries and officers

consider that the proposed new business floorspace has the potential to meet the space needs of a wide range of uses within and connected to the creative industries.

h) Impact of the proposals upon the continuing industrial functioning of the

area The implications of the loss of the site from industrial use were considered in the Council’s Employment Land Survey carried out in 2008. This noted that the Plough Way DEA as a whole (of which the application site forms part) had critical mass and was a ‘strategic’ site with good access that had the potential to deliver significant new employment space close to an established commercial centre. However it also noted that the DEA comprised a collection of sites with a variety of different uses of varying age and quality, was accessed from various points but without continuous internal circulation. In addition much of the area was surrounded by well established and also new, high quality housing. Taking into account the existing and potential future supply of industrial space in the area the report concluded that the site should be reallocated from its DEA designation and identified for mixed employment uses, including significant elements of light industrial and office uses.

i) Employment land demand

Whilst there is evidently demand for employment space on the site and in the locality, Officers accept that on grounds of viability (see Section 9 below) a predominately employment-based development is highly unlikely to come forward at the Plough Way site.

7.2.4 In the light of the information submitted by the applicant and its assessment

by officers it is considered that the matters to be taken into account when considering exceptions to policy EMP 3 have been given due consideration and that, on balance, there is sufficient justification for allowing the release of this site for mixed use development.

7.2.5 Members are advised that the current application has been advertised by the

Council as a “departure” (i.e. a development proposal that does not conform with UDP policy). From the analysis above officers are satisfied that the weight of the evidence in relation to the matters specified in the UDP Policy EMP 3, as comprised in the application and from the Council's own studies, demonstrate that there is a sound case for an ‘exception’ to Policy EMP 3 and that the departure can be justified.

Plough Way Strategic Site

7.2.6 The boundaries of the Plough Way DEA in the UDP coincide with the Plough

Way Strategic Site designation in the Core Strategy and, given the stage to which the Core Strategy has now progressed, it is relevant to consider the application in the light of policies in that document in particular those for the Plough Way Strategic Site. Strategic Site Allocation 1 (SSA1) sets out a number of requirements relating to how proposals for the identified strategic sites, including Plough Way (of which Cannon Wharf forms part), should

come forward. Strategic Site Allocation 5 (SSA5) provides more detailed guidance in respect of the Plough Way site itself.

7.2.7 As noted above the Cannon Wharf forms part of the Plough Way Strategic

Site, which is one of four sites that is identified in the Core Strategy as being a catalyst for regeneration of the Deptford and New Cross area through mixed use redevelopment. Redevelopment of these 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. In the light of the conclusions regarding policy EMP 3, and prior to assessing the proposals against other saved policies in the UDP and policies in the Core Strategy it is appropriate to consider how the application relates to policies in the Core Strategy regarding this strategic site.

7.2.8 The Core Strategy 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 (Spatial Policy 2). Within the Regeneration and Growth areas ‘strategic sites’ have been identified that are of such a scale and significance that – individually and collectively – they are considered central to the achievement of the Lewisham Spatial Strategy (Strategic Site Allocation 1 – SSA1). In Deptford and New Cross these sites are: Convoys Wharf, Surrey Canal Triangle, Oxestalls Road and Plough Way (principally Cannon Wharf and Marine Wharf West and East).

7.2.9 In view of the importance and complexity of the strategic sites, Core Strategy

Policy 4 states that specific proposals will need to be progressed in the context of a site-wide masterplan to be submitted as part of a planning application. Details of the approach are set out in Strategic Site Allocation 1 (SSA1), the supporting text to which states that:

“… to ensure a comprehensive approach to their development and enable local communities to help further shape the proposals, specific proposals will need to be progressed in the context of a site-wide masterplan. The masterplan will need to be prepared by the prospective applicant and will be based on an analysis of the site and its context and set out an overall development strategy that will form the basis of a planning application for the site.”

7.2.10 Policy SSA1 goes on to identify the necessary components of a masterplan and Policy SSA5 sets out specific guidance in respect of the Plough Way Strategic Site. Policy SSA1 and SSA5 envisage an planning application based on a comprehensive masterplan for the entire strategic site which in the case of Plough Way comprises three main parcels of land (in three separate ownerships) that together make up approximately 90% of the Strategic Site designation, together with four smaller parcels (including the operational Earl Pumping Station site) which make up the remainder. The current planning application for Cannon Wharf relates to only part of the Plough Way Strategic Site (approximately 35% of the designated area excluding the route of the former canal, and 44% when this land is included).

7.2.11 At the time of the planning application in March 2008 the current version of

the Core Strategy had not been published although an earlier draft had been produced. At that time only the Cannon Wharf site was identified as a Strategic Site to be released for mixed use development. That earlier version of the Core Strategy was subsequently withdrawn and the current version requires that a masterplan be prepared for the Plough Way Strategic Site as a whole, i.e. comprising Cannon Wharf, Marine Wharf West and Marine Wharf East and land on Yeoman Street.

7.2.12 The Design and Access Statement (2008 and Revised 2011) includes a

series of Masterplanning Options examining how the Cannon Wharf site might be developed both as part of a larger scheme with the other sites forming the Plough Way Strategic Site as well as independently of them. This provided a framework within which proposals for the Cannon Wharf site were developed. A similar exercise was carried out for the adjacent Marine Wharf West site when proposals for that site were developed. The Marine Wharf West masterplan (prepared after submission of the Cannon Wharf application) also considered the location of commercial uses and on scale and massing of development across the site. Both documents set out development principles for the Strategic Site in terms of site layout and linkages across the area and are considered to satisfy the requirement for a masterplan under Policy SSA1

7.2.13 It is considered that the masterplans prepared for the two sites demonstrate

that each can be developed independently, with each representing a phase of the comprehensive development of the Plough Way Strategic Site in accordance with the policy and objectives set out in the Core Strategy. In this regard Policy SSA5 sets out a number of urban design principles as key features of any Masterplan for the site:

a) flexibility in the design of business units to ensure viability and flexibility, and compatibility with residential uses

b) create accessible cycle and pedestrian linkages along the route of the former Surrey Canal to provide a safe, attractive public route and help to tie the site with the Oxestalls Road strategic site and the nearby Pepys estate

c) improve access and linkages between Evelyn Street and the River Thames as well as between the Pepys estate and Greenland Dock

d) the scale, mass and orientation of buildings should take into account the surrounding built context to create a coherent area.

7.2.14 The Cannon Wharf application, as one phase of the delivery of the Plough

Way Strategic Site, provides a mix of employment space in the form of a separate building for B1 use as well as other business units that can be occupied by a range of uses compatible with the mixed use nature of the site and wider area. This mix, and the provision of a dedicated Business Centre in particular, is considered a positive feature of the proposals and will contribute to the masterplanning objectives for the Plough Way Strategic site. The location of the Business Centre at the northern end of the site sits well with the proposals for Marine Wharf West which also has business space adjacent that together will provide a hub for new employment activity.

7.2.15 In terms of routes and linkages the redevelopment of the site will create new connections between the Pepys Estate and Plough Way and Evelyn Street and Plough Way, and as part of the wider masterplan for the Plough Way Strategic Site with Greenland Dock and the Thames. The new routes within the application site connect with new routes proposed on the adjacent Marine Wharf West site and form part of a coherent set of routes that help knit together the existing and new communities. The application includes links to the route of the former canal and works to provide a new north-south pedestrian and cycle link. Although this land is not controlled by the applicant they have undertaken to either carry out the works to the section of the canal adjacent or, if these works are carried out by the adjoining site, to contribute to the cost of works to the section of the former canal to the south linking through to Oxestalls Road. This approach would secure the delivery of the public route identified in Policy SSA5. The scale, mass and orientation of buildings on the Cannon Wharf site itself and as part of the wider masterplan area are considered elsewhere in this report.

7.2.16 Officers consider that the masterplan analysis of the site and its context is

based on an appropriate understanding of the issues, constraints and opportunities of this part of the borough and that the options presented provide a coherent basis within which the Cannon Wharf and Plough Way site as a whole can come forward. The masterplan for the Cannon Wharf site (as well as that for Marine Wharf West) satisfactorily demonstrates that the proposals for the Cannon Wharf and Marine Wharf West sites are physically compatible with the comprehensive development of the Plough Way Strategic Site, and that the development of the Cannon Wharf site as submitted would not prejudice the redevelopment of the entire strategic site in a manner that would deliver the general and site specific objectives set out in the Core Strategy.

7.2.17 It should be noted that whilst the masterplan is comprehensive in terms of its

land coverage, taking in all of the land that makes up the Plough Way Strategic Site given the separate land ownerships it does not consider the detailed mix of uses and floorspace across the site, nor the overall financial viability and deliverability. In terms of delivery, the applicants for the other parcels of land that make up the strategic site are required to prepare delivery strategies for their proposals, as they progress. In this context the applicant for Cannon Wharf has included as part of the Planning Statement a delivery strategy that addresses issues relating to implementation of development on their site only, on the basis that this will comprise one phase of a wider redevelopment scheme. Nonetheless it is considered that the development of the Cannon Wharf site will have a catalytic effect on the regeneration of the area and, in the circumstances of this case, is considered an acceptable approach. This is considered in more detail in section 9 below (Financial Viability and Deliverability).

7.2.18 In terms of the delivery of a comprehensive scheme for the Plough Way

Strategic Site, in determining the application for the Marine Wharf West site the Council has accepted that the masterplan submitted with that application represents an acceptable framework for its comprehensive development. Given the way in which the Cannon Wharf proposal sits within that masterplan, the nature and the timing of the separate applications for Marine Wharf West and East and the fact that there is no single dominant

landowner or other likely site assembly issues it is considered that there is no necessity for a single planning application and delivery strategy and/or the prior assembly/acquisition of the balance of the entire strategic site in order to achieve the policy objectives relating to the Plough Way Strategic Site.

7.2.19 Although this approach is not fully consistent with the detailed requirements

set out in the Core Strategy, on balance the Council is satisfied that the masterplanning material submitted with the Cannon Wharf application provides sufficient context within which to consider the current planning application and how its fits into the wider Plough Way Strategic Site and the Council's aspirations and policy for it. Therefore whilst the policies envisage a single comprehensive redevelopment based on a single masterplan, for the reasons set out above it is considered that the submitted masterplan demonstrates that policy SSA5 can be delivered by separate proposals for the individual sites that make up the Plough Way Strategic Site. In the circumstances it is concluded that the determination of separate applications for parts of the Plough Way Strategic Site is acceptable.

7.3 Land Use: Employment

Introduction

7.3.1 The assessment of the application against saved UDP policy EMP3 has

concluded that, in principle, releasing the site from employment use for mixed-use development of the site is acceptable. Also of relevance are policies in the Core Strategy, in particular policy SSA5 as it relates to the provision of employment floorspace on this site. Paragraphs 8.33 and 8.34 of the Core Strategy note that:

• this is an appropriate site for employment and mixed use development

• the existing successful Cannon Wharf Business Centre indicates there is demand for smaller business premises in this location

• the site has sufficient scale to allow a distinct ‘business quarter’

• opportunities should be taken to provide… quality business and light industrial uses providing higher density employment

7.3.2 Paragraph 8.35 refers to the Council’s most recent Employment Land

Survey, and notes that, on balance, redevelopment of the Plough Way strategic site would increase the intensity of uses, provide a greater mix of business uses, and replace some of the existing buildings with modern facilities. The Mayor of London has reviewed Lewisham’s Core Strategy and has agreed with the proposed release of certain sites (that were previously Defined Employment Areas), including the Plough Way site, for mixed use development. The Core Strategy and evidence base has been found to be sound following the EIP.

Commercial Floorspace

7.3.3 Policy SSA5 requires, amongst other things, that redevelopment provides at

least 20% of the built floorspace developed on the site to be for a mix of business space within Use Classes B1(c), B2 and B8. This application

includes 6,588m2 (gross internal area) of commercial floorspace comprising 4,083m2 of B1 floorspace and 2,208m2 of A1, A2, A3 and A5 floorspace. The application also proposes 297m2 of D1 space.

7.3.4 At 4,083m2 of B1 floorspace the proposal amounts to only 8.6% of the built

floorspace. Although not specifically referred to in draft policy SSA5, when the proposed A1, A2, A3, A5 and D1 floorspace is included in the calculation this figure rises to 13.9%.

7.3.5 Whilst the absence of B2 and B8 uses from the current proposals is

considered appropriate given the potential impact of such uses on adjoining residential properties, the commercial floorspace proposed is significantly below that required by policy SSA5. The applicant has submitted a financial appraisal of the scheme which demonstrates that, based on the costs and values of this scheme, the non-residential floorspace provides a limited contribution to the gross development value of the scheme and not in proportion to its contribution to the overall floorspace. In other words, the provision of this space is cross-subsidised in part by the residential content of the development and so increasing the commercial floorspace would have a negative impact on scheme viability. In addition increasing commercial space whilst maintaining the number of housing units is not considered appropriate on this site given that the scheme is already a high density development. Alternatively the displacement of residential space with commercial space would have a disproportionate and further negative impact on viability given the overall financial viability of the scheme. In the circumstances, and taken with the other aspects of the proposed development it is considered that the proposed amount of commercial floorspace is acceptable in this case.

7.3.6 The proposed location of the B1 floorspace in a dedicated building to replace

the existing Business Centre on the site and in Phase 1 of the development (which will also allow business in the existing building to remain on site during its construction and to relocate to the new building without having to move off site) is welcomed. The location also ties in well with the proposed business space on the Marine Wharf West site to the east which is located on the northern part of that site and along the Plough Way frontage.

7.3.7 In terms of potential employment opportunities on the site, the applicant

estimates that a total of around 400 full-time equivalent jobs would be created by the development. Based on typical employee : floorspace ratios for different uses set out in English Partnerships’ “Employment Densities” report (2001) the B1 Class Business Centre would accommodate 292 employees. In terms of the other non-residential space the proposed D1 Class nursery would provide 8 new jobs. The balance of space is to be provided for an unspecified mix of A1, A2, A3, A5 and B1 floorspace. Assuming that all of this space was used for B1 Class purposes then it would provide space for 103 jobs.

7.3.8 Given the importance of securing a mixed use development on the strategic

sites and the relatively low level of commercial floorspace provision on this site compared to Policy SSA5 it is important that the Business Centre is developed and available for occupation in Phase 1. Accordingly it is recommended that the proposed phasing scheme is secured through the

Section 106 agreement and linked to occupation of residential accommodation. To support the relocation of existing businesses and ensure that new and existing occupiers can afford space within the development it is appropriate that the commercial space across the site has service connections and other basic infrastructure provided as part of the construction process.

7.4 Land Use: Housing

Introduction

7.4.1 At national level, PPS 1 (paragraph 14 onwards) and PPS 3 recognise the

need to develop socially inclusive communities, creating a suitable mix (both market and affordable) of housing. PPS 3 (paragraph 29 onwards) requires the Council to set a plan-wide target for affordable housing, and targets relating to the mix in terms of social and intermediate housing, size and type. In addition, PPS 3 requires the Council to set a threshold above which developments would be expected to achieve such targets and an approach for seeking developer contributions towards the provision of affordable housing.

7.4.2 The Lewisham Housing Market Assessment 2007-8 (HMA) published in

December 2009 states (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 3A.1 of the London Plan sets out a target of 9,750 additional homes to be built in Lewisham in the 10 years from 2007/8 to 2016/17, which is reflected in a monitoring target of 975 additional homes per year. 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.

7.4.3 Given that the application site is within reasonably close proximity to local

services and access to the necessary social infrastructure it is considered suitable for affordable housing in accordance with saved UDP policy HSG 14. This policy also commits the Council to negotiating for an element of affordable housing to be provided in any major residential development. The supporting text of HSG 14 adds that the Council considers it pragmatic to seek an affordable provision of 35% of the residential content in developments, although it should be noted that London Plan policy 3A.9 refers to a higher target of 50% as does Core Strategy policy CS1. With regard to tenure mix, the supporting text of HSG 14 refers to a target proposed by the Mayor of London in 2001 of 70% social rent / 30% intermediate housing within affordable housing provisions. The more recent London Plan policy 3A.9 confirms that, within affordable housing provisions, a London-wide objective of 60% social housing and 40% intermediate provision should be applied. Different proportions are supported by the most recent published HMA 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.

7.4.4 In these circumstances the provision of housing is a relevant consideration in the determination of this application, as is the ongoing need for affordable housing in the borough.

Housing Provision and Tenure Mix

7.4.5 The proposed development would provide 696 residential units including 117 affordable units comprising 22 social rented and 95 shared ownership units. The proposed unit sizes, habitable room numbers, and tenure breakdown of the proposed development are summarised in the tables below.

Detailed unit size and tenure breakdown

Detailed habitable room figures 7.4.6 Based on this mix the development would comprise 3% social rented units,

14% shared ownership units and 83% private sale units. Based on habitable room numbers, the development would comprise 5% social rented, 15% shared ownership and 80% private sale. Based on unit numbers, the combined affordable element would be 17%, 20% based on habitable room numbers due to the larger family-sized units being affordable. It should be noted that the financial viability appraisal does not assume any grant support and as a consequence no cascade mechanism to reflect differing grant levels is proposed.

7.4.7 These figures fall significantly short of the 35% affordable housing figure

referred to in saved UDP policy HSG 14, and the 50% target referred to in London Plan policy 3A.9. The applicant has submitted a confidential financial appraisal for the scheme which 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 at Section 9 of this report however in summary the financial appraisal demonstrates that, when taken with other policy requirements such as the provision of employment space and other site specific objectives, the proposed development provides the maximum viable amount of affordable housing at

Studio 1 bed 2 bed 3 bed 4+bed TOTAL

Social Rented

0 0 4 7 11 22

Shared Ownership

0 30 44 21 0 95

Private Sale

31 235 273 40 0 579

TOTAL 31 265 321 68 11 696

Studio 1 bed 2 bed 3 bed 4+bed TOTAL

Social Rented

0 0 12 8 59 99

Shared Ownership

0 60 132 84 0 276

Private Sale

31 470 819 183 0 1483

TOTAL 31 530 963 275 59 1858

this time. The GLA has noted in its Stage 1 response that the level of affordable is below target levels (and that the proposed tenure split does not reflect London Plan policy). The financial viability report that underpins the scheme will be provided to the GLA when the application is referred back following determination by the Council.

7.4.8 Whilst 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 this is kept under review. To this end a mechanism is to be incorporated as part of the Section 106 to secure funding for additional affordable housing should values increase to a level where this would be financially viable.

7.4.9 It is also relevant to note that the provision of 22 social rented units

represents 19% of the affordable housing, significantly below the 70% social rented / 30% intermediate housing set out in Core Strategy policy CS1 and London Plan policy 3A.9. In this case a balance has been struck between the mix of uses on the site, affordable housing size and tenure mix and it is considered that the provision of the majority of the social rented units as 3+ bed houses is relevant when assessing the scheme against the policy targets and it is recommended that this tenure mix is accepted.

7.4.10 In terms of the location and timing of provision of affordable housing in the

development the affordable housing will be provided in Phase 2, 5 and 7 which includes the first block of residential units (Phase 1 being the Business Centre). This is considered acceptable and would be secured through the Section 106 agreement.

Accommodation Mix

7.4.11 The application states that the 696 residential units would comprise:

Total

Flats Units

Studios 31 4.5%

1-bed 265 38.1%

2-bed 321 46.1%

3-bed/Duplex 63 9.1%

Houses

3-bed 5 0.7%

4-bed 7 1.0%

5-bed 4 0.6%

Total 696

7.4.12 The proposed size mix includes 79 units (11.3% of the units) as family-sized

accommodation (3+ bedrooms) including 11 4+ bedroom houses (all of which would be social rented). The applicant has justified this level of provision on the basis of financial viability and in the circumstances officers consider the proposed unit size mix is acceptable.

7.4.13 The Council's Adopted Residential Standards SPD (2006) sets out minimum

dwelling size space standards (these are below the GLA Draft Housing

Design Guide, 2009). Whilst the majority of units meet the Council’s minimum standard, some comfortably so, 11 of the 1-bed units fall short of the 45m2 standard. Whilst this is sometimes by only small amount, given the number of residential units on the site it is particularly important that a high standard of residential amenity is achieved in the flats. Accordingly some minor alteration to the floor layout of units in Blocks C2 and C4 is required to meet the minimum standard and this will need to be confirmed through submission of updated floorplans and floorspace schedules for these Blocks. As the majority of the 1-bed units just meet the Council’s minimum space standard they fall below the GLA space standard (50m2) and the GLA has raised this as a concern. The GLA acknowledges however that the scheme was designed some time ago to comply with Lewisham’s own space standards which had been adopted as SPD. The GLA goes on to state that given the length of time the scheme has been at the planning stage and the considerable work that would be required to redesign the scheme to meet the draft replacement London Plan standards, in this instance, the applicant is not required to comply with this policy

7.4.14 In terms of flat layout, although a small number of units have somewhat

awkward layouts as a consequence of recesses and projections in the elevations it is considered that the overall layout of units and rooms would not seriously compromise their use. The applicant proposes combined kitchen, dining and living spaces in the majority of units including some 3-bed units. Whilst separate kitchen and living/dining rooms for the larger units to achieve a degree of separation for one living space and for the work area of the kitchen is encouraged in the GLA guidance this is not specifically required by the Council’s Standards and therefore the layout is considered acceptable.

7.4.15 Stacking of the units is also considered to be generally satisfactory.

Although there would be some instances of living spaces being located directly above bedrooms, such arrangements are limited and it is considered that overall the proposed layout is acceptable in this respect.

Accessibility

7.4.16 Policy HSG 5 of the UDP states that the Council will only permit new

residential development which provides physical accessibility for all members of the community including people with disabilities. Where appropriate the Council will seek the provision of new homes designed, or capable of adaptation, to housing for long term needs. The supporting text later confirms that the Council will encourage developers to provide facilities that improve upon those statutorily required and that the Council will encourage the provision of units that are designed to the Joseph Rowntree Foundation's Lifetime Homes Standards.

7.4.17 The Council’s Residential Standards SPD (2006) reflects London Plan (pre-

2008 version) policy 3A.4 Housing Choice. This stated that UDP policies should seek to ensure that all new housing is built to Lifetime Homes standards and to ensure that 10% of the new housing is designed to be wheelchair accessible or easily adaptable for residents who are wheelchair users. These standards are repeated in the updated (2008) London Plan, at policy 3A.5 and Core Strategy Policy 1 in the Council’s Core Strategy.

7.4.18 The applicant has confirmed that all residential units have been designed to

Lifetime Homes standards (para. 3.2 of the Planning Statement) and that the wheelchair accessible/adaptable units have been designed to meet South East London Housing Partnership standards (para. 25.37 of the Design and Access Statement). This space standard is more generous than the GLA standard and together with the commitment regarding Lifetime Homes will be secured by condition.

7.4.19 70 units (10%) are proposed as wheelchair accessible/adaptable, 35 being

affordable (5 houses and 30 shared ownership) and 35 for private sale. The size breakdown of these units would be as follows:

Unit size Social Rent Shared Ownership Private Sale

Studio 0 0 0

1 bedroom 0 0 0

2 bedroom 0 12 23

3 bedroom 5 18 12

4 bedroom 0 0 0

Total 5 30 35

7.4.20 This provides for an appropriate number and mix of unit sizes that are

distributed across the site and it is considered by officers that the proposed size, tenure mix and location of the wheelchair accessible/adaptable units is acceptable.

Residential Amenity

7.4.21 The layout of the site means that the majority of units are east or west facing

with a number of the larger flats being dual aspect which is welcomed. All houses are dual aspect. The detailed layout of the flats has sought to limit the number of single aspect north facing units and these are limited to parts of Blocks B and C. In total 15 units (2%) are single aspect reliant on daylight from north-facing windows, however none of these flats are family units (only 1bed and studio apartments). Whilst single-aspect north-facing units should be avoided wherever possible the applicant has reduced the number of affected units through revisions to the scheme and on balance the layout and orientation of the residential accommodation is considered acceptable. The dual-aspect layout of a number of the residential units would also allow for natural cross-ventilation and thereby reduce the need for mechanical ventilation. Given the orientation of the flats and proposed position of windows it is considered that habitable rooms within the proposed development would receive adequate levels of natural light.

7.4.22 In terms of outlook, windows serving habitable rooms would generally not be

enclosed by adjacent development or other parts of the proposed development. Privacy within the proposed residential units would also be satisfactory due to the relationship between the blocks and the existing residential properties on surrounding streets. The relationship of the proposed housing to that adjacent is considered in 7.9 below and on balance is considered acceptable.

7.4.23 The applicant proposes a variety of types of amenity space for residents around the site, some as private gardens for individual units and other areas being shared amongst flats within a block. The Council’s Residential Standards SPD does not specify minimum amenity space requirements for new residential development but does recommend gardens for houses are at least 9m in depth. The majority of the proposed residential units would be provided with their own private outdoor amenity spaces in the form of balconies or roof terraces, small gardens or outdoor spaces for houses in Blocks E and F. 6 of the 16 houses would have a garden of 9m+. Almost all of the proposed balconies and gardens would be accessed from the living spaces, with some units having the possibility of a second access from a bedroom. The majority of flats in the tall buildings will have either balconies or enclosed ‘winter gardens’ with openable louvres. Balconies would have a minimum depth of 1200mm, with some 1500mm or deeper. The 1200mm deep balconies would provide 3m2 of private amenity space with the deeper and wider units providing over 5m2. All units within the relevant blocks would have direct access to associated communal gardens as well as the shared space in front of Block F.

7.4.24 Officers consider that the type, location and size of private and communal

amenity space provided for the residential units is acceptable for a development of this nature and density.

7.5 Land Use: Retail

Introduction

7.5.1 In addition to the Business Centre and Nursery the application proposes 2,208m2 of ‘other’ commercial floorspace. This is identified as Class A1, A2, A3, A5 retail and B1 however there is no detailed breakdown. The Socio-economic chapter of the ES assumes that all non-residential space is B1 however unless otherwise limited by condition or legal agreement, there could be 2,208m2 of Class A1, A2, A3 and/or A5 retail space. In the circumstances it is appropriate to consider the land use implications and the impact of these uses on existing retail centres.

7.5.2 PPS4 requires 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. Guidance on impact assessment accompanying PPS4 states that comprehensive assessments will only generally be needed if a scheme is over 2,500 square metres, although they can be required for developments of less than 2,500 square metres which are likely to have a significant impact on smaller town centres. The site is outside an existing town centre and there may be impacts on existing local centres, particularly when taken together with other sites comprising the Plough Way Strategic Site including Marine Wharf West which proposes 1,543m2 of A1, A2 or A3 space.

7.5.3 Core Strategy policy 6 sets out the retail hierarchy and location of retail

development across the borough and policy SSA5 notes that development of the Plough Way Strategic Site will provide retail uses to serve local needs that do not adversely impact on existing town centres. London Plan policy 3D.1 states that boroughs should encourage retail uses in town centres and

discourage them outside the town centres and UDP policy STC 2 sets out a sequential test applicable to substantial retail development (1,000m2), confirming that such development should be located in the first instance in major and district centres.. .

Retail Impact

7.5.4 Although in this case a retail impact assessment was not submitted with the

application the site has been assessed by specialist retail consultants appointed by the Council as part of a wider assessment of the potential impact on existing town centres of the retail floorspace proposed on the strategic sites in the area. Their analysis was undertaken in the context of the original 2008 planning application which proposed 1,675m2 of A1, A2, A3, A5, B1, D1 space (in addition to the Business Centre) i.e. less than the maximum that is currently proposed.

7.5.5 A simple capacity analysis for the Cannon Wharf site (based on the number

of additional residents and typical convenience expenditure per head) indicates that, in isolation, the scheme could justify around 155m2 (net) of local convenience goods floorspace provision by the year 2014. This though does not take account of the additional housing likely to come forward on the rest of the Plough Way Strategic Site and associated additional spend by new residents nor the spend by business occupiers on the site. Quantitative analysis by the Council’s retail advisers shows that there is capacity for a small foodstore to serve both Cannon Wharf and Marine Wharf West sites. The Marine Wharf West site proposes a foodstore of 390m2.

7.5.6 Given the proximity of the Strategic Sites to each other the assessment also

considers the potential cumulative impact of the proposed retail floorspace across these sites. The Plough Way Strategic Site is between 600 metres and 1 kilometre from the nearest existing retail provision at Evelyn Street Triangle which is a relatively small centre with limited convenience provision. There is also a store on Grove Street close to its junction with Oxestalls Road and shopping further afield on Lower Road and at Surrey Quays. However the Council’s advisers consider that the surrounding retail provision is not likely on its own to be sufficient to meet the needs of the new residential accommodation and employment uses on the Marine Wharf West and Cannon Wharf sites. In the circumstances the provision of a limited amount of retail space on these sites is 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. These are matters that can be controlled by condition.

7.5.7 The total of 2,208m2 of other commercial space proposed on the Cannon

Wharf site would be split between five blocks with the largest amount unit in Block H in the centre of the site amounting to 440m2 and intended for use for A3 purposes. None of the units alone would meet the definition of “substantial” provided under UDP policy STC 2 although a number would be greater than the 155m2 (net) of local convenience goods floorspace that the Cannon Wharf residential population itself might justify. The applicant has proposed that Class A1 local convenience goods floorspace be limited to

300m2 (net). Given the combination of the new resident and working population on the site and taking into account existing and proposed retail floorspace locally officers consider this scale of provision is acceptable. Given the potential impact of additional A1 uses on exsiting local centres it is considered that the balance (1,468m2) should be used for B1 purposes. This would be secured by condition. Should other uses be proposed then this would be the subject of an application in due course.

7.6 Design

Introduction

7.6.1 UDP policy URB 3 Urban Design states that the Council will expect a high

standard of design in new development or buildings, whilst ensuring that schemes are compatible with, or complement the scale and character of existing development, and its setting. Scale, mass, layout, access, townscape, height, alignment, quality and use of materials, ornamentation, and energy/resource efficiency will be taken into account. The Council will consider the preservation and creation of urban form which contributes to local distinctiveness such as plot width, building features and uses, roofscape and open space. Other UDP policies (including HSG 4 and HSG 5), and the Residential Standards SPD, similarly stress the importance of good design.

7.6.2 Relevant national guidance is provided in PPS 1 and PPS 3, and the

documents By Design and the Urban Design Compendium. At a regional level, London Plan policies 4B.1 and 4B.2 are relevant.

7.6.3 Policy in the Core Strategy is material consideration in the determination of

this application and very considerable weight should be attached to policies within it. As noted above, policy SSA1 in the Core Strategy states that for each strategic site allocation, a site masterplan must be prepared by the prospective applicant(s) with the involvement of landowners, local communities, the local planning authority and other interested parties. In this case, pre-application and post-submission consultation was undertaken with the Council, adjoining landowners and local residents and the scheme was presented to the Council’s Design Panel and adjustments have been made to the masterplan as well as to the development form and content. Draft policy SSA5, which relates specifically to the Plough Way strategic site, reiterates the Council’s requirement for redevelopment to be carried out in line with an approved masterplan. Policies relating to high quality design (Policy 15), protected vistas (Policy 17) and tall buildings (Policy 18) are also of relevance. The Core Strategy notes (para. 6.74) that subject to the detailed considerations set out in Policy 18 the Strategic Site Allocations in Deptford and New Cross are in principle considered appropriate for the location of tall buildings to mark the scope and scale of regeneration that the policies in the Core Strategy will deliver.

7.6.4 Paragraph 4.119 of the London Plan defines tall buildings as those that are

significantly taller than their surroundings and/or have a significant impact on the skyline and are larger than the threshold sizes set for the referral of planning applications to the Mayor. In this case two buildings are significantly taller than the surrounding area and whilst buildings on the

Pepys Estate to the south at 8 storeys are of a similar height to those proposed at Cannon Wharf, buildings to the west and north are of a smaller scale including 2-storey houses. Also of relevance is the fact that the site lies within the Greenwich to St Paul’s Cathedral viewing corridor. The impact on this view has been assessed and is considered in section 8 below as part of the review of the ES.

Masterplanning

7.6.5 The site does have a number of physical constraints that have impacted on

the masterplanning approach – a very limited road frontage which means the site is unable to have a street presence and is isolated from the activity on Evelyn Street, the existence of the railway embankment to the south which presents a blank two storey wall to the site and creates a significant barrier to integration with the Pepys estate, an irregular site boundary which creates an awkward geometry, and wide-ranging building heights in the vicinity from 2-storey houses to 8-15-storey blocks of flats. The proposed layout provides a ‘street’ linking Evelyn Street with Yeoman Street, flanked by buildings that increase in scale from west to east. This route turns from west-east to south-north in the centre of the site in the form of a ‘square’ from which a connection to the former canal is also possible.

7.6.6 The Design and Access Statement identifies seven objectives for the site:

• to establish a sense of place and community through a high quality urban environment;

• a mixed use development focused around vibrant employment opportunities to create active frontages to public spaces;

• to fully address the public park on the former Surrey Canal;

• a distinctive neighbourhood character through a variety of appropriate typologies; embracing a site-wide sustainability strategy; and

• provide high quality amenity for different groups and different uses.

7.6.7 The Design and Access Statement also sets out the key urban design decisions that created a framework for developing the scheme, and then examines different layouts, building footprints and massing that arise form this process. These are identified as:

• Built development around the perimeter of the site with new buildings fronting onto new and existing routes including the route of the former Grand Surrey Canal;

• Opening up new pedestrian links through and beyond the site west-east (Evelyn Street to Plough Way) and south-north (Rainsborough Avenue/Pepys Estate to Plough Way)

• A massing strategy that increases in height from west to east acknowledging the scale of existing buildings and the potential of the route of the former canal to accommodate taller buildings

• The location of two tall buildings marking the intersection of the two arms of the main route through the site and a route to the canal; and

• The location of commercial floorspace along the main route through the site.

7.6.8 Whilst these objectives and key decisions are relevant and appropriate to the masterplanning of the site, of equal importance is the integration of the site into the wider area. The analysis in the original Design and Access Statement focused principally on the Cannon Wharf site in isolation from the wider Plough Way Strategic Site, in part a consequence of the timing of the original application which pre-dated the Core Strategy identification of the larger Strategic Site boundary. Whilst connections were shown linking through to the former canal route, in the absence of a wider masterplan these served only a limited purpose. The revised Design and Access Statement (2011) more explicitly acknowledges the adjacent Marine Wharf West site and demonstrates how the two proposals would work together in terms of routes and treatment of the common feature of the former Surrey Canal.

7.6.9 The layout of the site (as well as design quality and proposal for tall buildings

which are considered below) has received significant criticism from CABE and Lewisham’s Design Panel and these are acknowledged. In isolation the proposals for the site could be considered to fail to deliver a coherent, connected scheme being inward looking and giving the impression of turning its back on the surrounding area. However as already noted the site forms part of a larger development (i.e. the Plough Way Strategic Site) and setting the scheme within this wider context and demonstrating how the site fits within a masterplan for the strategic site as a whole are relevant considerations and crucial to the success of the scheme. Masterplan options have now been prepared for the wider Plough Way Strategic Site and form part of the current application submission. This approach has been developed and refined in the strategic masterplan prepared as part of the application for the Marine Wharf West site and recognise the need for a comprehensive masterplan for the whole of the Plough Way Strategic Site whilst also acknowledging that applications for the major landholdings may come forward independently.

7.6.10 Concerns have also been raised by the GLA, Design Panel and CABE about

the purpose (or rather lack of purpose), size (too large/civic in scale) and location (centre of the site or offset) of the main square. The square is located close to the junction between the west-east and south-north routes through the site and is considered a logical location for this space. It will be framed by commercial units and so there will be activity around its edges helping to animate what might otherwise be a large but purposeless space. Given the overall density of the proposal and height of buildings framing the square it is considered that the space is an appropriate feature within the site.

7.6.11 Whilst the development is focused on its internal street, for the reasons

outlined above and as a constrained backland site, it is considered that site layout options are limited. To make sense of the scheme and to create a successful place it is necessary to set the Cannon Wharf site and layout within the context of the wider Plough Way masterplan that provides a coherent framework for the comprehensive development of the Plough Way Strategic Site. As well as delivering a mixed use scheme, the proposals will create new links through the area (and tie in with those proposed on the adjacent Marine Wharf West site) and by incorporating the route of the former canal will, subject to landownership matters being resolved (or the

works being implemented by third parties And the site funding works to the remainder of the canal route locally), make a significant contribution to achieving the objectives for the Plough Way Strategic Site On this basis it is considered that on balance the proposals for Cannon Wharf integrate appropriately with the site-wide masterplan and respond appropriately to the site and its context.

7.6.12 Detailed consideration of massing and design are addressed below.

Density

7.6.13 With the UDP policies on density (HSG 16) and sustainable living areas

(HSG 17) now deleted, the appropriate development density for this site is to be considered in the context of London Plan policy 3A.3 taking account of the site's PTAL score and surrounding residential densities as well as the design, massing, land uses, amenity space and quality of the proposed residential accommodation. Densities locally vary from an estimated 95 units per hectare to the south to the higher densities of Iceland Wharf and Baltic Quay. Marine Wharf West adjacent has a density (based on a site area including the former canal) of 532 habitable rooms per hectare/188 dwellings per hectare.

7.6.14 London Plan policy 3A.3 and the related table 3A.2 indicate that at "Urban"

sites with PTAL scores of 2 to 3, a density range of 200 to 450 habitable rooms per hectare can be appropriate. This translates as 45 to 170 residential units per hectare, depending on the average dwelling size. The site is not within the Deptford Creek/Greenwich Riverside Opportunity Area and therefore additional density considerations set out in London Plan policy 5D.2 do not apply in this case. The Core Strategy notes that the Regeneration and Growth Areas (in which the Cannon Wharf site is located) will deliver over 80% of the borough's forecast housing growth and that this will primarily be achieved through the development of higher density housing as part of a mixed use scheme including within land previously allocated solely for employment uses within Deptford and New Cross (Core Strategy Policy CS4 and SSA5 relating specifically to the Plough Way Strategic Site).

7.6.15 With 696 residential units (accommodating 1,858 habitable rooms) proposed

in a site of approximately 3.01 hectares excluding the former canal route (3.58 hectares including the canal), the development would have a residential density (averaged across the site) of 618 habitable rooms per hectare, and 231 dwellings per hectare (519hrh and 194dph including the canal). It should be noted that, given the amount of non-residential floorspace to be provided on the site the development’s residential density is in fact likely to be higher.

7.6.16 Commenting on density, the GLA have noted that it is not unusual for

residential schemes in urban London to exceed the density guidance set out in the London Plan. However it also notes that high density development must not represent an overdevelopment of the site and the layout and design must achieve a high quality internal and external built environment, high quality public realm and communal amenity spaces with a range of transport improvements to accommodate the proposed density. The quality of the residential units has been addressed above (7.4) and other matters

are considered separately below. In the circumstances, although the proposed density is above the range set out in the London Plan it is considered that a higher density, which has been reduced from the original proposals as a consequence of changes to the height of buildings, would be acceptable.

Height, Massing and Tall Buildings

7.6.17 Building heights (including ground floor) vary across the site from 3 storey

houses, 5-6 storey intermediate blocks and 7-8 storey perimeter blocks to 20 and 23 storey towers. The development generally scales up in height from west to east, with buildings fronting the linear park proposed at 7 storeys (sub-blocks B5 and C4), falling to 3-4 storeys along the boundary adjacent to lower buildings to the north and west in Woodcroft Mews. The two tall buildings form part of the 7-8 storey perimeter blocks. The site-wide massing strategy has also been informed by the requirements of London Plan policy 4B.16 (which deals specifically with the London View Management Framework) and the Mayor of London’s 2010 London View Management Framework (LVMF) Revised SPG. Core Strategy policy CS17 seeks to manage protected vistas, the London panorama and local views, landmarks and panoramas in accordance with this guidance.

7.6.18 The Core Strategy notes that, subject to meeting the criteria set out in CS18

(The location and design of tall buildings), Strategic Site allocations in Deptford and New Cross are, in principle, considered appropriate for the location of tall buildings to mark the scope and scale of regeneration that the policies in the Core Strategy will deliver. In this case the site also lies within the viewing corridor from Greenwich Park to St Paul’s Cathedral and so a detailed assessment of the impact of the proposed development on this protected view is required. Policy 18 and London Plan policy 4B.10 also note that tall buildings will need to be of the highest design quality.

7.6.19 The identified viewing location is close to the General Wolfe statue in

Greenwich Park, and the designated view takes in the River Thames, the Convoys Wharf site, and Aragon Tower. Iceland Wharf and some of the blocks on the Pepys Estate are also visible in the view. Beyond these, Tower Bridge, The Monument, and St Paul’s Cathedral can be seen. The background of St Paul’s Cathedral in the view is mostly unimpeded, with a silhouette of the dome clearly visible.

7.6.20 Section 7 of the Design and Access Statement applies the LVMF

assessment criteria and parameters to the site. The impact of the proposed development on this view is also examined in Chapter 19 of the ES (and ES Appendix 64a and 64b – Location H). This shows that the main viewing corridor crosses the north east corner of the site with the wider lateral assessment area (which is defined to provide a suitable setting for the relevant landmark and avoid buildings creating a canyon effect) crossing the site from its south-east to north-west corners. The taller of the two tall buildings (Block C1) lies outside this zone however the lower (20 storey) building (Block B1) encroaches marginally into the lateral assessment area corridor. The analysis submitted with the application demonstrates that the building is at the western periphery of this viewing corridor and whilst it will intrude into the lateral assessment area it is considered that it will not detract

from the setting of the main viewing corridor nor create a canyon effect as there is sufficient distance between the tall buildings at the Cannon Wharf site and those that form part of the wider view from Greenwich. More generally the tall buildings on the application site form part of a collection of taller buildings in the north Deptford area, and will be seen in the context of Eddystone and Daubney buildings in particular which also lie to the west of the viewing corridor.

7.6.21 At page 26 of the LVMF SPG, it is noted that the foreground and middle

ground of London Panoramas must be given careful attention, as development within these areas can greatly affect the designated view. The Cannon Wharf site falls within the middle ground in this case, and whilst the two tall buildings by virtue of their height will be clearly visible it is considered that they would be read with other tall buildings in the vicinity and not appear overly intrusive or prominent to the detriment of the view.

7.6.22 The applicant’s case for including two tall buildings on the site presented in

the Design and Access Statement is essentially an urban design one. Reference is made to the role of tall buildings as markers and points of recognition within the townscape, referencing Aragon Tower as a comparable. The detailed siting of the tall buildings is explained in terms of the intersection of the two main visual axes from Yeoman Street and Evelyn Street (Building C1) and the predominant east-west pedestrian route from the canal to the square on Cannon Wharf between Blocks B and C (Building B1).

7.6.23 Given that existing and proposed buildings in the immediate vicinity of the

site are generally up to a maximum of 8 storeys (with some buildings significantly lower) the two tall buildings will be very prominent in local and longer distance views. The Core Strategy (CS18) notes that subject to meeting various criteria tall buildings may be appropriate on Strategic Sites and at Cannon Wharf they will provide markers for the site and along the canal. Given the backland nature of the Cannon Wharf site and its restricted access from Evelyn Street (bounded on one side by the former railway embankment and on the other by the 5-storey Hazelwood House), the tall building aligned with the intersection of this route and the route from Yeoman Street will provide a marker for the development, and the second tower signals the connection to the canal. Whilst the principal route across the canal from the Marine Wharf West site is located further north (linking with the route between Blocks A and B on the Cannon Wharf site) there is a pedestrian route on Marine Wharf West that the southerly route as marked by the tower can connect with. As the application site and canal (both currently effectively inaccessible) will become integrated into the local urban fabric through the redevelopment of the Cannon Wharf site, the presence and location of the tall buildings is considered appropriate.

7.6.24 The proposed building height at 20 and 24 storeys is of a similar scale to the

other tall buildings in the wider area. The ES includes an assessment of overshadowing of the site and adjoining properties caused by the proposed development, as well as an assessment of daylight and sunlight to adjoining properties using the BRE’s guidance. The findings of the Vertical Sky Component (VSC) and Average Daylight Factor (ADF) tests are considered under the assessment of the ES (Section 8 of this report). The sunpath

analysis shows that the tall buildings will cast a shadow at different times of the day over the site and beyond, including the smaller residential properties in Croft Street, Woodcroft Mews and Acacia Close, the adjacent canal and Marine Wharf West site. Properties to the west and north will be affected from about 8.00-10.00am on 21 March/September and parts of the canal and sites to the east from midday onwards, with the 7-8 storey buildings also beginning to cast a shadow over the canal from about 2.00pm. The overshadowing is earlier/later and to a lesser/greater extent during summer/winter respectively. Given the orientation of the site and buildings, properties on the Pepys estate will not be overshadowed other than after about 7.00pm in June and then only the easternmost block on Rainsborough Avenue.

7.6.25 Within the site, routes will be in shadow by the tall buildings (and mid-rise

blocks) at different times of the day as will the south-east facing communal gardens on Blocks B and C. Whilst it is evident that the tall buildings (and some mid-rise blocks) will have a direct and noticeable effect on adjoining properties, these impacts will be transitory with the smaller residential buildings to the west and north being over-shadowed in the earlier part of the day only, and to a limited extent during the summer months. Given this situation it is considered that the overshadowing impacts from the tall buildings will not give rise to significant detriment to the amenity of adjoining residential properties or open space and are acceptable.

7.6.26 The design of the tall buildings has been the subject of significant criticism

from local residents, CABE and the Lewisham Design Panel and has undergone review and redesign by the applicant to seek to address these concerns. The plan form of the buildings has been reconfigured, the area of solid panel cladding has reduced and separated from the main structure, and the over-wrapping roof structure has been removed. More detailed changes include the introduction of horizontal ‘shadow gaps’ separating the buildings into a series of 3-storey elements linked by common materials and form, and offset vertical projecting ‘fins’ to break up the expanse of glazing. The glazing and balcony treatment has also been rationalised and simplified through a combination of inset balconies behind the solid panels and introduction of enclosed winter gardens. The effect of these changes is that the tall buildings now have a more lightweight appearance and read as a simple glazed building made up of linked elements partially framed by a more solid structure. Whilst the amended design has not been reassessed by CABE or Lewisham’s Design Panel it is considered that the tall buildings are now a significant improvement on their original form and detailed design. Whilst the tall buildings will inevitably be highly visible in the local and wider area given their height, for the reasons outlined above regarding the design changes it is considered that their design is now acceptable.

7.6.27 More generally, the proposed building heights across the site (with the

exception of the two tall buildings which are intended as markers for the site) provide a transition between the lower buildings to the west and taller buildings (as proposed) on the Marine Wharf West site. The proposed massing has emerged from the site analysis and in response to feedback from consultation with the Council and other consultees with the heights of individual blocks being adjusted to bring down the height of the larger blocks. This scaling back of building heights and is welcomed.

7.6.28 When viewed from the south (along the route of the former canal) the

proposed 7-8-storey blocks on the canal frontage are of a broadly similar height to buildings on the Marine Wharf West site (although the flat roofed blocks on Cannon Wharf will contrast with the more articulated and pitched roofs proposed for the canal buildings on Marine Wharf West) and this relationship in scale is considered acceptable. In the case of the tall buildings these will be very prominent in this view, particularly the building which fronts the canal. As noted above the detailed design and proposed materials of the tall buildings has been amended in response to comments from the Council and other consultees. These changes create a more lightweight feel to the buildings and on balance are considered acceptable.

7.6.29 The height of buildings on the northern edge of the site onto Yeoman Street

(the 6-7 storey Business Centre and 6 storey block J) will contrast with the existing lower 1-2 storey sheds and 2-3 storey open-sided industrial buildings on sites immediately adjacent which also form part of the Plough Way Strategic Site. There are, however, 5+ storey buildings further to the north on Yeoman Street. Although new building footprints and heights as part of the redevelopment of the Yeoman Street sites that form part of the Plough Way Strategic Site have yet to be agreed, it is considered that larger scale buildings than those existing would be appropriate and relate both to the context being created by the developments on the Marine Wharf West and Cannon Wharf sites as well as the larger buildings to the north. In this context the general scale of Blocks A and J on Cannon Wharf are considered acceptable.

7.6.30 In terms of massing across the site as a whole there are a range of building

heights which generally respond to the scale of the adjacent existing (and proposed future) buildings or structures. Building height generally increase from west (adjacent to the 2-storey houses in Woodcroft Mews/Acacia Close/Croft Street) to east (adjacent to the canal and 5-8 storey buildings proposed for the Marine Wharf West site. A concern was raised by the Council and consultees about the height of the courtyard blocks which were considered oppressive, both in terms of their presence on the internal street and in relation to the canal edge. The 8-storey buildings (plus recessed 9th floor) on the internal streets and 8-10 storey blocks fronting the canal have been reduced in height by 1-3 storeys. These changes helps reduce the overall scale of the development and potential sense of overbearing that the original buildings had, particularly within the site. The range in heights and differing elevational treatments will further assist in preventing blocks from appearing monolithic.

Streets and Routes

7.6.31 Core Strategy policy 4 (CS4) states that Mixed Use Employment Locations

(including Strategic Sites) will, through comprehensive redevelopment, be required to provide improvements to the overall environmental quality of these locations by providing where appropriate the provision of new, or improvement of existing, walking and cycling routes to public transport services and local facilities. The introduction of new east-west and north-south routes connecting beyond the application site allow for significantly greater permeability and connections with the surrounding area than exist at

the moment and will help integrate the site and its surroundings by addressing some of the existing barriers to movement in the area. The proposed layout of streets also complements, and forms a component of the North Lewisham Links programme currently being promoted by the Council.

7.6.32 The routes through the site are well defined by buildings that front them and

routes through the site will be clear and legible. Entrances to the buildings that line the main route in from Evelyn Street (Blocks D, and F) face onto this route with the entrances to the houses in Block F facing onto the open space in front of them. The majority of the ground floor space within the site is commercial with access to the blocks of flats generally located on the main routes thereby avoiding unobserved or hidden entrances. Units facing on the canal are generally accessed from a shared core/corridor within the blocks (with terraces onto the canal although 3 3-bed duplex units are accessed only from the canal side of the block. The Marine Wharf West development includes similar units accessed from the canal side of the blocks located at a similar point along the canal and it is considered that the provision of entrances to units from the canal will provide useful activity and surveillance.

7.6.33 The appearance of the commercial space at ground floor level has not been

detailed in the submitted drawings however these ground floor treatments can be dealt with at conditions stage. The submitted floor plans suggest that there will be scope for significant stretches of glazing at ground floor level, which would enable the uses within to animate the streets that they would line, and would improve natural surveillance of the street.

7.6.34 Overall, the experience of residents of and visitors to the developed site at

street level is considered acceptable.

Materials and Elevational Detail

7.6.35 Section 20 of the Revised Design and Access Statement describes the design, appearance and materials of the proposed blocks with a mix of architectural styles and materials proposed to provide variety across the site. Amendments have been made to the design and materials in response to comments from officers and other consultees and these are welcome.

7.6.36 The houses and lower rise buildings located towards Evelyn Street are to be

of brick construction comprising a simple elevation treatment with two storey ‘bays’ breaking up the elevation. This approach achieves a domestic feel to these buildings and is considered appropriate . Block D adjacent to the former railway embankment which steps up from 5 to 7 storeys comprises three separate elements with the two end blocks being faced in a brown brick and the central element ‘overlapping’ these two buildings in a contrasting white rendered finish with green laminated balconies set randomly on the elevation. The ground floor treatment is a consistent brick and glazing throughout. The contrasting use of materials and window treatments helps break up the length of the façade onto the main route into the site however the expanse of white render on this building (and elsewhere on the site) is a concern and whilst the overall elevational treatment of this building is considered acceptable it is recommended that the materials

palette is reviewed. Condition 5 is proposed which allows for officers to ensure the final choice of materials for each block is appropriate.

7.6.37 Block G which is located at the junction of the route from Evelyn Street and

Yeoman Street is a 5-storey building which projects over the pedestrian route at first floor level giving it a presence on the west-east route from Evelyn Street. It is proposed that the entire front elevation of this building is a red aluminium cladding with grey window frames and grey projecting balconies. At the rear the lower floors would be white render from ground to fourth floor with the upper recessed fifth floor in the red aluminium cladding. Objection has been received to the colour of the cladding system from residents in Woodcroft Mews. Whilst it is considered that the red top floor element will be only partially visible from these properties, the expanse of the material within the site needs further consideration. Condition 5 regarding materials samples is appropriate on a development of this scale and this will provide an opportunity to address this concern. The buildings on the western side of the site on the extension of Yeoman Street (Blocks H and J) are to be buff stock brickwork with a simple and regular elevational treatment for the residential units comprising regular window spacing and treatment with deep recessed terraces. This creates a somewhat bland appearance and so the choice of brick and detailed treatment of the elements should be subject to prior approval by the Council to ensure that this will help enliven this elevation.

7.6.38 The buildings opposite and extending along the routes to the canal (Blocks B

and C) adopt a similar design approach and materials palette to each other. The blocks comprise the main building set behind a ‘freestanding’ white precast cladding panel with projecting balconies using differing colours, and timber and textured precast panels set into the main elevation. The treatment of the blocks facing onto the canal route is similar although the lower floors comprise grey panels with coloured glass balconies and a glazed seventh floor with timber panels and setback from the main elevation. Block A on this frontage is brick clad with timber panels. Whilst the design of the buildings fronting the canal lacks the imagination and historical reference and resonance of those on Marine Wharf West opposite the design of the buildings is considered acceptable, creating a strong edge to the canal and enabling residents to enjoy this space either from balconies or with direct access from the ground floor units.

7.6.39 The Business Centre building is predominately white render frame and grey

window frames and contrasting grey spandrel panels. A translucent polycarbonate clad entrance block is also proposed on Yeoman Street. The footprint is staggered along its northern side following the boundary with the site beyond. The ground floor is raised to allow for semi-basement parking. This will present a retaining wall to the residential units opposite however these are at first floor and above (with commercial units and building entrances at ground floor level) and this relationship is considered acceptable.

7.6.40 A criticism of the original application from CABE was that the perimeter

blocks (Blocks B and C) try too hard to express their individuality by employing an indulgent mix of materials which only serves to emphasise their sameness. Whilst the revised approach is similar, the scaling down of

the buildings combined with simplifying the elevational treatment and identification of the corners results in a more satisfactory solution. Given the number of buildings on what is a constrained site with no meaningful street frontage a balance needs to be struck between a uniformity in building design (which could very easily become monotonous) and a wide variety to express ‘individuality’ (which could become a cacophonous clash of styles). Whilst there is a wide range of building styles within the site it is considered that, subject to some further refinement of materials, a reasonable balance has been struck. Subject to some further refinement of the materials used on some blocks (in particular the use of white render) and submission of materials samples to ensure that these are of an appropriate nature and quality the overall design of buildings is considered acceptable.

Design and Crime

7.6.41 Core Strategy policy 15 (CS15) (High quality design for Lewisham) states

that for all development the Council will ensure design acts to reduce crime and the fear of crime. The layout and design of the site means that public open space within the site and the route of the former canal would be overlooked, and would have private and communal entrances opening onto them, as would publicly-accessible routes through the site. With the exception of the canal front buildings entrances to all blocks would be located on the main street elevations passed by residents and members of the public walking or cycling through the site. The blocks facing onto the canal have access either at the eastern end of the pedestrian routes where they connect with the canal or from the canal itself. Without the works to the canal proposed by both the Marine Wharf West and Cannon Wharf sites and the onward connections into these sites from either direction these access points and units could be isolated and potentially unsafe. For this reason it is essential that the canal works are delivered before the units facing the canal are constructed. This will also ensure that the existing industrial use of the Marine Wharf West site is not reinstated with potentially adverse impacts on the Cannon Wharf site. Given the resolution to grant planning permission for the Marine Wharf West development and progress on concluding the legal agreement as well as the land owners expressed intent to commence development it is considered that such an outcome is unlikely. However to ensure compliance with the proposed development strategy the s.106 agreement will include a clause controlling the phasing of development on the Cannon Wharf site.

7.6.42 The proposed communal courtyards in Blocks B and C are intended for

residents however they would be accessible to members of the public. Parking areas beneath the courtyards would be gated and secure cycle parking provided within the blocks. The proposed internal layout of the residential units is generally acceptable with blocks with longer corridors serving more than 8 flats generally being served by two lift/stair cores. The exception is Block C4 which has 14 units served by a single core on the 1st-5th floors above ground level. On balance it is considered that the proposed layout and design raises no significant concerns in terms of crime and the fear of crime. No response to the Council’s consultation was received from the Metropolitan Police Crime Prevention Unit.

7.7 Transport

Introduction

7.7.1 This section of the report addresses issues relating to traffic impact and trip generation, highways works, car and motorcycle parking, cycling and cycle parking, servicing and construction traffic. National guidance on transport matters is found in PPG 13 (Transport) and PPS 3 (Housing). The most relevant general UDP policy is TRN 1 Location of Development - this policy directs high trip generating development to places where there are high levels of public transport accessibility and capacity, sufficient to meet the transport requirements of the development. UDP policy TRN 6 Employment Areas states that the Council will seek to improve public transport, cycling and pedestrian access to Defined Employment Areas. London Plan policy 3C.1 (Integrating transport and development) sets out a similar policy position whilst 3C.2 (Matching development to transport capacity) and 3C.3 (Sustainable transport in London) seek to ensure that development is related to transport capacity and that measures are taken to encourage movement to more sustainable modes of transport. Other more specific relevant local and London-wide policies are referred to later in this report, where appropriate. Core Strategy policy CS14 (Sustainable Movement and Transport) states that there will be a managed and restrained approach to car parking provision will be adopted to contribute to the objectives of traffic reduction while protecting the operational needs of major public facilities, essential economic development and the needs of people with disabilities. A network of high quality, connected and accessible walking and cycling routes across the borough will be maintained and improved including new connections throughout the Deptford New Cross area.

Traffic Impact and Trip Generation

7.7.2 Relevant UDP policies are TRN Location of Development, TRN 2 Travel

Impact Statements, TRN 3 Developer Contributions, TRN 4 Access for Public Transport, TRN 5 Green Travel Plans, TRN 10 Protection and Improvement of Public Transport and TRN 20 Improving Road Safety. Relevant London Plan Policies are 3C.9 (Increasing the capacity, quality and integration of public transport to meet London’s needs), 3C.13 (Improved Underground and DLR services), 3C.14 (Enhanced bus priority, tram and busway transit schemes), 3C.17 (Tackling congestion and reducing traffic), 3C.18 (Allocation of street space), 3C.20 (Improving conditions for buses), and 3C.21 (Improving conditions for walking). Core Strategy policy CS14 (Sustainable Movement and Transport) states that there will be a managed and restrained approach to car parking provision will be adopted to contribute to the objectives of traffic reduction while protecting the operational needs of major public facilities, essential economic development and the needs of people with disabilities.

7.7.3 The Transport Assessment submitted as part of the Revised ES estimates

vehicle trips that the proposed development would generate for different modes (private car, taxi motorcycle, public transport (bus, tube, rail) cycle and walk) and assesses their impact on the existing network and services. Given that the site is currently in use this is calculated on a net additional basis, taking into account existing parking and trip generation from the site.

The assessment has been undertaken using development traffic from Cannon Wharf and that from ‘committed’ schemes i.e. those with planning permission or likely to come forward in the near future (Oxestalls Road, Convoys Wharf, Marine Wharf West, Paynes and Borthwick Wharf, Creekside Village East and West, Greenwich Reach, Surrey Canal Triangle, Grinstead Road, Surrey Quays Leisure Site, Canada Water sites A, B, C & E, Mulberry Business Park, Downtown Road/Salter Road).

7.7.4 The trip generation arising from the proposed development has been

estimated using TRAVL data for six residential sites (surveyed between 2004 and 2008) and three business sites (surveyed in 1992), with modal split data from the 2001 census data. Given that the TRAVL data for the business uses is very dated the applicant prepared a revised methodology for calculating business trip based on the number of employees and the availability of on-site parking and updated to reflect the current proposed land use mix. This shows that trip generation for the business space (all non-residential space excluding the nursery) would be lower than from using the TRAVL data and so to ensure a robust assessment the higher traffic flows from TRAVL have been used. In the case of public transport trips the revised methodology shows a higher trip generation using the revised methodology compared with the TRAVL data and so this higher figure has been used. It is considered that the residential trip generation using the TRAVL data and amended methodology for the business uses provides a robust basis on which to undertake the impact assessment.

7.7.5 Using this information the applicant estimates the following net additional

week day peak hour trip generation:

AM Peak Public Transport Car

In Out Total In Out Total

Redevelopment Trips 135 219 354 80 100 180

Full Occupation - - - 38 22 60

AM vehicle trip attraction: net change +42 +78 +120

PM Peak Public Transport Car

In Out Total In Out Total

Redevelopment Trips 163 176 339 77 88 164

Full Occupation - - - 18 46 64

AM vehicle trip attraction: net change +59 +42 +100

Estimated weekday peak hour net additional trip generation

7.7.6 Impacts on the various public transport modes has been estimated by applying the split adopted for the Oxestalls Road site (around 50% of public transport trips are carried out on bus with the other 50% being carried out on rail/underground). This split has been agreed by TfL for that site and is considered by officers to be a reasonable basis on which to assess the Cannon Wharf site given their proximity and similar levels of accessibility to public transport services. In the case of Cannon Wharf given the distance to Deptford station it is unlikely that many people from the site will use that station and so it has been assumed that the rail/underground trips will be distributed evenly across the London Overground and Jubilee lines. Officers

concur with this assumption and this approach is considered a reasonable basis on which to assess impacts on public transport. Cumulative impact with other sites in the locality has been assessed using the data from the Marine Wharf West site as the sites adopted for the Marine Wharf West assessments have been agreed by TfL.

7.7.7 The Transport Assessment assesses the impact of these trips on the

highway network during the weekday AM and PM peak hours (08.00 – 09.00 and 17.00 – 18.00) looking at four key junctions: Rainsborough Avenue/Evelyn Street/Alloa Road and Yeoman Street/Plough Way. Link flow analyses were also undertaken on the wider road network, at several points at the edge of the study network. Development traffic has been distributed on the surrounding highway network in accordance with existing traffic flows. The percentage increase in traffic due to the development was calculated in five locations (Evelyn Street north of Rotherhithe New Road, Rotherhithe New Road, Bestwood Street, Alloa Road and Evelyn Street south of Rainsborough Avenue)

7.7.8 The original (2008) TA assessed junction capacity for an assumed opening

date of 2013 and the revised (2011) TA retains this as the assessment date, i.e. approximately Year 2 of the construction programme rather than completion of the development. As part of the analysis for the TA, and to justify this approach, the applicant has reviewed traffic flows along Evelyn Street using Annual Western Screen Line Traffic Counts to assess overall trends in the volume of traffic using this route. At the survey location closest to the site (by Blackhorse Bridge approximately 500m south of the junction with Rainsborough Avenue) between 1997 and 2010 total traffic flows between 7.00am and 7.00pm (using a three year moving average to ‘smooth out’ year-by-year fluctuations) decreased by 33%. Survey counts for the AM and PM peaks at this location (using the same method) show a small (3%) overall reduction in the AM peak between 1997 and 2010. For the PM peak the reduction was more significant at over 40% between 1997 and 2010. Whilst the survey data shows both increases and decreases on a year-by-year basis, the overall picture is one of decline and on this basis it is considered that the assumption in the Transport Assessment that there will be nil growth in traffic between the base assessment year of 2006 and projected (completion) year is reasonable.

7.7.9 Modelling of the identified locations using PICADY shows that at each

location the impact due to the development is below 5%, with a maximum impact of 3.2% calculated on Evelyn Street south of Rainsborough Avenue in the AM peak. As such the increase in traffic on the local road network attributable to the development is below the significance threshold for assessing impact. Analysis of the junctions where development traffic (Evelyn Street/Rainsborough Avenue/Alloa Road and Yeoman Street/Plough Way) joins the local road network shows that they operate within capacity with the ratio of flow to capacity (RFC) below the maximum desirable level of saturation (0.85). As such it is concluded that both the junctions will continue to operate satisfactorily under the additional loading of the development and committed development in the area.

7.7.10 Notwithstanding this conclusion, it is appropriate that measures are

introduced to encourage non-car modes and the applicant proposes that

there is a site-wide Travel Plan and traffic/transport related contributions including public transport service and infrastructure enhancements and a Car Club for residents and businesses.

Public Transport

7.7.11 In terms of the impact on public transport the Transport Assessment has examined the impact on buses, underground (at Canada Water) and London Overground (at Surrey Quays).

Additional Passengers

AM Peak (08.00-09.00)

PM Peak (17.00-18.00)

In Out Total In Out Total

London Overground 34 55 89 41 44 85

Jubilee Line 34 55 89 41 44 85

Bus 67 110 177 81 88 169

7.7.12 The Transport Assessment then translates the total passenger numbers

over the peak hour period into the number of additional passengers per train/bus. Based on a timetabled frequency of 12 trains per hour on the London Overground this equates to a combined total of an additional 7-8 passengers per train. Assuming the lowest peak frequency on the Jubilee Line of a train every five minutes in each direction (24 trains per hour) the development would generate an additional 3-4 passengers per train.

7.7.13 In terms of local buses, routes 47, 188 & 199 are within walking distance of

the site and using the lowest peak frequencies for each service, a total of 16 buses per hour, would result in 11 passengers per bus. The Transport Assessment does not consider likely preferences and therefore assumes that passengers will be spread evenly across all the services. The analysis does not though take into account existing public transport trips generated by the uses on site at present and so the net increase is likely to be lower.

7.7.14 The Transport Assessment concludes that existing public transport services

have capacity to accommodate the additional passengers that will be generated by the development. Officers agree with this conclusion however in the case of buses, cumulatively the development sites in the area will add significant numbers of additional passengers onto the existing bus services. Accordingly a contribution to bus service enhancements is appropriate and would be secured through the legal agreement.

7.7.15 In conclusion it is considered that the Transport Assessment and its

assumptions are reasonable and that the applicant’s conclusions regarding impacts in terms of the local highway network are generally accepted although the cumulative impact of this scheme with others in the area means that a financial contribution to bus services is required and the applicant has indicated their willingness to do this.

Highways works

7.7.16 The application proposes minor works to Rainsborough Avenue to allow for

a cycle contraflow into the site at the eastern access point with a cycle route between the wall and railway embankment. Given that this route is not

intended for motor vehicles this is likely to be a relatively safe route and subject to appropriate visibility splays being achieved is considered acceptable.

Car and motorcycle parking

7.7.17 Relevant UDP Policies are TRN 6 Employment Areas, TRN 23 Car Free

Residential Development, TRN 25 Controlled Parking Zones, TRN 26 Car Parking Standards and the related Table TRN 1, and TRN 28 Motorcycle Parking. Relevant London Plan policies are 3A.3 (Maximising the potential of sites) and the related Table 3A.2 (Density Matrix), 3C.1 (Integrating transport and development) and 3C.23 (Parking strategy). Core Strategy policy CS14 states that the car parking standards contained within the London Plan will be used as a basis for assessment.

7.7.18 Table TRN 1 of the UDP indicates maximum car parking standards and the

provision of spaces at a ratio of 40%, in combination with measures set out in the Travel Plan to encourage non-car modes and contributions to public transport services, is considered acceptable for this site. A concern has been raised by TfL regarding the impact on parking in surrounding streets due to the scale of development taking place in the Deptford and New Cross Area the area and overall number of parking spaces proposed across the Strategic Sites. At the moment this part of the borough is not covered by a CPZ although part of Plough Way (in LB Southwark) is part of a CPZ. Given the scale of proposed development in the vicinity (the Plough Way sites, Oxestalls Road and Convoys Wharf all located to the east of Evelyn Street) it is appropriate that at an appropriate time consultation with local residents is undertaken on a CPZ in the area and the applicant has agreed to a financial contribution towards this. Should a CPZ be agreed then it is intended that residents of the development would not be able to apply for on-street residents parking permits within the Zone.

7.7.19 In addition, to further reduce residents’ need to own vehicles the applicant is

proposing up to 6 spaces for Car Club vehicles on the site. This would be secured as part of the Section 106 agreement including membership for occupiers (residents and businesses) of the development. The facility would also be available for use by the general public. The Framework Travel Plan refers to the developer and Travel Plan Coordinator investigating the opportunity of a special introductory joining fee for residents of the on site and local Car Clubs to encourage uptake. As a minimum this should be the provision of a years free membership for occupiers of the site, in line with other recently approved schemes.

7.7.20 The provision of 33 car parking spaces for blue badge holders, 28 for the

residential units (i.e. 10% of overall residential car parking provision matching the 10% wheelchair accessible/adaptable units across the site) and 5 for the commercial units (i.e. 5% of overall commercial parking provision, in line with the standard in Table TRN1 of the Adopted UDP) is considered acceptable.

7.7.21 Parking for commercial uses comprises a total of 113 spaces (compared

with the existing 175 spaces including 2 for large goods vehicles). These would be located in the semi-basement car park beneath the business

centre (32 spaces) and either in parking courts or on-street. Parking standards in the UDP indicate a maximum provision of 1 parking space per 600m2 of B1 floorspace (Annex 4 of the London Plan suggests 1 space per 600-1,000m2). This would permit 6 spaces for the Business Centre and up to 11 spaces in total for the non-residential space assuming all of the floorspace was to be used for B1 purposes.

7.7.22 The London Plan also notes that it is not possible to prescribe parking

standards for mixed/multi-use developments as these differ widely and that the key to identifying parking provision is in a Transport Assessment supported by impact studies of large mixed use developments. In this case consideration has been given to existing parking levels on the site and the impact of development traffic on the local road network. Given these circumstances it was concluded that parking provision should be informed by the operational needs of the proposed commercial floorspace. Accordingly 75 spaces were identified for commercial parking, with an additional 38 spaces available to all uses on site, but primarily intended to cater for visitors to the commercial units. Whilst this is at a level significantly above the standards set out in the UDP this represents a net reduction in non-residential parking of around 35% , slightly higher than the reduction in building commercial floorspace on the site (around 20%). Therefore whilst the level of provision is above UDP and London Plan standards, subject to both the development and implementation of a Travel Plan to work towards reducing use of the private car and controls on the use of spaces as residential ‘overspill’ the level of provision is considered an acceptable.

7.7.23 28 residential and 11 non-residential motorcycle parking spaces are

proposed within the secure parking areas, equivalent to 10% of the proposed car parking spaces for the residential units and commercial space. Whilst no standard is set out in the relevant development plan this level of provision is above that recorded in the 2001 Census in respect of mode of travel to workplace and as a non-car mode of transport this is considered acceptable.

Cycling and cycle parking

7.7.24 Relevant UDP Policies are TRN 6 Employment Areas, TRN 14 Cycle

Parking, TRN 15 Provision for Cyclists and Walkers and TRN 16 Developing Pedestrian and Cycle Networks. The most relevant London Plan policy is 3C.22 (Improving conditions for cycling). Core Strategy Policy CS14 states that cycle parking will be required for new development and TfL guidelines will be used to assess provision. Design will need to incorporate safe and secure cycle storage and parking as well as other facilities including showers and lockers, where appropriate.

7.7.25 696 cycle parking spaces are proposed for residents in the secure parking

areas within each of the blocks. 53 are proposed for the commercial space including 30 outside the Business Centre. Visitor cycle parking would be provided in the form of on street parking stands. The proposed provision meets the requirements set out in UDP policy Table TRN 2 and is considered acceptable.

Servicing

7.7.26 All servicing and refuse collection would take place from within the site with refuse collection vehicles being able to travel through the site.

Travel Plan

7.7.27 A Framework Travel Plan, setting out overall strategy and specific measures

and targets to promote sustainable modes of transport by both businesses and residents on the site is included as an appendix to the Transport Assessment. This aims to achieve a 4% mode shift away from the car for residents and a 5% mode shift for commercial users of the site.

7.7.28 It proposes that a Travel Plan Coordinator will be appointed at least three

months prior to first occupation and will be responsible for overseeing the management, development, implementation, monitoring and review of the Travel Plan. It is proposed that the developer would fund the Travel Plan Manager for the first five years and thereafter funded by site occupiers.

7.7.29 It is considered that these key principles and proposals form an appropriate

basis for a detailed Travel Plan however the target levels of modal shift are lower than those considered achievable in the Borough Wide Transport Study (February 2010) which suggests an 11% shift from private car by a range of modes. It is recommended that the preparation, submission and implementation of a full Travel Plan to be secured as part of the Section 106 agreement with further consideration being given to achieving higher target levels of modal shift.

7.8 Environmental Sustainability

Introduction

7.8.1 UDP policy URB 3 refers to the contribution that developments make to energy and natural resource efficiency. Other UDP policies relating to energy in the Environmental Protection chapter of the plan have been deleted. Paragraph 2.4 of the Council's Residential Standards SPD encourages the inclusion of energy efficient and renewable energy technology and design. The SPD also refers to London Plan (pre-2008 version) policies regarding energy efficiency, renewable energy, water supplies and sustainable design and construction. These policies have been revised and strengthened in the extant (2008) London Plan – policies 4A.3, 4A.4, 4A.6, 4A.7, 4A.9, 4A.10, 4A.14, 4A.16 and 4B.1 are considered to be of most relevance to this case. In particular, policy 4A.7 Renewable Energy states that boroughs should “adopt a presumption that developments will achieve a reduction in carbon dioxide emissions of 20% from on site renewable energy generation… unless it can be demonstrated that such provision is not feasible”. London Plan policy 4A.1 (Tackling climate change) establishes an energy hierarchy based around using less energy, in particular by adopting sustainable design and construction (being ‘lean’), supplying energy efficiently, in particular by prioritising decentralised energy generation (being ‘clean’) and using renewable energy (being ‘green’). This approach is reflected in Core Strategy Policy 8 (CS8) (Sustainable design and construction and energy efficiency) which states that the Council will

explore opportunities to improve the energy standards and other sustainability aspects involved in new developments and that it will expect all new development to reduce CO2 emissions through a combination of measures including maximising the opportunity of supplying energy efficiently by prioritising decentralised energy generation for any existing or new developments (and in the Regeneration and Growth Areas using SELCHP as an energy source) and meet at least 20% of the total energy demand through on-site renewable energy. All new development comprising the creation of new dwellings will need to comply with the Code for Sustainable Homes by achieving a. Level 4 by 1st April 2010 and Level 5 by 2012. Development will be required to meet at least 20% of the total energy demand through on-site renewable energy.

Sustainability Proposals

7.8.2 The sustainability proposals for the development have been the subject of a

series of revisions and updates in the light of feedback from the Council and GLA. The Revised Energy Report (April 2011) seeks to demonstrate how relevant CO2 reduction targets are to be achieved and consideration is also given the viability of renewable energy sources. The Report states that all residential units will be designed and constructed to meet Code for Sustainable Homes (CfSH) Level 4 and the commercial space will achieve BREEAM rating ‘Excellent.

7.8.3 The Revised Energy Report states that regulated CO2 emissions savings of

14% (7% including unregulated energy use) will be achieved through the use of energy efficient measures (i.e. lean), increasing to 67% (35% including unregulated) through the use of on-site gas-fired CHP giving a total energy saving of 71% (35% including unregulated use). Earlier proposals for a biomass boiler (as a renewable energy source) were discounted on air quality grounds. The CHP will provide a community heating system with a single energy centre for the Cannon Wharf site served by a single heat network details of which will be secured by condition.

7.8.4 The Council’s Sustainability Officer and the GLA have also promoted

connection to a district heating network linked to SELCHP. This system is not yet in place and therefore the proposed development would allow for the possibility of a future connection to SELCHP subject to this being technically and financially viable and compatible with the construction programme. In the circumstances it is accepted that, at the present time a commitment to connecting to SELCHP being made prior to the determination of this application is not feasible however future-proofing for a connection should this become available is appropriate and will be secured by condition.

7.8.5 The scheme would achieve a carbon saving of 71% on regulated energy use

(35% including unregulated) which is above the London Plan target. The applicants have stated that the use of renewables through photo-voltaics is not cost efficient in terms of the carbon emission savings achieved and in the circumstances given the high CO2 reduction achieved in this scheme the failure to include renewables is accepted. As noted above the applicant has committed to CfSH Level 4 and it is considered appropriate for the Council to require by condition the submission of confirmation that the proposed score has been achieved in each phase post-construction.

7.8.6 London Plan policy 4A.11 (Living roofs and walls) expects major

developments to incorporate living roofs and walls where feasible. Living roofs are proposed on blocks (except for the houses and blocks E and F which are considered by the applicant to be too small). This is a significant improvement on the original proposals and subject to detailed design and specification is welcome. Implementation of the living roofs (to a specification agreed by the Council) will be secured by condition.

7.8.7 The applicant refers to the Mayor of London’s Sustainable Design and

Construction SPG (May 2006) and in the ES identifies targets to achieve sustainable construction methods including the minimisation of waste and re use of reclaimed or recycled materials in line with the SPG standards. This will be delivered through a Site Waste Management Plan which will be secured by condition.

7.9 Other Planning Considerations

Neighbour Amenity

7.9.1 Policies HSG 4 Residential Amenity and HSG 5 Layout and design of New

Residential Development seek to ensure that new developments are designed so that the amenities of existing residential properties are not unacceptably harmed. Policy ENV.PRO 11 Noise Generating Development aims to resist development that could lead to unacceptable levels of noise. The Council’s Residential Development Standards SPD states that developers will be expected to demonstrate how privacy would be provided for occupiers of neighbouring housing, noting that unless otherwise demonstrated that privacy can be maintained through design, there should be a minimum separation of 21 metres between directly facing habitable room windows which would need to be increased where higher buildings are involved.

7.9.2 Overshadowing has already been assessed in Section 7.6 of this report

under ‘Height, Massing and Tall Buildings’ Privacy and Overlooking

7.9.3 The majority of the proposed residential accommodation would be

positioned generally in excess of the 21m from neighbouring properties and have no significant impact on privacy. The 3-storey houses in Block E are close to the boundary with properties in Acacia Close with building-building distances down to 12m at the closest point, although an oblique view. Building-building distance between the 2-storey houses in Block E and Hazelwood House would be a minimum of 15m. In both cases the layout of the houses has the staircase at the rear of the properties (and a small study) in which obscure glazing could be provided to avoid overlooking. Rooftop open space for the houses in Block F (and 2 storey houses in Block E) will be screened to ensure privacy of adjoining properties. Both of these measures will be secured by condition.

7.9.4 The development does propose buildings which are higher than those

surrounding, significantly so in the case of the two tall buildings. Objections

to the proposed development have been received from the occupants of properties surrounding the site on the grounds of loss of privacy and overlooking. However, it is considered that, even with the taller buildings, window-window distances (generally greater 25m or greater and 30m for buildings more than 4 storeys) are acceptable. Subject to balconies not being provided to the rear of Building J where the building to site boundary (though not building-building distance) is reduced then the layout is considered to be acceptable. This would be secured by condition.

7.9.5 Buildings on either side of the proposed linear park along the route of the

former canal would be 30 metres apart which is acceptable.

Publicly Accessible Open Space and Landscaping 7.9.6 The submitted Design and Access Statement provides a description of the

proposed landscaping strategy for the site. This includes the publicly-accessible soft landscaped open space and play area in front of the Block F Houses (453m2) as well as communal gardens in the form of podium level gardens which will be accessible to all residents within the blocks in which they are located. This is in addition to the private amenity space for the houses comprising gardens and courtyard spaces. In addition there are areas of hard landscaping within the site including the central square.

7.9.7 The communal amenity space (in addition to private balconies provided for

the majority of units) comprises:

Block Units Communal Amenity Space

A 33 0

B 210 1,459m2

C 249 1,731m2

D 61 249m2

E 6 0

F 13 0

G 42 349m2

H 33 146m2

J 33 67m2

Houses 16 Private amenity space

Shared 453m2

7.9.8 The communal courtyards for residents of Blocks B and C would provide the

largest amenity spaces for residents of the development, with half of this space (i.e. 1,595m2) identified as ‘useable playspace’. Whilst it is intended that these spaces are for the residents in the respective blocks that enclose them they are accessible from street level and so could be accessed by residents from other blocks (or the public). These spaces are south/south-east facing and so would receive direct sunlight with overshadowing being only transitory as the sun moves during the day, providing useable and attractive outdoor space for the residents of the proposed development.

7.9.9 In addition the application proposes the landscaping of the route of the

former canal which would provide approximately 0.5ha of public open space.

As noted elsewhere in this report, the planning application for the adjacent Marine Wharf West site (the applicant for which owns the former canal route) includes proposals to landscape this area which will be secured through the s.106 agreement. Should, as is anticipated, these works be undertaken by the developers of Marine Wharf West then the developers of Cannon Wharf would make a financial contribution, secured through the legal agreement, to the landscaping of the canal route to the south thereby significantly improving public open space within the vicinity of the site.

7.9.10 A key feature of the urban design principles for the Plough Way Strategic

Site set out in Core Strategy policy SSA5 is to create accessible cycle and pedestrian linkages along the route of the former Surrey Canal to provide a safe, attractive public route celebrating this historical use and helping to tie the site with the Oxestalls Road strategic site and the nearby Pepys estate. This is provided for within the site-wide masterplan for the Plough Way site and would provide open space for the Plough Way site as well as connect with sites to the north and south. Given the fact that flats on the Cannon Wharf site overlook this area it is crucial that these works are delivered before the development of the blocks on Cannon Wharf that adjoin this space. This approach to phasing would be secured through the s.106 agreement.

7.9.11 In terms of the amount of public open space proposed, all of the application

site is within an area of public open space deficiency. UDP policy OS 8 states that, at sites within deficient areas, the Council will negotiate with developers for new provision of public open space, and that public open space will be sought within housing schemes. It is considered that with the provision of the linear park (or contribution to the landscaping of the route to the south) this policy requirement would be met.

7.9.12 Landscaping proposals for the public, communal and private spaces in the

Design and Access Statement are indicative, with illustrations of the type and quality of space to be created but without specifying materials or fixing any details other than the overall size of the spaces. Whilst the generality of the proposals suggests the potential for achieving a high standard of design this is an area requiring considerable further work. An appropriate condition requiring details of the hard and soft landscaping of all unbuilt parts of the site to ensure a high quality scheme is delivered is proposed.

Boundary Treatment and Trees

7.9.13 There are few trees or shrubs within the site and all those other than along

the site boundaries will be removed. The existing boundary of the site with residential properties in Hazelwood House, Acacia Close, Woodcroft Mews and Croft Street is a mix of brick walls, fences and railings of varying heights. There are also a number of trees (of varying types, age and condition) located within the site along these edges although a plan showing trees to be removed/retained is not included with the application documents. The application proposes that the existing boundary treatment is retained in some places (for example the existing boundary wall with Hazelwood House) but replaced with new railings adjacent to the car park in Woodcroft Mews. Given the proximity of existing residential properties to the application site is considered that further details of the treatment of the boundary need to be

provided and also clarification of trees to be retained, removed and replaced in order to ensure that the amenity of adjoining properties is maintained or improved.

7.9.14 Indicative landscaping proposals for within the site are described in the

Design and Access Statement which also explains the strategy that has informed the ground level landscaping as well as the treatment of the raised podiums. This includes tree planting within the site and the laying out of the podium gardens to provide a mix of environments. Tree planting is proposed along the key routes however little detail is provided in terms of species. Landscaping proposals for the route of the former canal are in sketch form and considerably more work is required to satisfactorily demonstrate that should the applicant undertake the landscaping of the canal that a high quality scheme will be delivered. The drawings are also vague about finished levels on the application site and canal and measured survey drawings should be submitted prior to commencement to ensure that proposals for the canal and new buildings tie in.

7.9.15 It is considered that significant additional detail of the landscaping proposals

is required and should be submitted prior to commencement on site with detailed approval of each phase. Conditions requiring the adequate protection of trees to be retained and the replanting of any trees that fail within 5 years of planting are also recommended.

7.9.16 It is understood that maintenance of the proposed development’s

landscaping would be the responsibility of the development’s management team. Given the proposals to open up routes through the site and consequential significant areas of public realm it is appropriate that as well as ensuring public access is provided, that these areas are maintained to an appropriate standard. This would be secured through the s.106 agreement.

Ground Levels

7.9.17 As noted above, finished ground levels along the eastern edge of the site

where it adjoins the canal need to be clarified. Although parking is generally above ground level some excavation work will be required for the semi-basement car park under Block A as well as excavation to deal with any site contamination remediation. In the circumstances a proposed/finished site levels plan including sections along the eastern edge of the site, secured by condition, should be submitted prior to commencement.

8. ENVIRONMENTAL IMPACT ASSESSMENT

8.1 Introduction

8.1.1 The planning application is accompanied by an Environmental Statement

(ES) that reports on likely significant impacts arising from the proposed development and proposed mitigation. The ES considers the impact of the development in terms of the following topics:

• Air Quality • Archaeology • Construction

• Daylight and Sunlight • Ecology • Ground Conditions and Contamination including Ground Water • Micro-climate (Wind) • Noise and Vibration • Socio-economics • Telecommunications and Interference • Transport • Waste • Water Resources, Drainage and Flooding • Townscape and Visual • Cumulative Effects • Residual Effects

8.1.2 The ES has been reviewed by specialist consultants, Capita, appointed by

the Council to assess whether the ES meets the relevant regulatory requirements and guidelines in respect of the scope and format of an ES; whether there is sufficient clarity about the development for which planning permission is being applied; whether the methodology adopted to assess the likely significant effects for the identified topics is sufficiently robust for the effects to be assessed and for appropriate mitigation to be identified; and to identify any significant gaps in the methodologies and assessments which would prevent the Council from making an appropriately informed decision on the likely significant effects of the proposed development.

8.1.3 The advice to the Council was that the original ES was deficient in a number

of areas for the Council to be able to make a decision on the planning application without seeking further information. The Revised ES includes additional chapters and further information to specifically address the points raised including the assessment of the water environment (groundwater and surface water) and micro-climatic effects. In general the approach to assessment is considered acceptable and, as revised, meets the relevant Regulations although it is noted that there the Revised ES uses the original baseline data.

8.1.4 The following section sets out the Council’s consideration of the identified

impacts and proposed mitigation based on advice from its consultants. Transport (other than construction traffic impacts) is considered earlier in this report in Section 7.7.

8.2 Air Quality 8.2.1 With the UDP policy on air quality (ENV.PRO 8) now deleted, the relevant

development plan policy is London Plan policy 4A.19 (Improving air quality), which states that “boroughs should…achieve reductions in pollutant emissions and public exposure to pollution by…ensuring at the planning application stage, that air quality is taken into account along with other material considerations, and that formal air quality assessments are undertaken where appropriate, particularly in designated Air Quality Management Areas”. Chapter 6 of the ES addresses local air quality, noting that the site is within an AQMA and that, given the location of the site, some variation in air quality will occur across the site, with the highest pollutant

concentrations be closest to Evelyn Street, gradually declining across the site with increasing distance from Evelyn Street.

8.2.2 The Revised ES includes a chapter on ‘Construction’ which outlines the

activities and likely plant and equipment to be used during the different stages of construction. In the case of air quality impacts are identified as coarse and fine dust from construction activities including demolition, excavation, earthmoving, materials storage and movement of construction vehicles; and construction plant, both mobile and stationary (e.g. cranes and generators), which emit a mixture of exhaust gases, in particular PM10. In the absence of detailed information regarding the number and type of construction vehicles likely to be used during the construction phase and given difficulties in accurately predicting and quantifying the likely impacts from construction dust emissions the assessment concentrates on providing a qualitative assessment of nuisance risk from construction dust on nearby receptors. A generic method statement for the control of dust at demolition and construction sites is included as an Appendix to the ES. In addition ‘Construction Ecological Management Plan: Draft Heads of Terms’ has been submitted (separately from the ES) setting out a proposed demolition and construction methodology and taking into account the Council’s Code of Practice for the Control of Pollution & Noise from Demolition and Construction Sites.

8.2.3 The ES states that properties in the vicinity of the site are likely to

experience impacts as a consequence of the construction activities (with the highest impacts likely to occur at properties located along Rainsborough Avenue, Acacia Close and Woodcroft Mews and at Hazelwood House) with the potential for dust impacts higher during the initial construction period as a result of demolition, earth works and excavation activities and lower during the later part of the construction process. Without mitigation the ES assesses the risk of impacts from dust and emissions from construction and demolition as ‘high’. Mitigation of construction impacts is to be secured largely through the agreement and implementation of a detailed Construction and Environmental Management Plan (CEMP). With mitigation the residual effects are assessed to be short term and of minor negative significance. Subject to ensuring that appropriate controls are in place and enforced officers concur with this conclusion.

8.2.4 In terms of operational impacts the ES states that the proposed development

(comprising residential and specified commercial uses) is not of a type which would be expected to give rise to significant air quality impacts, with the main impact on local air quality predicted to occur from exhaust emissions associated with vehicle movements generated as a result of the proposed development. Given the proposed uses on the site officers consider this is a reasonable premise for assessing the likely significant effects of the proposed development and that operational impacts will largely be as a consequence of traffic from the development rather than activities taking place on the site.

8.2.5 The revised ES assesses the impact of increases in vehicle emissions as a

result of committed developments for 2010, rather than updating to reflect the likely future year of operation that represents worst case, on the basis that were the assessment to be carried out again for 2018 it is unlikely that

the impacts would be significantly different and therefore the conclusions of the assessment would remain unchanged. Following clarification, officers accept this assertion. In terms of the assessed impacts from the proposed development there will be an increase in annual mean NO2 and PM10 concentrations, with the highest increase predicted at the point of maximum concentrations (Evelyn Street). The proposed development is predicted to increase annual mean NO2 concentrations by 0.2µgm-3 at the point of maximum concentration. Predicted annual average concentrations for NO2 is 60µg/m3 at some locations which means that the objective for the hourly average is in danger of being exceeded and mitigation to reduce emissions (including implementation of the Travel Plan to reduce car use as well as a financial contribution to support measures in the Council’s AQMA) are to be secured through the s.106.

8.2.6 Impacts on local PM10 concentrations are predicted to be less, with a

predicted increase of 0.1µgm-3 at the point of maximum concentration with no change in the number of days exceeding the short term objective limit and no change in PM10 concentrations are predicted to occur at any of the identified receptor locations. The modelling concludes that PM10 concentrations will meet the 2004 annual mean PM10 objective and the 24-hour objective but will exceed the more stringent, though provisional, 2010 objectives. The ES concludes that the operational impacts of the Cannon Wharf development on its own will be ‘negligible’.

8.2.7 Taken cumulatively with other committed developments in the area the

development will result in a maximum increase in nitrogen dioxide and PM10 concentrations of 1.7µgm-3. This increase is predicted along the centre of Evelyn Street where concentrations are highest whereas at locations away from Evelyn Street concentrations are predicted to increase by a maximum of 0.7µgm-3.

8.2.8 The proposed development will also introduce new residential receptors into

an AQMA and therefore under London Councils Air Quality and Planning Guidance (2007) air quality is a ‘major consideration’ in the determination of the application. NOx concentrations are predicted to be over 5 % above the annual mean objective of 40 µgm-3 across the whole site and would therefore fall within Air Pollution Exposure Criteria (APEC) ‘C’. In such cases “refusal on air quality grounds should be anticipated, unless the Local Authority has a specific policy enabling such land use and ensure best endeavours to reduce exposure are incorporated.” Mitigation measures must be incorporated within the development, aimed at reducing future exposure of both residents and workers to elevated pollution concentrations.

8.2.9 Mitigation of impacts is proposed through a combination of a financial

contribution to assist in air quality monitoring and developing and implementing the Council’s Air Quality Action Plan, with operational impacts mitigated through the implementation of Travel Plans aimed at reducing the number of vehicles accessing the site and encouraging the use of alternative methods of transport for both the residential and commercial/retail areas of the development. The site is identified for redevelopment as part of the Council’s Core Strategy and although options for mitigation to deal with existing air quality problems are limited it is considered that the proposed measures will contribute to the Council addressing air quality issues through

its Air Quality Action Plan and are to be secured by through the legal agreement.

8.2.10 The applicant’s assessment has had to make certain assumptions regarding

the proposed CHP facility which predicts that NOx levels within the site (affecting new residents) are likely to be above target levels. Because the detailed specification of the CHP facility has not been fixed it is considered appropriate that the specification of the CHP facility is submitted to the Council for approval to ensure that air quality standards are not breached.

8.3 Archaeology 8.3.1 PPS5 sets out national planning policy in relation to the historic environment.

At the regional level London Plan policies 4B.11 (London’s built heritage), 4B.14 (World heritage sites) and 4B.15 (Archaeology) are relevant. Core Strategy Policy CS16 (Conservation areas, heritage assets and the historic environment) and UDP policy URB 21 Archaeology are also relevant.

8.3.2 All of the application site is within an Area of Archaeological Priority in the

UDP however it is not within a conservation area and does not include any listed or locally listed buildings. The nearest listed buildings are the Grade II listed Royal Victoria Yard entrance and cannon posts on Grove Street, approximately 150 metres away from the southeast corner of the application site. Beyond these, further southeast, are other Grade II listed buildings that formed part of the historic dockyard. To the east, over 200 metres away from the application site, is the Grade II listed parish boundary stone (dated 1819), wall and pier at St George’s Wharf. The nearest conservation area within the Borough is at Deptford High Street, some 1.2 km to the southeast, while the Thorburn Square and St Mary’s Rotherhithe conservation areas are located further away within LB Southwark. Given the site’s location in relation to relevant conservation areas and listed buildings, and the intervening development, it is considered that the proposed development would not adversely affect the setting or appreciation of these heritage assets.

8.3.3 Maritime Greenwich World Heritage Site is located approximately 2 km away

from the application site and London Plan policy 4B.14 states that boroughs should take account of and give appropriate weight to the provisions of the World Heritage Site Management Plans. The 1998 Maritime Greenwich World Heritage Site Management Plan discusses the importance of the setting of the WHS and important river views, but does not set out policy or guidance on appropriate building heights at sites as far away from the WHS as Cannon Wharf. As noted elsewhere in this report in respect of the protected view of St Paul’s Cathedral (Section 7.6) the proposed development would be visible from the Maritime Greenwich World Heritage Site (General Wolfe statue). This is assessed in the ES as part of the ‘Townscape and Visual’ chapter.

8.3.4 In terms of the site itself the ES concludes that the site has a low potential

for significant archaeological remains of all periods. In terms of palaeoenvironmental importance, geotechnical investigations at the site reveal that the site has been heavily truncated and contaminated and only a localised presence of peat deposits have survived. The ES concludes that

the site has a low palaeoenvironmental potential. With regard to industrial archaeology the ES concludes that the former 19th century buildings and their related industrial processes and the construction of the Surrey Canal and an associated timber pond (West Pond) within the application site are of some local interest. Assessing the impact of the proposed development the ES notes that piled foundations will be used which will have a localised impact on below ground deposits although as the buildings do not include basements excavation is not required. The ES concludes that construction impacts from the proposed development would be minor/negligible with no effects from the completed development. Mitigation would be in the form of a detailed documentary history to be phased ahead of construction works.

8.3.5 The ES is considered to be an acceptable assessment of the site’s potential

for archaeology and cultural heritage. Whilst the assessment and proposed mitigation is considered reasonable in principle, given the need for decontamination of parts of the site and associated excavation works (and likely excavation of the route of the former Grand Surrey Canal which could also have a deleterious effect upon any archaeological deposits within 1 to 2 metres of the modern ground surface), officers are of the view that mitigation in the form of a programme of archaeological work in accordance with a written scheme for investigation to be approved by the Council is appropriate. This will be secured by a condition.

8.4 Construction 8.4.1 This Chapter describes the proposed programme of the demolition and

construction works and summarises the key activities that will be undertaken as part of the proposed development. It identifies, in general terms, the likely potentially significant short-term, local environmental impacts associated with the activities and outlines the proposals for their mitigation. Detailed consideration of impacts during the demolition and construction works and proposed mitigation measures are provided in the relevant technical chapters of the ES e.g. noise, air quality, ecology etc. Reference is made to the adoption of best practice in demolition and construction activities to determine an appropriate Construction Environmental Management Plan (CEMP) suitable for the proposed development. As noted above (8.2) this would take into account the Council’s Code of Practice for the Control of Pollution & Noise from Demolition and Construction Sites.

8.4.2 The ES notes that because contractors are not yet appointed, detailed

methods and techniques of working are not known. However the ES does identify the likely scope of works and equipment used during site preparation, demolition and remediation, sub-structure works (including likely piling methods) and during superstructure construction and fit out. This is considered to provide a reasonable basis on which to assess construction impacts and to meaningfully inform a framework for the management of environmental impacts during the works through the CEMP. This will define the broad policies, procedures and a management framework for the implementation of specific controls and Draft Heads of Terms for this document have been submitted which is considered to be broadly acceptable as an outline of the scope of mitigation measures. Given the stage the project is currently at, this approach, including the proposed

mitigation strategy, is considered acceptable and will be secured by condition.

8.5 Daylight and Sunlight 8.5.1 The assessment of daylight, sunlight, overshadowing impacts of the

proposed development and assessment of amenity issues has been based on the guidelines set out in the BRE Report “Site layout planning for daylight and sunlight: A guide to good practice” (1991). All residential property with a view of the site and whose windows could be affected by a reduction in daylight or sunlight were identified and amenity space around residential buildings was identified in terms of overshadowing impacts. The impact of glare from the proposed tall buildings is described but not assessed quantitatively.

8.5.2 Daylight was assessed using Vertical Sky Component (VSC) and Average

Daylight Factor (ADF) methods. The ES states that of the 286 assessed neighbouring residential windows, 222 would receive less daylight but retain at least 0.8 the former value or more than 27% VSC, described as a negligible impact, with 5 receiving unchanged or improved daylight (a negligible beneficial impact). The remaining windows will receive less daylight, being both less than 0.8 the former value and 27% VSC and were subject to further assessment. This concluded that 41 of these windows retain VSC values that are so close to 27% VSC and/or have values so close to 0.8 the former value, that they are imperceptibly different from the BRE guidance.

8.5.3 Of the remaining windows where impacts were more significant, the majority

of these are on the ground and first floor levels of Hazelwood House. In this case the existing access walkways already significantly reduce the light that many of these windows receive. These windows are fairly evenly divided between kitchens, bedrooms and bathrooms and for assessment purposes kitchens and bathrooms are classified as non-habitable. In the case of bedrooms BRE guidance states that they should be analysed but are less important than main living rooms. Taking the existing condition, building structure, use of rooms and urban character of the area into account the ES describes the impact on these windows as ‘minor adverse’. The balance of affected windows are in properties in Woodcroft Mews where 10 of the 35 ground floor windows and 4 of the first floor windows are affected. Nearly all affected ground floor windows serve bathrooms and kitchens (i.e. non habitable space) and the first floor windows are likely to serve bedrooms which are relevant but of less importance than living rooms. The ES also notes that the outlook from these properties will be improved by replacement of an industrial dilapidated shed with a modern residential building. In the circumstances the ES assess the impact as ‘moderate adverse’.

8.5.4 In the case of the proposed development of the adjacent Marine Wharf West

development the ES has assessed the nearest ground floor rooms. The assessment concludes that all would satisfy BRE criteria, other than one bedroom but which would still be within 10% of the recommended level. The ES describes the impact as ‘minor adverse’ effect, in a single location.

8.5.5 The assessment of sunlight has considered 51 windows including the ground floor of Marine Wharf West and concludes that there will be relatively small variations in annual probable sunlight hours, some with very minor losses or gains and all satisfying BRE guidance. The only exception is a single room in Marine Wharf, but annual sunlight availability would, at 23%,

remain very close to BRE‟s recommended 25%. The overall impact is

assessed as ‘negligible’. The assessment of overshadowing concludes that at 21st March there will be no overall adverse effect on the shading of neighbouring residential property and amenity space. The degree of shadow impacting on the rear gardens of Acacia Close is assessed to be slightly reduced, with an increase to one end of Woodcroft Mews in the early morning hours only and to the closer elements of Marine Wharf in the afternoon. The impact is described as ‘negligible’.

8.5.6 Officers consider that the ES has appropriately assessed likely impacts in

terms of daylight, sunlight and overshadowing on the surrounding area. Given the built up nature of the surrounding area the level of impact in terms of those properties receiving below recommended levels of daylight is limited to a few windows. Given the nature of the impacts mitigation is not feasible other than by material changes to the scheme to amend the layout and/or building heights to increase the level of daylight to affected rooms. Given the acceptability of the scheme in other respects the impacts in terms of daylight, sunlight and overshadowing arise for a limited number of rooms and on balance are considered acceptable.

8.6 Ecology 8.6.1 UDP policy OS 13 Nature Conservation states that the Council will have

regard to the nature conservation value of all sites to be developed, and will seek to protect and enhance these. London Plan policy 3D.14 is also relevant. The part of the application site that includes the former route of the Grand Surrey Canal forms part of a Site of Nature Conservation Interest although this has been periodically cleared of vegetation. This designation continues southwards beyond the application site along the former canal route, and also westwards along the former railway embankment that runs parallel to Rainsborough Avenue. The entire site is in an Area of Nature Conservation Deficiency as set out at Map 3.3 in the UDP.

8.6.2 The ES describes the existing ecological interest of the site and surrounding

area, informed by a database search which revealed a number of rare, protected or UK Biodiversity Action Plan Priority animal species had been recorded within 1 km of the site (Black Redstart, House sparrow and Bats) and a Phase 1 habitat survey undertaken in 2007 and updated in May 2011 (including a bat survey). The potential adverse impacts from construction of the development are identified as including habitat loss during site clearance and preparation (affecting most of the vegetation on the site (including a mature ash by the Cannon Wharf Business Centre) and the route of the former Surrey Canal) and possible dispersal of Japanese knotweed during breaking-out and foundation works; degradation of off-site habitats during construction, caused by dust deposition on foliage and run-off of effluent containing oil and chemicals; compression of soil by construction activities causing damage to roots of trees to be retained; and noise disturbance. Operational impacts from the completed development include noise and light

pollution, particularly artificial light cast from the south façades of Blocks C and D onto the former railway embankment.

8.6.3 Mitigation during construction would be through the CEMP. On completion

the development proposed mitigation would be in the form of green/brown roofs on all buildings (except houses and blocks E and F), planting of trees along internal roads and paths, planting within each podium and in green amenity areas, and the removal of scrub along the former Surrey Canal and planting (using native species).

8.6.4 The ecological assessment is considered acceptable in the light of the

updated (2011) survey material. Furthermore, it is generally accepted that mitigation measures proposed by the applicant (including the planting of native trees, creation of living roofs, and provision of bird and bat boxes) would result in a positive residual effect in terms of the site’s ecological interest and biodiversity. Whilst scope for preventing the emission of artificial light at night from individual residential or commercial units in a high density mixed use development of the type proposed is limited, the exterior lighting scheme would be designed to direct light onto roads, paths and other public areas and to minimise loss of light laterally and upwards. In the circumstances a condition requiring details of measures and implementation of a full scheme of ecological enhancement as part of the landscaping scheme is recommended, as is a condition requiring the submission of a habitat management plan. This plan should contain a built-in review period and a commitment to post-completion ecological surveying to demonstrate and promote the success of the ecological enhancement required of and proposed by the applicant.

8.7 Ground Conditions and Contamination (including Groundwater) 8.7.1 National planning policy relating to contaminated land is set out in PPS 23.

UDP policy ENV.PRO 10 Contaminated Land is also relevant. Following a review of the original ES by specialist consultants appointed by the Council it was noted that the document make only passing reference to groundwater and further assessment was recommended to address the identified shortcomings.

8.7.2 The Revised ES sets out the findings of a desktop review of the site’s history

including records of nearby asphalt, tar and timber works, rubber works, saw mills, engineering and other works, from geotechnical investigations and contamination testing including land gas monitoring. Specific regard is also had to groundwater conditions and potential pathways for contamination migration on- and off-site. The ES reports elevated concentrations of methane at three locations in the eastern and northern parts of the site associated with depleted oxygen levels, and gas flow rates which indicated that ground gas is being generated on this part of the site. The ES suggests that this is a result of hydrocarbon contamination identified at these locations and that gas protection measures would be required within the majority of buildings developed across the site. Protective measures could include a reinforced concrete floor slab, the sealing of all joints and penetrations, proprietary gas resistant membrane and passively ventilated or positively pressurised underfloor sub-space, oversite capping or blinding and in ground venting layer in the relevant locations. The ES also notes that the affected

locations were relatively close together and that remediation within these areas would reduce the elevated concentrations of gas. Assessment against the National House-Building Council (NHBC) Traffic light system for the proposed low rise residential development in the south-west and east of the site has indicated that these areas are considered to be under a ‘Red’ Classification where further gas risk assessment and/or the reduction of the source of the gas would be required prior to development.

8.7.3 Elevated concentrations of metals were reported within the Made Ground,

notably arsenic and lead and significantly elevated concentrations of individual Polycyclic Aromatic Hydrocarbon (PAH) species along with elevated cyanide concentrations. Significantly elevated concentrations of Total Petroleum Hydrocarbon (TPH) were detected across the northern, central and eastern parts of the site in the shallow made ground. Only moderate concentrations of TPH were reported in the deeper Made Ground and the underlying natural soils. Elevated concentrations of Semi-Volatile Organic Compounds (SVOCs) were detected in the northern and eastern parts of the site, and only modestly elevated concentrations of Volatile Organic Compounds (VOCs) were detected.

8.7.4 In addition to existing recorded contamination on site and in perched

groundwater the ES notes that certain piled foundation solutions might lead to the development of pathways resulting in adverse impacts to groundwater which is identified as a high sensitivity receptor. The ES therefore recommends further assessment of potential risks to controlled water receptors including a detailed quantitative risk assessment and remedial strategy and completion of a piling risk assessment in accordance with Environment Agency guidelines to assess the risks to the underlying aquifer from the contamination present in the Made Ground. A combination of site remediation and mitigation measures including soil source removal and reduced water infiltration by capping of areas of soft landscaping (such as the route of the canal) as well as the use of appropriate piling techniques and control measures in consultation and agreement with the Council and Environment Agency are proposed.

8.7.5 In the absence of mitigation, the most significant risks to human health are

considered to be those to construction workers and neighbouring residents during the development of the site, especially during the earthworks phases, when workers could potentially come into direct contact with contamination and/or inhalation of airborne soil particulates. Construction workers could also be exposed to contaminated groundwater. In terms of the completed development, without mitigation there is a potential for site users to come into direct contact with contamination, a potential for gas ingress to the new buildings and the creation of new preferential migration pathways between contamination sources and the underlying Aquifers.

8.7.6 Mitigation during construction, in addition to activities being managed in

accordance the CEMP, would include further soil sampling to provide additional coverage of areas previously inaccessible in order to classify ground conditions across the entire site and assist in the determination of appropriate disposal techniques for spoil. This would comprise supplementary investigations for the purposes of remediation. Areas identified as containing particularly significant or specific contamination (i.e.

‘hotspots’) will be excavated and removed from the site. The ES notes that as a part of the detailed design work, further investigations will be undertaken to establish the land gas regime and consultation with the relevant Council Departments and/or the Environment Agency will be undertaken to ensure adequate measures to address potential issues associated with hydrocarbon vapours/odours are implemented to mitigate potential risk to future site users. Measures to address other contamination, such as capping, will be incorporated into the design.

8.7.7 The ES has identified significant contamination and recommends further

investigation to refine and specify the appropriate mitigation measures. The Environment Agency has reviewed the Revised ES and agrees with the conclusions and that further site investigation will be required, particularly focusing on the northern part of the site where the most significant contamination has been encountered. They also recommend further investigation of the impact any shallow contamination is having on the deeper groundwater and recommend a series of conditions to be attached to any permission granted with which officers concur. Given the stage to which the designs have been developed this is considered an appropriate strategy and a condition is therefore recommended requiring the submission of a detailed investigation and assessment of the site in relation to possible contamination together with full details of any remediation required, and the final submission of a closure report. Although site contamination information including details of site investigations already carried out at the site has already been submitted at application stage, given the history of the site and potential for contaminants to be revealed by further site investigation works this is not considered sufficient to obviate the need for an appropriate condition related to site contamination.

8.8 Microclimate – Wind

8.8.1 The Revised ES supplements the Computational Fluid Dynamics (CFD) wind

microclimate assessment (conducted in 2008 and reported in the original ES) with the findings of wind tunnel simulation and clarifies the methodology used in that assessment. The wind tunnel testing assesses pedestrian level wind microclimate and quantifies and classifies the findings in accordance with the Lawson Comfort criteria based on a detailed assessment of the mean and gust wind conditions. The wind tunnel tests were conducted for ‘with’ and ‘without’ Marine Wharf West and Yeoman Street sites development scenarios.

8.8.2 The wind speed was measured at up to 91 locations, and for all wind

directions in equal increments and shows that after development, conditions would be comparable or marginally windier than the baseline conditions experienced at the ground level around the existing buildings on site. Most locations at ground level are suitable for pedestrian standing/entrance use during the worst case (winter) season (classified as ‘negligible’ impact), but there are five thoroughfare locations in the south-east area of the site which are suitable for leisure walking (‘minor adverse’). During the summer, when winds are generally calmer, the wind conditions at all measured ground level locations are considered in keeping with their intended pedestrian use, and the potential impacts of the proposed development are negligible (where the wind microclimate is compatible with the intended pedestrian use of the site)

to moderate beneficial (where the wind microclimate is two categories calmer than desired).

8.8.3 At podium level (on blocks H and selected locations on B) conditions are

suitable for standing or sitting during the winter, and suitable for sitting during the summer season. Other locations on the podium level of blocks B and C are either directly exposed to the prevailing south-westerly winds or are between buildings which are subject to funnelling of the wind and experience conditions suitable for pedestrian standing or leisure walking during the summer season. These locations are windier than desired and potential impacts are minor or moderate adverse depending on the location. The impact of occasional stronger winds has also been assessed and two locations on thoroughfares have been identified as experiencing these infrequent but stronger winds. The ES states that these winds are unlikely to cause a nuisance to pedestrians. A third location on a podium would also experience stronger winds which would tend to occur in the winter when the podium will be less frequently used as an amenity space.

8.8.4 Mitigation is proposed for the locations where impacts are adverse, namely

the podiums, in the form of partition screening and/or landscape planting in the central areas of the courtyards to enhance the local wind microclimate and achieve a ‘negligible’ impact overall. When assessed with neighbouring buildings on Marine Wharf West and Yeoman Street conditions would be marginally calmer than predicted around the completed development with no development on these sites, and impacts would be negligible to moderate beneficial at most locations on the proposed development site.

8.8.5 In the light of these conclusions and subject to the proposed mitigation being

implemented it is considered that the development would not give rise to significant detrimental impacts on or off site.

8.9 Noise and Vibration 8.9.1 The national, regional and local planning policy relevant to noise is found in

PPG 24, London Plan 4A.20 (Reducing noise and enhancing soundscapes), and UDP policy ENV.PRO 11 Noise Generating Development

8.9.2 Baseline surveys were conducted at seven locations (including off-site)

during the daytime and night-time in April 2007 to determine the prevailing noise levels on and in the vicinity of the site to identify and characterise the principal sources of noise in the area. At that time the Salters Paper Mill site was vacant. Noise and vibration impacts from plant and equipment during construction were identified as well as the operational impacts on completion from development traffic, building services plant and sources external to the site impacting on the new development. At the time of the assessment the Marine Wharf West site was occupied by Jet Stationary which gave rise to noise impacts. This use has now ceased, buildings cleared and the Council has resolved to grant planning permission for a mixed use development which would not include similar noisy industrial uses.

8.9.3 During construction noise levels at selected locations around the site

(Hazelwood House and Woodcroft Mews (incorrectly named as Woodstock Mews in the ES) would exceed target noise criterion at first floor and above

during demolition and excavation works. There is also the potential for vibration during site excavations and piling operations to give rise to perceptible vibration levels at properties in Woodcroft Mews. Mitigation is proposed principally through implementation of the CEMP and is expected to result in minor adverse noise impact except for those receptors directly adjacent to construction sites where a temporary, moderate adverse impact may occur on occasions.

8.9.4 On completion traffic noise as a result of the development would increase

however this is assessed at less than 1dB and considered insignificant. Potential noise impacts from building services plant would be mitigated through equipment design and specification. Noise intrusion from external sources is assessed as low and providing that the residential façades of the proposed development are constructed using glazing and ventilation systems that meet or exceed the specified acoustic performance levels then the proposed development is expected to achieve an acceptable level of protection against noise for all dwellings during both the day and the night. Operational plant and other equipment on site might give rise to noise off-site and a condition limiting noise from such equipment is proposed.

8.9.5 It is considered that ES presents an acceptable assessment of noise and

vibration impacts and that no major concerns have been identified with the methodology, results or overall conclusions. Whilst the construction period is likely to give rise to the most significant noise and vibration impacts on surrounding properties, with appropriate mitigation (such as limiting hours of works) and given that the construction phase would be temporary, impacts are acceptable. A condition, requiring the preparation and submission of a CEMP including such noise mitigation measures during the construction period as may be required, is recommended.

8.10 Socio-Economics 8.10.1 London Plan policy 3A.28 (Social and economic impact assessments)

relates to social and economic impact assessments for major developments within Areas for Regeneration. Policy 2A.7 of the London Plan, and the related Map 2A.2, confirm that the application site is within such an Area for Regeneration (these designations correspond with London’s most deprived wards). Policy 3A.28 requires that the proposed development be subject to a social and economic impact assessment.

8.10.2 The Revised ES assesses the impact of the scheme in terms of population,

employment, housing, education, community facilities, recreation, leisure and open space, shops and services and healthcare. Based on the proposed residential unit size and tenure mix the Revised ES estimates a new resident population of 1,222. Of these, 129 would be children aged 0 to 18 although the ES then applies reductions to take account of actual school attendance, across boundary flows and those that attend private rather than state schools giving a net figure of 94 children.

8.10.3 In terms of impact the Revised ES states that in respect of education

facilities, all of the nursery aged children can be accommodated in the proposed onsite nursery, local primary schools are at capacity and mitigation measures will be required and for secondary and post 16 there would

appear to be sufficient capacity in local schools to accommodate the child yield of this age group, particularly Deptford Green Secondary School, but only for a limited period. For post 16 year children there would appear to be capacity to 2016/17 but the quality is poor. Without mitigation the sensitivity of the receptor is considered to be high and the scale of impact medium, leading to a major adverse impact. Mitigation is proposed in the form of financial contributions to fund primary, secondary and over-16 school places.

8.10.4 Construction employment is estimated at 320 full time equivalent (FTE) jobs

based on a five year construction programme, although elsewhere the ES indicates a 6-7 year programme which would suggest around 245 FTE jobs in construction. On site employment following completion of the development is assessed at a net increase of 249 jobs. This assumes that all non-residential jobs are in Class B1 space and applies multipliers to indirect and induced jobs as well as off-site employment as a consequence of the new development. The ES concludes that the impacts will be major beneficial. Whilst the method of calculation is somewhat unclear, the provision of modern dedicated business space to replace the existing Business Centre is a positive feature of the proposed development and its delivery in the first phase of development is particularly welcome.

8.10.5 Based on the new population and existing healthcare facilities the ES

identifies a minor adverse impact and an acknowledged need for improvement to GP and dental services. A similar scale of impact is identified for community facilities (with a reasonable provision within a 1.2 km catchment of the site but an acknowledged need for improvement in library and community space) and recreation, leisure and open space (with increased demand on higher order facilities). Mitigation is proposed by way of financial contributions to improve local facilities and this will be secured through the s.106.

8.10.6 Discussions with the applicant have clarified likely impacts and appropriate

mitigation and financial contributions to new and/or expanded facilities will be secured through a s.106 agreement. In the circumstances the proposed impacts and mitigation are considered acceptable.

8.11 Telecommunications and Interference 8.11.1 The impact on telecommunications interference is assessed in terms of

broadcast radio, and terrestrial, satellite and cable television. The ES concludes that whilst radio signals are unlikely to be adversely affected, the proposed development would cause shadowing of satellite television signal from the two tall buildings (Blocks B1 and C1). As well as the ‘shadow’ from these falling on other buildings within the site there would be some impact beyond the site boundary, on dwellings in Woodcroft Mews and Acacia Close. The proposed development will cast shadows on signals from the Crystal Palace and Croydon transmitters for terrestrial television approximately 2.9km to the north east of the site however with the change over to digital the signal is expected to be turned off permanently by 2012.

8.11.2 In terms of mitigation the ES notes that in practice measurement of the effect

by pre-construction and post-completion surveys provides the only reliable basis for determining the extent and significance of impacts and proposes a

staged approach to assessment and mitigation. This approach is considered appropriate (applied to terrestrial and satellite/digital reception) and would be secured by condition.

8.12 Transport 8.12.1 This matter is considered in detail in Section 7.6 of this report.

8.13 Waste

8.13.1 The ES provides an assessment of potential wastes arisings during

demolition, site preparation, construction and operation of the proposed development. Without mitigation construction and operational impacts are assessed as ‘moderate adverse’ on the basis that without management and other mitigation measures the majority of this waste would be disposed of at landfill sites.

8.13.2 Mitigation during demolition is proposed through maximising the recovery of

materials and components during the process (which has economic as well as environmental benefits) and during construction through the use of recycled materials and a commitment to source materials responsibly where feasible. In addition a Site Waste Management Plan (SWMP) will be implemented to seek to reduce waste during construction. Operational impacts will be mitigated through the a range of measures including sufficient space for storage areas to accommodate the necessary waste and recycling containers and a waste recycling information pack provided to the occupants of each dwelling and for new businesses. The ES concludes that when mitigated the impacts will be moderate beneficial.

8.13.3 The calculations of waste arisings during the operation of the site appear

high however the proposed mitigation is considered appropriate and will be secured through approval of the SWMP. On balance officers consider the impacts are acceptable.

8.14 Water Resources, Drainage and Flood Risk 8.14.1 The national planning policy relevant to flood risk is found in PPS 25.

London Plan policies 4A.13 (Flood risk management), 4A.14 (Sustainable drainage) and 4A.16 (Water supplies and resources) are also relevant, as are UDP policies ENV.PRO 15 Sustainable Surface Water Drainage in New Development and ENV.PRO 17 Management of the Water Supply. The application site is within Flood Zone 3a, where there is a high probability of flooding. A Flood Risk Assessment (FRA) is appended to the ES which identifies a flood risk associated with breach of the Thames flood defences.

8.14.2 The Environment Agency has reviewed the Flood Risk Assessment submitted as part of the ES and following clarifications (regarding the lack of a sequential test and insufficient information being submitted to be able to determine the impact of the proposal specifically relating to the greenfield run-off rate) the Agency is now satisfied on both points. Subject to a condition being imposed regarding implementation of the scheme in accordance with the submitted FRA and regarding approval of the detailed design of green roofs the Agency raises no objection to the application.

8.14.3 Conditions are proposed on both matters (as well as groundwater protection measures also proposed by the Agency) and officers are satisfied that the ES adequately addresses this matter.

8.15 Townscape and Visual 8.15.1 The ES provides an assessment of changes to the fabric, character and

quality of the townscape as a result of the development, and changes to available views of and the effects of those changes on people and visual amenity. The assessments have been undertaken in accordance with the IEMA “Guidelines for Landscape and Visual Impact Assessment” (Second Edition 2002) and the London View Management Framework using desk and field study of the site and its surrounding area.

8.15.2 The ES summarises the existing character of the area referring to the 19th

century growth, the effect of railway expansion (generally on embankments) and industrial development and large scale regeneration projects that have left a legacy of a broad range of uses, typologies, scales and ages with no one character dominating and resulting in an inconsistency in the built form. In terms of local topography the site sits within the level Thames Basin with land rising to the south and south east, most notably at Greenwich which provides views back over the site towards central London and St. Paul’s Cathedral. Locally to the site the more or less complete lack of street frontage is identified as having a strong influence on the existing understanding and perception of the site, although the sensitivity of particular receptors such as the small scale residential properties to the west is acknowledged. Existing buildings on the site are described as being of poor quality, of low to medium scale, and of no architectural merit. Existing surfaces are of poor quality, with large areas of tarmac to the south (generally car parking), whilst much of the northern part is a mix of tarmac finishes or un-kept rough surfaces. The former railway embankment to the south creates a significant green boundary to the site.

8.15.3 In terms of townscape impact given the existing poor quality of the site, any

improvements are likely to be high impact on the baseline environment with the new development replacing the existing dilapidated structures on the site. The ES concludes that this impact is major beneficial.

8.15.4 For the visual assessment a number of locations for the were agreed with

the Council that provide short, medium and longer distance views of the site and a 3600 illustration of the visibility and impact of the completed development from key locations around the application site. The applicant has used as-existing images of each of the views, and prepared Verified Visual Montage (VVMs) for 7 locations with the proposed development overlaid as wireframe or solid blocks. An additional (unverified) view from the railway line close to the junction of Trundleys Road and Grinstead Road has also been assessed. Non verified photo-montage views close to the site and within it give an impression of the scheme when completed.

8.15.5 The applicant has categorised the views into short, medium and long range

views and assessed their sensitivity in terms of such factors as their policy status, local amenity value as well as permanency/transience of the view in the identified locations. The views are assessed as follows:

8.15.6 T

he ES states that during the construction phase there will be a temporary townscape evolving throughout the development programme. Townscape and visual impacts arising from the construction process (cranes, plant and equipment, partially completed buildings) will be most noticeable from locations close to the site (rather than the selected VVM positions) and are identified in the ES as ranging from moderate adverse to major adverse (directly against the western boundary with Woodcroft Mews). Given the scale of some of the proposed buildings on the site and use of tall cranes during construction this assessment is considered to reasonably reflect the likely scale of impact. No specific measures are identified mitigate these impacts other than site management practices, however given the temporary nature of the construction stage (and phased construction of buildings across the site) it is considered that these impacts though adverse are acceptable by virtue of their short term impacts.

8.15.7 For the completed development the impact on selected views is assessed in

terms of whether it is positive or negative and whether the impact is minor, medium or major. Depending on the sensitivity of the view the impact is assessed in terms of adverse or beneficial and minor, moderate or major.

Views with applicant’s assessment of impact

8.15.8 Assessing impact of new development on views is, to an extent, subjective.

However given the height of the proposed tall buildings and their visibility from short, medium and longer distances officers consider that the assessment understates the likely impact. Whilst some views are from designated viewpoints (such as Greenwich Park and Stave Hill) and others are more transient (such as when walking along Evelyn Street) the tall buildings in particular will be highly visible. It is apparent from the assessment that they will generally be seen in the context of other tall buildings in the vicinity (such as Eddystone, Daubney and Aragon) and so will be adding to an existing but small number of taller structures in the area that currently break the roof/tree/skyline. As such the scale of impact is considered to be high.

View Location Sensitivity

A Evelyn Street from the North (looking South) Medium

B Evelyn Street from the South (looking North) Medium

C Oxestalls Road bridge (looking North) High

D Deptford Park (looking north east) High

F Isle of Dogs (LB Tower Hamlets) High

G Stave Hill (LB Southwark) High

H Greenwich Park General Wolfe statue High

View Location +ve/-ve Scale Overall

A Evelyn Street Positive Medium Moderate Beneficial

B Evelyn Street Positive Medium Minor Beneficial

C Oxestalls Road bridge Positive High Minor Beneficial

D Deptford Park Positive Medium Minor Beneficial

F Isle of Dogs Negative Medium Minor Adverse

G Stave Hill Negative High Minor Adverse

H Greenwich Park Negative Medium Negligible

8.15.9 The exception is the view from Greenwich which, though a protected view,

because it is longer distance and from an elevated position the tall buildings at Cannon Wharf sit within the middle distance as a group with those on the Pepys estate, with taller buildings beyond and to the east providing the backdrop/context to the view. In this case the scale of impact is considered medium. The impact on the safeguarded view and formal assessment under the Mayor of London’s 2010 London View Management Framework has been discussed and assessed in section 7.6 above.

8.15.10 In the light of this assessment officers consider the impacts to be: 8.15.11 Although the overall impacts are considered minor/moderate adverse in

terms of the overall impact, this is mitigated by a combination of the proportions and detailed design of the tall buildings. They have a relatively small footprint and simply articulated facades which means that although they are prominent on the skyline from a number of locations they do not have the bulk or solidity of the nearby Eddystone or Daubney towers nor the height and footprint of Aragon Tower. In the circumstances it is considered that the overall impact is acceptable.

8.15.12 In terms of local views, the nearest listed in Schedule 1a of the UDP are

those panoramic views (northwest, northeast and southeast) of the River Thames from Deptford Foreshore (site reference LV7). Due to the building heights proposed at Marine Wharf West, and the intervening distance and buildings, it is considered that these local views would not be obstructed or otherwise adversely affected by the proposed development.

8.16 Cumulative Effects 8.16.1 The ES is required to consider the cumulative effects of the proposed

development with other committed sites identified in the ES as Oxestalls Road, Convoys Wharf, Marine Wharf West, Paynes and Borthwick Wharf, Creekside Village East and West, Greenwich Reach, Surrey Canal Triangle, Grinstead Road, Surrey Quays Leisure Site, Canada Water sites A, B, C & E, Mulberry Business Park, Downtown Road/Salter Road. The assessment has been made on a topic-by-topic basis and is reported in Section 8 of this report. Of particular relevance is air quality given the existing conditions and designated AQMA. The ES concludes that although taken cumulatively with the committed developments within the area there will be an increase in nitrogen dioxide and PM10 concentrations, this will be within acceptable levels and not conflict with the objectives of the Air Quality Management Plan. In the case of additional traffic on the local road network the ES

View Location +ve/-ve Scale Overall

A Evelyn Street Neutral Medium Minor Adverse

B Evelyn Street Neutral Medium Minor Adverse

C Oxestalls Road bridge Positive High Minor Beneficial

D Deptford Park Negative High Moderate Adverse

F Isle of Dogs Negative High Moderate Adverse

G Stave Hill Negative High Moderate Adverse

H Greenwich Park Negative Medium Minor Adverse

concludes that the development would have negligible effect on the surrounding highway with the increase in traffic on the local road network.

8.16.2 It is considered that the ES has appropriately assessed the cumulative

impacts of the proposed developments and that the development will give rise to both positive and negative impacts. With mitigation as appropriate, the overall impacts are considered acceptable.

8.17 Residual Effects 8.17.1 The ES includes as a Conclusion a summary of the environmental effects of

the proposed development including the effects of the proposed development after mitigation i.e. the residual effects. Full details of mitigation measures proposed by the applicant are set out in the relevant chapter each chapter of the Revised ES.

8.17.2 A number of the adverse effects will occur during the site preparation and

construction period when mitigation measures can be secured through the CEMP and relevant conditions. There will be residual effects of the completed development in terms of the townscape and visual impacts however on balance the proposed development is considered acceptable, and that planning permission can be granted subject to the conditions and Section 106 agreement as set out below.

9. FINANCIAL VIABILITY AND DELIVERABILITY

9.1 Introduction

9.1.1 The application site forms part of the Plough Way Strategic Site, one of four

that is identified in the Core Strategy as being a catalyst for regeneration of the Deptford and New Cross area through mixed use redevelopment. Development of the Cannon Wharf site in conjunction with the adjacent Marine Wharf West site has the potential to be a key component in the regeneration this part of the borough, not simply because of the size of the site and its capacity for development but also because of its location in relation to other development sites, the potential it offers for the repair of the disjointed landscape and urban fabric around it, and the provision of connections of wider benefit to the north of the borough and to LB Southwark.

9.1.2 Core Strategy policy SSA1 sets out the requirements strategic sites including

the need for a comprehensive masterplan and a delivery strategy setting out how the development will be implemented and managed once occupied (including housing stock and publicly accessible space), any matters to be resolved such as land assembly and preparation, infrastructure requirements and delivery, development phasing and likely need for planning obligations (including financial contributions) and/or conditions. The delivery strategy should also identify the likely need for public sector intervention, by which agency and when.

9.1.3 In addition to the masterplanning options discussed elsewhere in this report,

a financial appraisal and delivery strategy for the Cannon Wharf site has been submitted in support of the application. The applicant is the owner of

the site with experience of developing and managing business space and intends to develop the site jointly with a house-builder. Whilst there can be no guarantee that they will commence or complete the proposed development as submitted they have indicated that they are committed to delivering the scheme and that their development strategy will allow for existing businesses on the site to remain and relocate to the new Business Centre.

9.2 Viability and Deliverability 9.2.1 The following considers viability and deliverability in the light of the

information provided by the applicant and its assessment by the Council and its advisers, Lambert Smith Hampton.

Financial Viability

9.2.2 The financial appraisal provides information on land purchase costs together

with projected build costs, sales values, and rents and yields (for the commercial space). This has been supplemented with additional information in respect of the abnormal site costs arising from decontamination of the site.

9.2.3 The build costs have been benchmarked against BCIS rates and sales

values and rental levels/yields assessed in terms of comparables for the type of scheme and locality. The advice from the Council’s appointed consultants who have reviewed the financial appraisal is that the build costs are within the BCIS range and based on the evidence provided they are generally reasonable. Commercial rents and yields are comparable to those for similar space in the local area. Accordingly the base information is considered acceptable.

9.2.4 Land purchase cost in the appraisal reflects the sequence of acquisitions

over a number of years. The appraisal has been amended to remove interest costs incurred since these acquisitions. In addition the land cost has been adjusted to reflect current values rather than historic purchase costs. Whilst not strictly an ‘Existing Use’ value (using the RICS Red Book definition), Valuation Office data on land values in the area has been used as a proxy for this exercise and in the absence of more detailed information this is considered a reasonable basis for this assessment. The effect of this adjustment is to reduce the land value by about 15%. The scheme has been appraised on a cash flow basis to reflect the timing of costs and income from the scheme including financing (interest payments and credits). Part of the cost of the scheme is involved in section 106 contributions to mitigate the impact of the proposed development. This includes a financial contribution to the cost of works to the route of the former canal, either immediately adjacent to the site or to the south which will support the delivery of the Council’s wider objectives for the area as part of the North Lewisham Links initiative.

9.2.5 The appraisal has also been reviewed in terms of the developer’s preferred

return which in current market conditions would be in the order of 15-20%. Based on the proposed mix of uses the appraisal shows that the scheme shows a return (based on profit on cost) below this level. It should be noted

that the submitted scheme does not provide affordable housing or commercial space in line with London Plan and/or local policy in the adopted UDP and Core Strategy and it is accepted that a policy compliant scheme based on the costs and values in the appraisal would show a loss.

9.2.6 Whilst on current terms if the applicant were to seek to dispose the site

based on their historic land purchase costs the scheme would not be commercially viable, given the build out period and potential increase in sales values and or reduction in build costs the applicant might be prepared to undertake the development. In this regard the applicant has indicated their commitment to proceed.

9.2.7 Given the fact that the scheme does not provide affordable housing in

compliance with development plan policy a review mechanism to secure funding for additional affordable housing should the scheme achieve specified sales values is proposed and will be secured through the S106 agreement.

Land Ownership

9.2.8 London Business Centres own the freehold of the land defined by the planning application red-line boundary apart from the route of the former canal which is currently owned by a Berkeley Homes company. Given the importance of improvements to the canal to the Cannon Wharf scheme, which has a significant number of homes overlooking this area, until such time as the canal works have been undertaken either by Berkeley Homes as part of their Marine Wharf West development (or by Cannon Wharf in agreement with Berkeley Homes) then construction of buildings on that frontage should not be undertaken. The applicant has proposed a phasing scheme and planning obligation to achieve this outcome which is considered acceptable and will be secured through the S106 agreement.

9.2.9 The access onto Evelyn Street via Rainsborough Avenue can be achieved

within the land ownership of the applicant and/or public highway as they have a right of access through the former railway embankment onto Rainsborough Avenue.

9.2.10 Subject to agreeing details of the mechanism to the delivery the canal works

(either adjacent to the site or on the route of the former canal to the south) linked to the phasing of the development, the Council is not aware of any third party interests that would prevent or limit the implementation of the proposals as submitted.

Phasing

9.2.11 Construction of the proposed development would be carried out in 8 phases (plus site preparation, demolition and remediation, and sub-structure works) over an 80 month period. So, if site preparation started in March 2012 then the final phase would be completed in late 2018 (see paragraph 3.9.3 above for further details).

9.2.12 The applicant has included in the Delivery Strategy a schedule setting out

the number/type of units to be provided in each phase:

Phase Blocks Units (Affordable)

Non-Residential Uses

1 A 0 Business Centre

2 H, J 66 (40) Energy Centre and ground floor commercial

3A B2, B3 B4 97 Ground floor commercial

3B B1 66 Ground floor commercial

4A C2, C3 82 Ground floor commercial

4B C1 81 Ground floor commercial

5 G 42 (42) Nursery

6 D 61 Ground floor commercial

7 E, F, houses 35 (35)

8 A, B5, C4 166 ground floor commercial

9.2.13 As already noted the applicant owns the freehold of the application site

(other than the canal) and subject to receiving planning permission it is intended that they would commence construction on this site in March 2012. The phasing of the construction programme would deliver the canal-side housing in the last phase of development i.e. year 5+. When considered with the programme identified for the Marine Wharf West site, which would deliver the canal improvement works within approximately 2½-3 years of commencement and the completed development within 5 years it is considered that there is a reasonable prospect that the sites will be developed comprehensively and in a timely manner.

9.2.14 The provision of the Business Centre in Phase 1 and some of the affordable

units in Phase 2 means that a mixed-use/mixed-tenure development is being developed on the site from an early stage.

Infrastructure

9.2.15 The proposed development will give rise to additional demands on existing

social infrastructure (e.g. schools, health services and public transport). Officers have been in discussion with the applicant regarding the key infrastructure requirements arising from the proposed development informed by the Council’s Adopted Planning Obligations Supplementary Planning Document and Infrastructure Delivery Plan and Schedule. The applicant has agreed to make financial contributions towards infrastructure as well as carrying out associated works (e.g. to the former Grand Surrey Canal) as an integral part of the proposed development. The scope and timing of these financial contributions and works in kind are set out in Section 10 below.

Housing Demand

9.2.16 The applicant has advised that they are in discussion with a house-builder as development partner and intend to commence development within a relatively short time after grant of planning permission. The provision of 696 residential units will make a contribution to the housing targets set out in the Core Strategy and whilst the Council cannot require commencement of the development the applicant has indicated their intention to undertake the scheme.

Non-Residential Uses

9.2.17 The application proposes that the new Business Centre (providing 4,083m2 of B1 space, approximately 60% of the total non-residential space on the site) in Phase 1 of the development. Although occupiers of the Business Centre have not yet been identified, it is understood that a number of existing tenants in the current Business Centre would relocate. The phasing of the development would allow them to do so without having to leave the site. This approach is welcomed and is a positive aspect of the proposed development.

Management and Maintenance

9.2.18 A management and maintenance strategy for the site including roads, publicly accessible routes and open space and communal residential amenity and play space is included in the Heads of Terms for a Section 106 agreement. Details of the strategy will cover both how the relevant areas are to be managed and maintained as well as the ongoing maintenance regime for the site as a whole.

Other Legal Agreements and Consents

9.2.19 Minor works on the public highway on Rainsborough Avenue are proposed and therefore highways agreements under s.278 of the Highways Act will be required.

Conclusion

9.2.20 Overall it is considered that there is a reasonable prospect of the scheme proceeding on this site and, subject to delivery of the canal works by a third party or the applicant with their agreement, there are no other major impediments to delivery of comprehensive redevelopment for the site. Whilst the scheme falls short on some policy matters it has been demonstrated that the scheme could not afford to increase the amount of commercial space nor, at this time, the level of affordable housing.

9.2.21 Although the application is for only part of the Plough Way Strategic Site it

has been prepared in the context of a site-wide masterplan for the strategic site. This demonstrates that the proposed development is compatible with the wider masterplan and would not prejudice the redevelopment of the entire strategic site in a manner that would deliver the general and site specific objectives set out in the Core Strategy. In this context and given the conclusions of the viability assessment, including the level of affordable housing and overall commercial space level as well as the Section 106 provisions, it is considered the proposals are acceptable and will help deliver the objectives for the Plough Way Strategic Site set out in the Core Strategy.

10. CONSIDERATION OF OBJECTIONS

10.1 Introduction

10.1.1 As noted at paragraph 5.3.1 above, written comments from were received from a total of 56 addresses in response to the initial consultation and reconsultation. Responses are summarised at paragraph 5.3.3 above and in detail in Appendix 3. A summary of the key issues raised at the local meeting held on 19th May 2011 is set out in paragraph 5.3.7 above.

10.1.2 The majority of matters raised are material planning considerations and are

addressed in the relevant parts of this report.

11. LEGAL AGREEMENTS

11.1 Introduction 11.1.1 Paragraph B2 of Circular 05/2005 states that in dealing with planning

applications, local planning authorities consider each on its merits and reach a decision based on whether the application accords with the relevant development plan, unless material considerations indicate otherwise. Where applications do not meet these requirements, they may be refused. However, in some instances, it may be possible to make acceptable development proposals which might otherwise be unacceptable, through the use of planning conditions or, where this is not possible, through planning obligations. Accordingly, planning obligations can prescribe the nature of the development, compensate for or offset likely adverse impacts of the development, and mitigate the proposed development’s impact.

11.1.2 The Community Infrastructure Levy (CIL) Regulations 2010 puts the

Government’s policy tests on the use of planning obligations set out in Circular 05/2005 on a statutory basis for developments which are capable of being charged CIL. The Regulations make it unlawful for a planning obligation to be taken into account when determining a planning application for a development, that is capable of being charged CIL (whether there is a local CIL in operation or not) if the obligation does not meet all of the following tests:

(a) necessary to make the development acceptable in planning terms (b) directly related to the development; and (c) fairly and reasonably related in scale and kind to the development

11.1.3 UDP policy IRM3 (Community Benefit and Planning Loss), London Plan

policies 6A.4 (Priorities in planning obligations) and 6A.5 (Planning obligations), and Core Strategy Policy CS21 (Planning Obligations) together with the Council’s Adopted Planning Obligations SPD set 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 will 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, the proposed heads of terms for a Section 106 Agreement are set out below.

11.1.4 Given that the applicant proposes works to public highways, an agreement

or agreements with LB Lewisham under Section 278 of the Highways Act 1980 will also be necessary.

11.2 Planning Obligations (Section 106 Agreement) 11.2.1 The Heads of Terms for a Section 106 Agreement are:

1. Housing

• provision of 117 affordable housing units comprising 22 social rented (4 x 2 bed, 2 x 3 bed duplex flats; 5 x 3 bed houses, 7 x 4 bed houses, 4 x 5 bed houses) and 95 shared ownership (30 x 1 bed, 44 x 2 bed, 21 x 3 bed)

• all affordable housing to be built with no discernible difference in quality of external appearance to private dwellings

• affordable housing to be provided as per submitted plans and construction phasing strategy

• provision of a review mechanism to secure funding for affordable housing if financial viable

2. Public Realm

• implementation of landscaping works to the route of the former Grand Surrey Canal (details of the scheme, phasing and cost to be agreed)

• maintenance and management of the public realm in accordance with a management plan agreed with the Council

• areas of public realm to remain available for use by the public 3. Transport:

• financial contribution of £450,000 towards improvement of local bus services and cycle facilities, public transport infrastructure enhancements including bus stops within the vicinity of the site, air quality monitoring and the cost of consultation and implementation of a Controlled Parking Zone in the vicinity of the site

• site wide Travel Plans for residential and non-residential uses to be submitted and approved by the Council

• provision of six car club spaces with free membership for one-year for all occupiers of the site

• submission, approval and implementation of a parking management plan

• implementation of works to the public highway (under S278 Agreement)

• provision of 6 car club spaces within site and free membership for 1 year for all occupiers of the site

4. Social Infrastructure (Education and Health):

• financial contribution of £1.3m for Primary, Secondary and Post-16 Places facilities in the borough

• nursery to be fitted out to a scheme agreed with the Council, and rent and service charges agreed with the Council for a period of three years from first availability to ensure the facility is delivered and made available for, but not solely limited to, residents of the proposed development

• financial contribution of £904,000 to be spent on the improvement or extension of existing health facilities in the borough

5. Leisure and Open Space:

• financial contribution of £400,000 towards the improvement of existing leisure, open space and community facilities within borough of which £46,688 to be spent on improvements to, or provision of new allotments, and £4,453 to be spent on improvements to playing pitches

6. Community Facilities/Trust:

• financial contribution of £390,000 towards a Community Trust

7. Employment and Training:

• implementation of a local labour scheme on site to be agreed with the Council

• financial contribution of £200,000 towards Construction Training (details to be agreed as part of an Employment Method Statement)

• specification of commercial space fit out

8. Children's Playspace/Communal Private Residential Amenity Areas:

• financial contribution of £53,746 to be spent on the provision of new children's playspace within the vicinity of the application site

• communal private residential amenity areas to be maintained and managed in accordance with a plan submitted to and approved by the Council

9. Phasing

• phasing of the development in accordance with a strategy to be agreed with the Council

• construction of residential properties adjacent to the route of the former canal to be linked to the landscaping of this area

10. Costs:

• meeting the cost of external financial viability consultants appointed by the Council to assess and advise on proposed development

• meeting the Council’s legal, professional and monitoring costs associated with the drafting, finalising and monitoring of the Agreement

11.2.2 These heads of terms as set out in summary under Recommendation C

below (with appropriate timing to be agreed with the Council) take account of the proposed Planning Conditions set out below and the planning considerations in section 7-9 of this report, and are considered appropriate to secure policy objectives, prescribe the nature of the development, compensate for or offset likely adverse impacts of the development, and

mitigate the proposed development’s impact. These take account of comments raised by the GLA in the Mayor of London’s Stage 1 comments.

11.2.3 Officers consider that the obligations and financial contributions referred to

above are appropriate in order to mitigate the impacts of the proposed development, and are in accordance with CIL regulations, Circular 05/2005 and development plan policy. The total package secured is below that using the amounts and calculations set out in the Council’s Adopted Planning Obligations SPD. However this needs to be seen in the context of advice from the government regarding the need for a pragmatic approach to Section 106 negotiations, the financial viability of the scheme and the ‘in-kind’ benefits of the development including implementation of part of the North Lewisham Links project through works to the route of the former canal. Confidential viability information, which has been independently reviewed, has accompanied the application and this has demonstrated that the level of affordable housing proposed and the other financial contributions that officers have negotiated is commensurate with the overall viability of the scheme.

12. CONCLUSIONS AND RECOMMENDATIONS

12.1 Introduction 12.1.1 The proposed development of the Cannon Wharf site raises issues relating

both to the development of the Plough Way Strategic Site (of which it forms part), and site specific issues in terms of the nature and scale of the proposed development and its impact on the local environment. This report has considered both matters in the light of adopted and emerging development plan policies and other material considerations including the information set out in the Revised ES.

12.1.2 Core Strategy Policy SSA1 sets out an approach regarding the process by

which proposals for strategic sites should come forward, that is in the context of a comprehensive masterplan for the entire site. In this case the applicant has considered the site in the context of the Plough Way site as a whole and demonstrated that this provides a framework and development principles for the strategic site in terms of site layout and linkages across the area. It is within this context that proposals for the Cannon Wharf site have been developed.

12.1.3 Officers consider that the site analysis and its context is based on an

appropriate understanding of the problems, constraints and opportunities of this part of the borough and that the masterplan provides a coherent basis within which the strategic site can come forward. Whilst adopted UDP policy does not require comprehensive development of the Defined Employment Area (of which Cannon Wharf forms part), given the very considerable weight that must be given to policies in the Core Strategy it is relevant to consider the proposed development in the light of these policies. Although the application for Cannon Wharf is not fully consistent with the detailed requirements set out in the Core Strategy in terms of a single comprehensive application for the entire strategic site, on balance the officers are satisfied that the material submitted with the application provides sufficient context within which to consider the current planning application and how its fits into

the wider Plough Way Strategic Site. Officers consider that development of the Cannon Wharf site as submitted would not prejudice the redevelopment of the entire strategic site and would in fact deliver a number of objectives set out in the Core Strategy. Accordingly it is considered that the application demonstrates that policy SSA5 can be delivered by separate proposals for the individual sites that make up the Plough Way Strategic Site. In the circumstances it is concluded that the determination of a separate application for this part of the Plough Way Strategic Site is acceptable.

12.1.4 In terms of site specific issues these include: the change of the use of the

site from industrial to mixed use incorporating a significant residential element; 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; and the ability to deliver an environmentally sustainable development.

12.1.5 The proposed development does not comply with policy in a number of

respects in particular the level of affordable housing and employment floorspace, due to accepted viability constraints. The proposed development would however provide much needed housing and an element of affordable accommodation, and would improve the appearance of a large site. 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 will provide a satisfactory standard of accommodation. The proposed development would also deliver a key element of the Council’s strategy for the wider area in terms of opening up pedestrian and cycle routes to connect the existing communities within this part of the borough.

12.1.6 The current use of the site for storage, storage, recycling of building

materials, freight distribution and clothes and mattress recycling is causing considerable disturbance to local residents and redevelopment of the site as proposed would remove this use. As commencement and implementation of the proposed development cannot be guaranteed if planning were to be granted for the proposed development there is the potential for these uses to continue unless or until they give rise to a material change in the use of the land or can be controlled by other legislation. In the circumstances it is appropriate that should planning permission be granted for the proposed development that there is an undertaking from the site owner that these uses would cease.

12.1.7 The proposals have attracted a significant number of objections from

neighbouring properties on a wide range of issues. Those material concerns expressed by residents have been considered and addressed in earlier sections of this report in particular Sections 7 and 8, and in provisions set out in the recommended conditions and Section 106 agreement.

12.1.8 Officers consider that, with the recommended mitigation, planning conditions

and obligations in place the scheme is broadly consistent with local and

national policies (including the extant development plan) and is therefore recommended for approval.

RECOMMENDATIONS

12.1.9 The recommendations to the Committee are set out below. 12.1.10 As the proposed development is not in accordance with one of the

provisions of the relevant development plan (Policy EMP3), there is a requirement to refer the application to the Secretary of State at the appropriate regional government office (the Government Office for London) under the Town and Country Planning (Development Management Procedure) (England) Order 2010. As noted at Section 5 above, there is also a requirement to refer the application to the Mayor of London.

RECOMMENDATION (A)

12.1.11 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 (Categories 1A, 1B, 1C and 3E of the Schedule of the Order).

RECOMMENDATION (B) 12.1.12 Subject to no direction being received from the Mayor of London, to refer the

application to the Secretary of State at the appropriate regional government office (the Government Office for London) under the Town and Country Planning Town and Country Planning (Development Management Procedure) (England) Order 2010, as a departure from the development plan in respect of Policy EMP3.

RECOMMENDATION (C) 12.1.13 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 following principal matters (as set out in more detail in part 8 of this report), including such other amendments as considered appropriate to ensure the acceptable implementation of the development:

1. Housing (including Affordable Housing) 2. Public Realm 3. Transport: 4. Social Infrastructure (Education and Health): 5. Leisure and Open Space: 6. Community Facilities/Trust: 7. Employment and Training: 8. Children's Playspace/Communal Private Residential Amenity Areas: 9. Meeting the Council’s legal, professional and monitoring costs

RECOMMENDATION (D)

12.1.14 Subject to completion of a satisfactory legal agreement, authorise the Head of Planning to GRANT PERMISSION for the reasons set out in paragraph 9.2 below and subject to conditions including those set out in paragraph 9.3 below and such amendments as considered appropriate to ensure the acceptable implementation of the development.

12.2 Summary of Reasons for Grant of Planning Permission 12.2.1 The decision to grant planning permission has been taken, having regard to

the policies and proposals in the London Plan (Consolidated with Alterations since 2004) (February 2008) and the adopted Unitary Development Plan (July 2004) as set out below, and all relevant material considerations, including comments received in response to third party consultation.

12.2.2 The application was granted for the following reasons:

The Local Planning Authority has considered the particular circumstances of the application against relevant planning policy set out in The London Plan (Consolidated with Alterations since 2004) and saved policies in the Council’s adopted Unitary Development Plan (2004). The Local Planning Authority has further had regard to the Mayor of London’s Supplementary Planning Guidance and Best Practice Guidance, as well as the Local Planning Authority’s Adopted Residential Standards Supplementary Planning Document (August 2006) and Planning Obligations Supplementary Planning Document (January 2011), Government Planning Policy Guidance and Statements, and all other material considerations including policies in the Core Strategy, and the obligations that are to be entered into in the planning agreement in connection with the development and the conditions to be imposed on the permission. The Local Planning Authority has also taken account of the information set out in the Environmental Statement, the identified impacts and proposed mitigation. The Local Planning Authority considers that: (1) The mixed use development of the site for A1, A2, A3, A5, B1 and C3

use is in accordance with London Plan policy 3B.4, which notes the potential for surplus industrial land to help meet strategic and local requirements for a mix of other uses such as housing and social infrastructure, Lewisham UDP policy EMP 3 which allows for non-employment uses where nine criteria are met, and Lewisham UDP policy HSG 2 which promotes the development of housing on previously developed land. The objectives for the Plough Way Strategic Site set out in Core Strategy policy SSA5 in respect of mixed use development have been satisfactorily addressed within the context of financial viability.

(2) The site is an appropriate location for a development of the density

proposed in accordance with London Plan policy 3A.3, which seeks to ensure that development proposals achieve the highest possible intensity of use compatible with local context, identified design principles and public transport capacity.

(3) The provision of residential accommodation at the density proposed at this site is in accordance with London Plan policy 3A.3 which seeks to maximise the potential of sites, and with Lewisham UDP policy HSG 2 which promotes the development of housing on previously developed land and Core Strategy policy SSA5 which identifies the site as suitable for higher density development.

(4) The layout of the site, the design of the development, and the provision

of housing is in accordance with London Plan policy 3A.5 which seeks to achieve a range of housing choice, and with Lewisham UDP policy HSG 5, which requires that all new residential development is attractive, neighbourly and meets the functional requirements of its future inhabitants.

(5) The proposed dwelling mix and provision of affordable housing, which is

controlled by planning obligations agreed as part of the permission, is considered to be the maximum reasonable that can be achieved on this site taking account of targets and scheme viability and the need to encourage rather than restrain residential development in accordance with London Plan policy 3A.10 regarding the provision of affordable housing, with Lewisham UDP policy HSG 14 which seeks the provision of affordable housing including on mixed use sites and HSG 15 which seeks the affordable housing contribution to be provided in a way which assists in securing a more balanced social mix, having regard to the financial viability of the development, as well as Core Strategy policy 1 regarding housing provision, mix and affordability. The proposal is also in accordance with Lewisham UDP policy HSG 6 which seeks a mix of dwelling sizes determined by reference to the housing needs of the area, the nature of the development and its proposed relationship to the surrounding area,.

(6) The provision of new public realm and publicly accessible open space,

and mitigation secured through planning obligations, is appropriate and complies with London Plan policy 4B.3 which seeks high quality and accessible public realm, with London Plan policy 3D.13 and Lewisham policy LCE 4 which seeks to provide attractive, safe and accessible places for children to play, and with Lewisham UDP policy URB 12 which requires the inclusion of landscape proposals for all areas not occupied by buildings. The inclusion of the open space along the route of the former Grand Surrey Canal specifically addresses one of the key urban design principles for the masterplan for the Plough Way site in Core Strategy policy SSA5.

(7) The energy demand of the proposed development has been assessed

in accordance with London Plan policies 4A.1, 4A.4 and 4A.6 and Core Strategy policy 8 regarding energy and carbon dioxide savings through a lean, clean and green strategy.

(8) The proposed highway works including provisions for pedestrians,

cyclists and other road users and the overall traffic impact of the development have been assessed in accordance with Lewisham UDP policy TRN 2, and the identified highway impacts and proposed mitigation measures secured by planning conditions and obligations,

are considered acceptable in accordance with Lewisham UDP policies TRN 4, TRN 5, TRN 14, TRN 15, and TRN 16 which require major schemes to provide access that take account of the requirements of public transport providers as well improvements to public transport and facilities for cyclists and pedestrians.

(9) The proposed level of cycle parking and associated measures to reduce

car use are in accordance with Lewisham UDP policies TRN 5, TRN 14 and TRN 23 (and the related Table TRN 2), as well as Core Strategy policy 14 regarding sustainable movement and transport. Measures to reduce car use, provide off-street parking, provide spaces for and membership of a Car Club and to submit a Travel Plan are proposed to be secured by planning obligations agreed as part of the permission and by conditions.

(10) The regeneration benefits inherent in the scheme and the financial

contributions towards achieving other planning policy objectives are in accordance with Lewisham UDP policy IRM 3 which seeks the inclusion of community benefits as part of development proposals, with London Plan policies 6A.4 and 6A.5, and Core Strategy policy 21 regarding planning obligations.

12.2.3 Consideration has also been given to the objections made to the proposed

development, at set out in Sections 7 and 8 above. It is considered that none of the material objections outweigh the reasons for granting planning permission.

12.3 Conditions

12.3.1 The Planning Conditions referred to in Recommendation D are as follows:

General 1. Approved drawings and documents The Development shall be carried out in accordance with the following application documents, plans or drawings hereby approved: 815_0010 E Application Boundary Plan 815_0020 B Site Survey 815_0503 M Site Plan 815_0100 P Ground Floor Plan 815_0101 N First Floor Plan 815_0102 N Second Floor Plan 815_0103 N Third Floor Plan 815_0104 N Fourth Floor Plan 815_0105 N Fifth Floor Plan 815_0106 N Sixth Floor Plan 815_0107 N Seventh Floor Plan 815_0108 M Eighth – Sixteenth Floor Plans 815_0117 M Seventeenth Floor Plan 815_0118 M Eighteenth Floor Plan 815_0119 M Nineteenth Floor Plan

815_0120 N Twentieth Floor Plan 815_0121 G Twenty-First Floor Plan 815_0122 G Twenty second Floor Plan 815_0123 G Roof Plan 815_0200 N Elevations 01 815_0201 M Elevation 02 815_0202 L Elevation 03 815_0203 K Elevation 04 815_0204 L Elevation 05 815_0205 L Elevation 06 815_0206 F Elevation 07 815_0207 J Elevation 08 Revised Planning Statement and Appendices (CgMs, March 2011) Revised Design and Access Statement (RMA Architects, March 2011) Revised Non Technical Summary (CgMs, April 2011) Updated Flood Risk Assessment (CgMs, June 2009) Revised Environmental Assessment: Text Only (CgMs, March 2011) including Transport Assessment (Colin Buchanan & Partners, updated March 2011) Revised Environmental Assessment: Technical Appendices Part 1 (CgMs, March 2011 BVP letter dated 1st June 2011, Appendix 64c dated 13th June 2011) Updated Baseline Ecological Evaluation (May 2011) Construction Ecological Management Plan: Draft Heads of Terms (May 2011) Planning Energy Statement (April 2011) Statement of Community Consultation and Appendices (CgMs, February 2008 and March 2010) Reason To ensure that the development is carried out in accordance with the approved documents, plans and drawings submitted with the application (or other documents, plans and drawings subsequently approved in writing by the local planning authority) and to ensure that the development is acceptable to the local planning authority. 2. Time limit The development must be begun not later than three years from the date of the grant of this permission. Reason To comply with Section 91 of the Town and Country Planning Act 1990. 3. Restriction of A1 floorspace Class A1 retail floorspace on the site shall not exceed 300m2 (gross internal area).

Reason 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 Policies STC 2 Location of New Stores (Sequential Test) in the adopted Unitary Development Plan (July 2004) and 3D.1 Supporting Town Centres in the adopted London Plan (February 2008). Details 4. Detail for all phases No phase of the development shall be commenced until details of the following matters in respect of that phase have been submitted to and approved in writing by the local planning authority: i) detailed elevational drawings and sections to a scale of 1:50 and 1:100 ii) details of existing and finished ground levels for the application site iii) details of finished ground levels around each building The development shall be carried out in accordance with the approved details. Reason In order that the local planning authority is satisfied with the details of the proposed development. 5. External materials (buildings) No development shall commence on any phase until details, including samples, of all facing materials (including their colour and texture) to be used on the building(s) in that phase have been submitted to and approved in writing by the local planning authority. The development shall be carried out in accordance with the approved details, unless the local planning authority agrees in writing to any variation. Reason To ensure that the Development is of a satisfactorily high design standard to ensure that it makes a positive contribution to the appearance of the locality and to comply with Policy URB 3 Urban Design in the adopted Unitary Development Plan (July 2004). 6. External lighting (i) Details of all external lighting to be installed within each phase, including details of directional hoods and measures to prevent light spillage, shall be submitted to and approved in writing by the local planning authority not later than six months following the commencement of that phase.

(ii) All such external lighting shall be installed in accordance with the approved details before any dwelling in the relevant phase is occupied and thereafter any external lighting (including any directional hoods) shall be retained in accordance with the approved details. (iii) Details submitted for approval pursuant to paragraph (i) of this condition, shall be accompanied by a supporting statement which demonstrates that the proposed lighting is the minimum needed for security and working purposes and that the proposals minimise pollution from glare and spillage. Reason To ensure that the lighting is installed and maintained in a manner which will minimise possible light pollution to neighbouring properties and to comply with Policies ENV.PRO 12 Light Generating Development and HSG 4 Residential Amenity in the adopted Unitary Development Plan (July 2004). 7. Shopfronts (i) Details of the shopfronts to all non-residential accommodation hereby approved shall be submitted to and approved in writing by the local planning authority before being installed. (ii) The said shopfronts shall be installed in accordance with the approved details. Reason In order to ensure an acceptable external appearance and that the design provides adequate access for everyone, particularly people with disabilities and to comply with Policy URB 8 Shopfronts in the adopted Unitary Development Plan (July 2004). 8. Lifetime Homes and wheelchair accessible/adaptable units No phase of the development shall commence on site until drawings for each dwelling type in that phase demonstrating compliance with Lifetime Homes standards has been submitted to and approved in writing by the local planning authority. The development shall be constructed in accordance with the approved drawings and on completion of the development not less than 70 of the dwellings shall be wheelchair accessible or shall be easily adaptable for wheelchair users (designed to SELHP August 2009 standards) in accordance with drawings submitted to and approved in writing by the local planning authority. Reason In order to comply with the requirements of Section 76 of the Town and Country Planning Act 1990 which relates to the provision of satisfactory access to buildings for people with disabilities and to comply with Policy HSG

5 Layout and Design of New Residential Development in the adopted Unitary Development Plan (July 2004). Sustainability 9. Code for Sustainable Homes No dwelling hereby approved shall be occupied until a Code for Sustainable Homes Level 4 post-construction certificate and verified Code for Sustainable Homes report for that dwelling has been submitted to and approved in writing by the local planning authority. Reason To ensure the use of sustainably-sourced and recycled materials and aggregates and the sustainable use of water, and to meet the requirements of Policies 4A.3 Sustainable Design and Construction and 4A.16 Water Supplies and Resources in the adopted London Plan (February 2008). 10. BREEAM The non-residential floorspace hereby approved shall not be occupied until a BREEAM 2008 Excellent design and procurement certificate and report has been submitted to and approved in writing by the local planning authority. A post construction certificate to demonstrate compliance with the design and procurement assessment shall be submitted to the local planning authority within 3 months of the occupation of the non-residential floorspace. Reason To meet the requirements of Policies 4A.3 Sustainable Design and Construction and 4A.16 Water Supplies and Resources in the adopted London Plan (February 2008). 11. Performance of the CHP and future connection to a district CCHP or CHP scheme No development shall commence on site until a written specification for the on-site CHP facility demonstrating the carbon-dioxide emission reductions to be achieved, and information, drawings and sections showing a scheme for the provision of conduits and/or piping for future connection to a district CCHP or CHP scheme and network have been submitted to and approved in writing by the local planning authority. Reason To ensure that the projected carbon-dioxide emission reductions are achieved and to enable the future connection of the development to a district CCHP or CHP scheme and network, and to comply with Policy 4A.6 (Decentralised Energy: Heating, Cooling and Power) in the London Plan (February 2008) Consolidated with Alterations Since 2004.

12. Living Roofs The provision of living roofs shall be no less than as shown on the submiited drawings and development on any phase shall not commence until details of living roofs (including roof plans to a scale of 1:50, cross-sections to a scale of 1:20, specification and details of a substrate base with a depth of 80-150mm, and details of management) for that phase have been submitted to and approved in writing by the local planning authority. No part of the relevant phase shall be occupied until the living roofs forming part of the approved scheme have been implemented in full, and the living roofs shall be planted or seeded with the approved mix of species within the first planting season following the practical completion of building works. The living roofs shall not be used for play or recreation and shall only be used in the case of essential maintenance or repair, or escape in case of emergency. The living roofs shall be maintained as such thereafter and no change therefrom shall take place without the prior written consent of the local planning authority. Reason To ensure the development provides the maximum possible provision of living roofs to enable the creation of habitats and areas for biodiversity and to reduce the rate and volume at which rainwater reaches watercourses in times of heavy or prolonged rainfall, in accordance with Policies OS 13 Nature Conservation and ENV.PRO 15 Sustainable Surface Water Drainage in New Development in the adopted Unitary Development Plan (July 2004), Policies 3D.14 Biodiversity and Nature Conservation, 4A.3 Sustainable Design and Construction, 4A.9 Adaptation to Climate Change, 4A.11 Living Roofs and Walls and 4A.14 Sustainable Drainage in the London Plan (February 2008) Consolidated with Alterations Since 2004), and Planning Policy Statement 9: Biodiversity and Geological Conservation (2005) and Planning Policy Statement 25: Development and Flood Risk (2006). 13. Car Club car parking (i) Details of the proposed number, location, size, and layout of the spaces to be provided and reserved for Car Club use shall be submitted to and approved in writing by the local planning authority before the commencement of the phase(s) in which they are located. (ii) The said spaces shall be provided and made available for use before any part of the relevant phase is occupied. Thereafter the spaces shall be retained and used only for parking cars associated with the Car Club. Reason To limit car ownership/use and encourage sustainable modes of transport in accordance with Policies 3C.3 (Sustainable transport in London) and 3C.23 (Parking Strategy) in the approved London Plan (Consolidated with Alterations since 2004 (February 2008).

14. Electric Vehicle Charging Points (i) Details of electric vehicle charging points to be provided in each phase and a programme for their installation and maintenance shall be submitted to and approved in writing by the local planning authority prior to commencement of the phase within which they are to be located. (ii) The electric vehicle charging points as approved shall be installed prior to first occupation of the relevant phase and maintained in accordance with the details approved under (i). Reason To reduce pollution emissions in an Area Quality Management Area in accordance with London Plan Policy 4A.19 (Improving air quality). 15. Detailed Waste Management Plans (i) A detailed waste management plan (WMP) (to include details for the disposal, processing, recycling and storage of operational waste and for the provision of composting facilities) for each phase shall be submitted to and approved in writing by the local planning authority no later than three months following the commencement of that phase. (ii) The development of each phase shall be carried out and operated in accordance with the approved WMP relating to that phase unless minor variations are otherwise approved in writing by the local planning authority. Reason To ensure that waste is minimised as far as practicable and managed in an environmentally sustainable way and to comply with Policy 4A.21 (Waste strategic policy and targets) in the London Plan. Residential Amenity 16. Minimum Flat Size All flats shall achieve at least the minimum floorspace (gross internal area) set out in the Council’s Adopted Residential Standards Supplementary Planning Document (August 2006). Reason To ensure a satisfactory environment for the residential occupiers of the development and to comply with Policy HSG 5 Layout and Design of New Residential Development and Adopted Residential Standards. 17. Balconies and Roof-top Amenity Space No flats in Block J shall have external balconies at second floor level or above and details of boundary treatment and screening to any roof-top

amenity spaces shall be submitted to and approved by the local planning authority prior to commencement of the relevant phase of the development. Reason To ensure that the amenity of adjoining residential properties is safeguarded and to comply with Policy HSG 5 Layout and Design of New Residential Development and Adopted Residential Standards. 18. Noise Insulation Details for each phase, including relevant drawings and specifications of:- (a) The construction of the ceilings and walls separating the residential

and non-residential uses hereby permitted and (b) The proposed works of soundproofing against airborne and impact

sound and vibration shall be submitted to and approved in writing by the local planning authority prior to commencement of the relevant phase. The uses hereby permitted shall not commence in that phase until the soundproofing works have been implemented in accordance with the approved details. The soundproofing shall be retained permanently in accordance with the approved details. Reason To ensure a satisfactory environment for the residential occupiers of the development and so as to comply with Policy ENV.PRO11 (Noise Generating Development) in the adopted Unitary Development Plan (July 2004). 19. Noise and vibration from fixed plant and machinery (i) The rating level of the noise emitted from fixed plant and machinery on the development including the CHP plant shall be 5dB below the existing background level at any time, as measured at the façade of any noise sensitive receptor. The measurements and assessments shall be made according to BS4142:1997. (ii) For any particular phase, the design, operation and maintenance details of a scheme for compliance with paragraph (i) of this Condition shall be submitted to and approved in writing by the local planning authority within three months of commencement of that phase. (iii) No phase shall be occupied until the approved scheme has been implemented in its entirety in relation to that phase. (iv) Thereafter, the approved scheme shall be retained and maintained in accordance with the approved details.

Reason To ensure a satisfactory environment for the occupiers of the development and so as to comply with Policy ENV.PRO11 (Noise Generating Development) in the adopted Unitary Development Plan (July 2004). 20. A3 and A5 hours of use Any A3 or A5 use within the site shall not be open to the public other than between the hours of 8.00am and 11.00pm 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). 21. Ventilation No A3 or A5 use shall be fitted out or commence on site until detailed plans and a specification of the equipment comprising a ventilation system which shall include measure to alleviate noise, vibration, fumes and odours (and incorporating active carbon filters, silencer(s) and anti-vibration mountings where necessary), have been submitted to and approved in writing by the local planning authority. The ventilation system shall be installed in accordance with the approved plans and specification before the A3 or A5 use commences and shall thereafter be permanently maintained in accordance with the approved specification. Reason To ensure that the proposed development does not prejudice the enjoyment by neighbouring occupiers of their properties and to comply with Policies ENV.PRO 11 Noise Generating Development, HSG 4 Residential Amenity and STC 9 Restaurants, A3 Uses and Take Away Hot Food Shops in the adopted Unitary Development Plan (July 2004). 22. A1, A2, A3 and A5 delivery hours No deliveries shall be made to any A1, A2, A3 or A5 use within the site other than between the hours of 7.00am and 11.00pm Monday to Friday, 7.00am to 7.00pm on Saturdays and 7.00am to 5.00pm on Sundays and Bank Holidays. 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).

23. Air quality No development of any phase shall commence on site until a detailed for the CHP facility has been submitted to and approved by the local planning authority and the CHP shall be constructed in accordance with the approved details and specifications, unless minor variations are approved in writing by the local planning authority. Reason

To reduce pollution emissions in an Area Quality Management Area in accordance with London Plan Policy 4A.19 (Improving air quality). Landscaping 24. Landscaping details No development of any phase shall commence on site until detailed landscaping proposals for the site have been submitted to and approved by the local planning authority. Details shall include but not be limited to: (a) a drawing showing the trees on the site to be retained, removed and replaced (b) drawings showing hard and soft landscaping of any part of the site not occupied by buildings including any retained features and the treatment thereof (including planting, tree species and location, paving, walls and fences, temporary and permanent site boundary treatments, details of the permeability of hard surfaces), (c) drawings showing hard and soft landscaping to be provided in Blocks B, C and D (d) details of the management and maintenance of the landscaping for that phase have been submitted to and approved in writing by the local planning authority. All works which form part of the landscaping scheme shall be completed in the first planting season following the completion of that phase, unless the local planning authority has given written consent to any variation. 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, unless the local planning authority has given written approval to any variation. Reason In order that the local planning authority may be satisfied as to the details of the proposal and to comply with Policies URB 3 Urban Design, URB 12 Landscape and Development and URB 13 Trees in the adopted Unitary Development Plan (July 2004). 25. Ecological enhancement Development shall not commence until a site-wide strategy for ecological

enhancement and mitigation including a habitat management plan setting out details of monitoring arrangements has been submitted to and approved in writing by the local planning authority. The habitat management plan will be implemented in full as approved. Reason In order that the local planning authority may be satisfied as to the details of the proposal and to comply with Policies URB 3 Urban Design, URB 12 Landscape and Development and OS 13 Nature Conservation in New Development in the adopted Unitary Development Plan (July 2004), and Policy 3D.14 (Biodiversity and nature conservation) in the London Plan. 26. Trees – protection during construction No development of any phase shall commence on site until adequate steps have been taken in accordance with Section 8 of BS 5837:2005 Trees to safeguard all trees to be retained within or adjacent to that phase against damage, prior to or during building works, including the erection of fencing. These fences shall be erected to the extent of the crown spread of the trees, or where circumstances prevent this, to a minimum radius of 2 metres from the trunk of the tree and such protection shall be retained until the development has been completed. No excavations, site works, trenches or channels shall be cut, or pipes or services laid in such a way as to cause damage to the root structure of the trees. Reason To safeguard the health and safety of trees during building operations and the visual amenities of the area generally and to comply with Policies URB 3 Urban Design, URB 12 Landscape and Development and URB 13 Trees in the adopted Unitary Development Plan (July 2004). Archaeology and Heritage 27. Archaeology No development shall take place on the site until the applicant, or any successors in title, has secured the implementation of a programme of archaeological work in accordance with a written scheme of investigation, observation and recording which has been submitted to and approved in writing by the local planning authority. Reason To ensure adequate access for archaeological investigations and to comply with Policy URB 21 Archaeology in the adopted Unitary Development Plan (July 2004). 28. On-site heritage assets All stones, bricks and paving materials that formed part of the original Grand Surrey Canal towpath and canal edge and that are intact and remain on site

shall be retained and reused in the landscaping of the site, unless the local planning authority agrees in writing to any variation. Reason To ensure that heritage assets remaining on site are retained and reused in the development. Construction Management 29. Construction and Environmental Management Plan (i) No works (including demolition and construction) shall commence in each phase until a Construction and Environmental Management Plan, including but not limited to details of hours of works, wheel washing, dust minimisation, noise mitigation relating to on-site crushing, and deliveries, details of compliance with the relevant Code of Construction Practice, and incorporating a Construction Traffic Management Plan and Construction Logistics Plan in respect of that phase has been submitted to and approved in writing by the local planning authority. (ii) No works (including demolition and construction) in the relevant phase shall be carried out other than in accordance with the approved Construction Management Plan. Reason To ensure that the demolition and construction processes are carried out in a manner which will minimise noise, vibration, dust and mud pollution and minimise disturbance from road traffic and safeguards road safety and the amenities of adjacent occupants in accordance with Policies ENV.PRO 9 Potentially Polluting Uses, ENV.PRO 11 (Noise Generating Development) and HSG 4 (Residential Amenity) in the adopted Unitary Development Plan (July 2004) and that all reasonable measures have been taken to improve construction freight efficiency by reducing CO2 emissions, congestion and collisions in accordance with Policy TRN20 (Improving Road Safety) in the adopted Unitary Development Plan (July 2004) and Policy 3C.25 (Freight Strategy) in the approved London Plan (Consolidated with Alterations since 2004 (February 2008). Flood Risk 30. Flood risk The development permitted by this planning permission shall only be carried out in accordance with the approved Flood Risk Assessment (FRA) carried out by WSP Development and Transportation dated October 2007 and the mitigation measures detailed within the FRA. Reason To ensure the development is designed safely in reference to flood risk and to ensure the development minimises risk associated with flooding in

accordance with Policy ENV.PRO 15 (Sustainable Surface Water Drainage in New Development) in the adopted Unitary Development Plan (July 2004) and Policy 4A.13 (Flood risk management) in the approved London Plan (Consolidated with Alterations since 2004 (February 2008). 31. Green Roofs Green Roofs design showing a satisfactory reduction in the total discharge rate shall be carried out in accordance with details which shall be submitted to and approved in writing by the local planning authority before development commences. Reason To prevent the increased risk of flooding. 32. Surface water (i) No phase shall commence until a scheme of surface water management, including specifications of the surface treatments and sustainable urban drainage solutions, has been submitted to and approved in writing by the local planning authority, in consultation with the Environment Agency and Thames Water. (iii) Each phase shall be carried out in accordance with the approved scheme for that phase 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 Policy ENV.PRO 15 (Sustainable Surface Water Drainage in New Development) in the adopted Unitary Development Plan (July 2004) and Policy 4A.12 (Flooding) in the approved London Plan (Consolidated with Alterations since 2004 (February 2008). Contamination 33. Contaminated land (a) No development shall take place until each of the following has occurred:

(i) a site investigation has been carried out to survey and assess the extent of potential contamination and its effect (whether on or off site); (ii) a report comprising the results of that site investigation and recommendations for treatment of any contamination (whether by remedial works or not) has been submitted to and approved in writing by the local planning authority; and (iii) all measures or treatments identified in that report as being necessary or desirable for the remediation of the site have been implemented in full.

(b) If during any works at the site (whether pursuant to paragraph (a) of this condition or implementation of this planning permission generally) contamination is encountered which has not previously been identified (“the new contamination”), then paragraph (a) shall apply to the new contamination and no further development shall take place 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 local planning authority. The closure report shall include details both of the remediation (including waste materials removed from the site, an audit trail demonstrating that all imported or reused soil material conforms to current soil quality requirements as approved by the local planning authority) and any post-remediation sampling that has been carried out. Reason To ensure that the local planning authority may be satisfied that potential site contamination is identified and remedied in view of the historical uses of the site, which may have included industrial processes and to comply with Policy ENV.PRO 10 Contaminated Land in the adopted Unitary Development Plan (July 2004). 34. Piling operations (i) Piling or any other foundation designs using penetrative methods shall not be permitted, other than with the prior written consent of the local planning authority. Any such application for consent shall be accompanied by details of the relevant penetrative methods. (ii) The said piling shall be carried out only in accordance with the written consent of the local planning authority. Reason To prevent pollution of controlled waters and to comply with Policies ENV.PRO 10 Contaminated Land and ENV.PRO 17 Management of the Water Supply in the adopted Unitary Development (July 2004). Transport 35. Use of car parking i) All car parking spaces within the development shall be reserved for and used by vehicles of the occupiers or users of the development only. ii) No phase shall be occupied until details of the allocation of the car parking spaces to the uses within that phase have been submitted to and approved in writing by the local planning authority.

Reason To ensure the permanent retention of the space(s) for parking purposes, to ensure uses within each phase are not over-provided with car parking spaces, to ensure that the development does not increase on-street parking in the vicinity and to comply with Policy TRN 26 Car Parking Standards in the adopted Unitary Development Plan (July 2004). 36. Cycle parking (i) A minimum of 749 cycle parking spaces shall be provided within the development, as follows:- Residential – 696 spaces Commercial – 53 spaces (ii) A minimum of 30 visitors’ cycle parking spaces shall be provided. (ii) No phase shall be occupied until the cycle parking spaces to be provided within that phase have been provided and made available for use. Thereafter, such spaces shall be retained and used only as cycle parking for use as provided for in paragraphs (i) and (ii) of this Condition. Reason In order to ensure adequate provision for cycle parking and to comply with Policies TRN 14 (Cycle Parking) and TRN 15 (Provision for Cyclists and Walkers) in the adopted Unitary Development Plan (July 2004). 37. Motorcycle parking (i) A minimum of 39 motorcycle parking spaces motorcycle parking spaces shall be provided within the development as follows: Residential – 28 spaces Commercial – 11 spaces (ii) No phase shall be occupied until the motorcycle parking spaces to be provided within that phase have been provided and made available for use. Thereafter such spaces shall be retained and used only as motorcycle parking for use as provided for in paragraph (i) of this condition. Reason In order to ensure adequate provision for motorcycle parking and to comply with Policy TRN 28 (Motorcycle Parking) in the adopted Unitary Development Plan (July 2004). 38. Delivery Service Plan No phase of the development shall be occupied until a Delivery Service Plan demonstrating how the number and time of delivery and servicing trips to the development is to be rationalised with the aim of reducing the impact of

servicing activity has been submitted to and approved by the local planning authority and the development shall be implemented in accordance with the approved Delivery Service Plan. Reason In order to reduce development servicing traffic and to comply with Policy TRN 21 Traffic Management in the adopted Unitary Development Plan (July 2004). Informatives 1 Applicants should 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.

2 Assessment of the scheme required by Condition 17 (Noise from fixed

plant and machinery) must be carried out by a suitably qualified acoustic consultant.

3 With regard to Condition 27, the Construction Management Plan will

be required to confirm that no deliveries to the site in connection with demolition or construction works shall take place outside the hours of 8 am and 6 pm on Mondays to Fridays and 8 am and 1 pm on Saturdays and that no such deliveries shall take place at all on Sundays or public holidays.

4 With regard to Condition 27, the relevant Code of Construction

Practice can be viewed online at: http://www.lewisham.gov.uk/Environment/Pollution/PollutionNoiseDocument.htm

5 Your attention is drawn to comments provided by Thames Water on

13/04/2011 regarding water supply capacity.

6 Green roofs should be designed to provide a minimum of 13% run off rate reduction for the 1 in 100 year plus 30% climate change storm event. This will achieve a total of 50 % run-off rate reduction stipulated by the London Plan's Supplementary Planning Guidance (SPG).