Committee STRATEGIC PLANNING COMMITTEE Item No. 3 …

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Committee STRATEGIC PLANNING COMMITTEE Item No. 3

Report Title MARINE WHARF WEST, PLOUGH WAY SE16 7UE

Ward Evelyn

Contributors Victor Grayson

Class PART 1 Date 4 NOVEMBER 2010

Reg. Nos. DC/10/73437, DC/10/73437A &DC/10/73437B

Application dated 29.1.10 completed 16.2.10, additionalinformation received 23.7.10 and revised20.8.10 and 22.10.10

Applicant Indigo Planning Ltd on behalf of BerkeleyHomes (Urban Renaissance) Ltd

Proposal The construction of new buildingsbetween 1 and 8 storeys in height atMarine Wharf West (land formerlyoccupied by Jet Stationery), Plough WaySE16 to accommodate 4,126 squaremetres of commercial floorspace (UseClasses A1/A2/A3/B1/B1c), 532residential units (including 78 unitsprovided as an "Extra Care" facility), carparking, pedestrian and vehicular access,landscaping, new public open spacealong the route of the former GrandSurrey Canal, and other associatedworks.

Applicant's Plans and other documents submitted with the application

(1) Revised application drawings (August 2010, listed in Appendix 1);(2) Planning Statement (Indigo Planning, January 2010) as amended/supplemented by

Indigo Planning letter dated 19/08/2010 and Accommodation Schedule received20/08/2010;

(3) Design and Access Statement (Hamiltons, January 2010) asamended/supplemented by Addendum Design and Access Statement (GridArchitects, August 2010);

(4) Environmental Statement Non Technical Summary (WSP, January 2010);(5) Environmental Statement Volume 1: Main Text and Figures (WSP, January 2010) as

amended/supplemented by Environmental Statement Addendum (WSP, August2010);

(6) Environmental Statement Volume 2: Technical Appendices (WSP, undated, receivedFebruary 2010) as amended/supplemented by Environmental Statement Addendum(WSP, August 2010);

(7) Transport Assessment (Savell Bird and Axon, January 2010) asamended/supplemented by Transport Assessment Addendum (Savell Bird andAxon, August 2010);

(8) Transport Assessment Appendices (Savell Bird and Axon, January 2010);(9) Employment Land Report (Colliers CRE, January 2010);

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(10) Landscaping Design Statement (Fabrik, January 2010) as amended/supplementedby Addendum Landscaping Design Statement (Fabrik, August 2010);

(11) Daylight and Sunlight Report (Drivers Jonas, January 2010) asamended/supplemented by Daylight and Sunlight Addendum (Drivers Jonas, August2010);

(12) Energy Statement Report (Meinhardt, October 2010);(13) Revised Drainage Strategy Report (Meinhardt, August 2010);(14) Tree Survey Report and Arboricultural Impact Assessment (Tree Fabrik, January

2010); and(15) Statement of Community Involvement (Urban Practitioners, January 2010);(16) Clarification to Townscape and Visual Impact Assessment Plans and Photographs

(Fabrik, July 2010);(17) Visually Verified Montages (VVMs) Methodology Statement (Glass Canvas,

undated); and(18) Confidential viability information received 15/07/2010.

Background Papers

(1) Case File – DE/153/C/TP(2) Adopted Unitary Development Plan (July 2004)(3) Core Strategy submission version (July 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)

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(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 (September 2010)

Zoning UDP – Defined Employment Area,Thames Policy Area, Site of NatureConservation Importance, Area ofArchaeological Priority, Strategic ViewingCorridor and Strategic Wider ViewingCorridorCore Strategy – Plough Way Strategic Site

CONTENTS Page

1. INTRODUCTION 81.1 Purpose of this Report 81.2 Background 82. APPLICATION SITE AND SURROUNDINGS 92.1 Introduction 92.2 Site Description 92.3 The Surrounding Area 102.4 Relevant Planning History 12 3. PRESENT APPLICATION 133.1 Format of Present Application 133.2 General Layout and Uses 133.3 Description of Proposed Buildings and Uses 15 3.4 Residential Accommodation 183.5 Non-Residential Uses 19 3.6 Open Space, Playspace and Landscaping 193.7 Parking and Movement 203.8 Servicing and Refuse 20

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3.9 Highway Works 203.10 Temporary Arrangements 203.11 Implementation and Phasing 213.12 Environmental Impact Assessment 213.13 Other Application Documents 284. CONSULTATION 334.1 Introduction 334.2 Consultation Process 334.3 Consultation Responses 35 5. PLANNING POLICIES AND GUIDANCE 46 5.1 Introduction 46 5.2 Planning Policy Guidance and Planning Policy Statements 465.3 London Plan 475.4 Adopted Unitary Development Plan 515.5 Local Development Framework 54 6. PLANNING CONSIDERATIONS 55 6.1 Introduction 55 6.2 Principle of Development 56 6.3 Land Use: Employment 626.4 Land Use: Housing 646.5 Land Use: Retail 696.6 Urban Design 71 6.7 Transport 78 6.8 Environmental Sustainability 83 6.9 Other Planning Considerations 85 7. ENVIRONMENTAL IMPACT ASSESSMENT 897.1 Introduction 89 7.2 Noise and Vibration 89 7.3 Air Quality 907.4 Ecology 917.5 Archaeology 927.6 Ground Conditions and Contamination 93 7.7 Water Quality and Resources and Flood Risk 947.8 Townscape and Visual 94 7.9 Socio-economics 97 7.10 Waste Management 98 7.11 Micro-climate – Wind 99 7.12 Cumulative Effects 1007.13 Residual Effects 1008. FINANCIAL VIABILITY AND DELIVERY 1008.1 Introduction 1008.2 Viability and Deliverability 1019. CONSIDERATION OF OBJECTIONS 1069.1 Introduction 10610. LEGAL AGREEMENTS 10710.1 Introduction 10710.2 Planning Obligations (Section 106 Agreement) 10811. CONCLUSIONS AND RECOMMENDATIONS 11011.1 Introduction 110

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11.2 Summary of Reasons for Grant of Planning Permission 11211.3 Conditions 114

APPENDICES1 List of Submitted Drawings 1282 Map Showing Consultation Letter Distribution Area 1293 Summary of Responses from Residents and Businesses 1304 Notes taken at Local Meeting 134

1. INTRODUCTION

1.1 Purpose of the Report

1.1.1 On 29/01/2010 the Council received an application for full planning permissionmade by Indigo Planning Ltd on behalf of Berkeley Homes (Urban Renaissance)for the redevelopment of the site formerly occupied by Jet Stationary at MarineWharf. The proposed development comprised a total of 532 residential units(including 78 units provided as an “Extra Care” facility), 4,126 square metres ofcommercial floorspace (Use Classes A1/A2/A3/B1/B1c), in buildings ranging from1 to 8 storeys in height, together with car parking, pedestrian and vehicularaccess, landscaping, new public open space along the route of the former GrandSurrey Canal, and other associated works.

1.1.2 The proposed development was subsequently amended on 20/08/2010. Theamendments did not significantly change the above development description, andincluded:

• The provision of a pedestrian connection to Carteret Way;• The re-allocation of 25 of the private housing units to shared ownership

units;• Deletion of previously proposed biomass boilers and provision of a single

gas-fired combined heat and power facility in block C4;• Changes to elevations, internal layouts, southern courtyard access, parking

provision and café at the end of the linear park; and• The submission of addenda to the Environmental Statement, Design and

Access Statement, Transport Assessment and other documents.

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

1.2 Background

1.2.1 The following background information is relevant to the current application.

1.2.2 Until August 2008 much of the application site was occupied by a large part single-storey, part 2-storey warehouse building which provided 12,252 square metres ofemployment floorspace. This building was occupied by Jet UK Ltd (Jet Stationery),who went into administration in late 2006. In early 2007 the business waspurchased and reformed as Concord Office Products Ltd, who continued tooccupy the application site until February 2008 when they relocated to Woolwich.Berkeley Homes acquired the site from the then owners, The Prudential, inSeptember 2007 and dismantled the warehouse building in August 2008.

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1.2.3 The site is in the freehold ownership of the applicant. The applicant refers to theapplication site and other adjacent sites collectively as “Surrey Wharves”.

1.2.4 The application site forms part of the Plough Way Strategic Site designation in theDraft Core Strategy, which is at submission version stage. This is the firstapplication for mixed use development at one of the Strategic Sites in Deptfordand New Cross to be reported to members for determination, although anapplication for the Oxestalls Road strategic site was reported to the StrategicPlanning Committee in 15/07/2010 to update members on progress and to seekendorsement of officers’ negotiating stance.

2. APPLICATION SITE AND SURROUNDINGS

2.1 Introduction

2.1.1 This section describes the site and surrounding area, and outlines relevantplanning history.

2.2 Site Description

2.2.1 The application site comprises a vacant 2.83 hectare parcel of land bounded byPlough Way (the B206) to the north and flanked by the Marine Wharf East site tothe east, the Pepys Estate to the east and south, the Cannon Wharf site and 19Yeoman Street to the west, and the Iceland Wharf development to the north.Plough Way forms the borough boundary with LB Southwark. The site is boundedto the north, east and south by fences 2 to 3 metres high. The site includes withinits boundaries part of the former route of the Grand Surrey Canal – this land runsnorth-south along the site’s western edge and is currently overgrown. Theconcrete slab of the now-dismantled warehouse building remains on site, as doesthe adjacent car park, therefore most of the site is currently hard surfaced. Anelectricity substation lies within the application site, adjacent to the pavement ofPlough Way.

2.2.2 Ground levels do not vary significantly within the application site, however alongthe former route of the Grand Surrey Canal there is a drop in levels of up to 1.8metres from east to west. This drop continues along all of this part of the formerroute of the canal, so that the Cannon Wharf site to the west is on lower groundthan the application site.

2.2.3 Most of the vegetation within the site is confined to its perimeter, with tall Cypresstrees lining the southern boundary (along Carteret Way), Ash trees lining part ofthe eastern boundary, and young trees and self-seeded buddleia present alongthe Plough Way frontage.

2.2.4 Vehicular access to the site is limited to a single point of access on Plough Way(opposite 151 and 153 Plough Way). A right-turn filter exists in the road at thispoint. Vehicular access to Iceland Wharf to the north is shared with the applicationsite although this access was not used when the site was last in active use.

2.2.5 In the adopted Lewisham UDP the application site lies within a DefinedEmployment Area, an Area of Archaeological Priority, and the Thameside PolicyArea. All of the site falls within an area of Public Open Space Deficiency and anArea of Nature Conservation Deficiency. That part of the site that is the route ofthe former Grand Surrey Canal is designated as a Site of Nature ConservationInterest. The Strategic Viewing Corridor and Strategic Wider Viewing Corridor –

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Greenwich Park to St Paul’s Cathedral – crosses the site (the different terminologyused by the Mayor of London for this designation is explained in sub-section 7.8 ofthis report).

2.3 The Surrounding Area

2.3.1 The area surrounding the application site accommodates a mix of residential andindustrial/commercial uses.

2.3.2 To the east is a site referred to as Marine Wharf East which is currently occupiedby a 2-storey office building with a surface car park adjacent to the application site.To the east and south the Pepys Estate abuts the application site with 2- and 3-storey terraced dwellings of Carteret Way. To the west, on the opposite side of theformer route of the Grand Surrey Canal, is the Cannon Wharf site (which, in thisreport, is taken to include the former Salter Paper Group and Insulcrete sites).Much of this site is hard surfaced, with low-rise industrial sheds and high fenceslining the boundary with the application site. To the west of these is the CannonWharf business centre, accessed from Evelyn Street and built in the 1970s asGuy’s Hospital Laundry. 19 Yeoman Street, which shares a short commonboundary with the application site at its northwest corner, is almost entirelycovered by an open-sided industrial shed. The application site also shares a shortcommon boundary with the Iceland Wharf development (once known as “The OvalSite”) on Plough Way – the vehicular access to these flats abuts the applicationsite. On the opposite side of Plough Way, within LB Southwark, are residential andoffice buildings.

2.3.3 Built form and building heights in the wider area surrounding the application sitevary. Virtually all development surrounding the application site dates from the 20th

Century, and includes the abovementioned 2- and 3-storey dwellings (built in darkbrown brick) of the Pepys Estate, which extends as far south as Leeway andConvoys Wharf. Within that estate are taller blocks of 8 storeys, and 3 towersranging in height from 26 to 31 storeys. To the west, the Cannon Wharf businesscentre rises to 3 storeys, and beyond this – fronting Evelyn Street – are the 5-storey blocks of flats at Pomona House and Hazelwood House. Iceland Wharf, atthe north tip of the application site, consists of a group of brick and renderedbuildings that rise to 8 storeys. Buildings on the opposite side of Plough Wayrange in height from 2- to 4-storeys. Further north are South Dock and the 15-storey Baltic Quay development, built during the epoch of the London DocklandsDevelopment Corporation. All buildings on this part of Plough Way are positionedaway from the backs of pavements, in some cases significantly so.

2.3.4 The nearest intact buildings of any significant age are the 2-storey Victorianterraced dwellings of 52 to 62 Croft Street, however these properties do not abutthe application site. Remnants of docklands heritage survive in the surroundingarea, including the nearby South Dock and Greenland Dock, the restored dockoffice on Rope Street, mooring posts, and the remaining buildings of Deptford’sdocks and the Royal Victoria (victualling) Yard, where several buildings are GradeII listed.

2.3.5 The topography of the surrounding area is similar to that of the application site,with no significant variations in ground levels, however infilling of the route of theGrand Surrey Canal directly to the south of the application site has raised groundlevels above the level of the route of the canal within the application site.

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2.3.6 Trees and other vegetation in Carteret Way and in the rear gardens of residentialproperties line parts of the southern and eastern boundaries of the application site.

2.3.7 The largest areas of public open space within 1km of the application site areDeptford Park, Pepys Park and Southwark Park. In addition, there are smallergreen spaces within the Pepys Estate.

2.3.8 The site is served by the 199 bus (and N1 night bus) along Plough Way. Thenearest bus stop to the application site is located on Plough Way outside theMarine Wharf East site. Other bus routes (the 47, 188 and N47) can be accessedon Evelyn Street. The nearest London Overground station is Surrey Quays withunderground services further away at Canada Water on the Jubilee Line, and thenearest railway stations are at South Bermondsey and Deptford providingconnections to south and central London and Kent. Commuter river services areavailable from Greenland Pier, 400 metres to the northeast of the application site,providing connections as far as the London Eye Millennium Pier to the west, andWoolwich Arsenal to the east.

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

2.3.10 LB Lewisham maintains all of the part of Plough Way that abuts the applicationsite, however westwards from a point to the north of the application site (betweenIceland Wharf and Mast Court), all of the highway is the responsibility of LBSouthwark.

2.3.11 The nearest district centre within the Borough is Deptford, however the SurreyQuays Shopping Centre (to the northwest) is closer.

2.3.12 The application site falls entirely within LB Lewisham, however certain saved UDPdesignations of adjacent land within LB Southwark are noted, namely the ThamesSpecial Policy Area (Southwark Plan policy 3.29), Urban Density Zone (4.1) andAir Quality Management Area (3.6) designations.

Proposed Thames Tunnel

2.3.13 On 13/09/2010, Thames Water began public consultation on proposals for a newThames Tunnel (sewer) between Hammersmith and Abbey Mills or Beckton, andrelated surface development. Thames Water have identified part of the PloughWay strategic site – the Earl Pumping Station and adjacent land between CroftStreet and Yeoman Street – as the preferred site for construction work andpermanent structures related to the new tunnel beneath this land. Under thecurrent proposals this tunnel would be either 1) the connection tunnel runningbetween Greenwich and King's Stairs Gardens (where a connection would bemade with the Thames Tunnel if routed along Thames Water’s preferred AbbeyMills route); or 2) the Thames Tunnel itself if routed along the Rotherhithe route(which is not Thames Water's preferred route).

2.3.14 No surface development is currently proposed by Thames Water at the MarineWharf West site, however it is possible that the connection tunnel or the ThamesTunnel itself would pass beneath the southwest corner of the application site,under part of the proposed linear park. It is not anticipated that this would haveimplications on the proposed development (the tunnel would be up to 75 metres

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below ground), and as these recently-announced infrastructure proposals are, inany case, currently at consultation stage, and as no part of the Plough Waystrategic site is safeguarded, it is considered that Thames Water’s recentannouncement need not affect the Council’s consideration or determination of thecurrent application.

2.4 Relevant Planning History

The Application Site

2.4.1 Prior to 1999 the Council considered a series of applications for industrial andstorage buildings at what is now the Marine Wharf West site. On 31/03/1999 (Ref:DC/98/42956) planning permission was granted for the erection of a two storeybuilding to provide a production and distribution facility with ancillary servicing, carparking and landscaping. This was building remained on the site prior to itsdemolition by the current site owners in 2009. Condition 17 of the 1999 permissionstated: “No deliveries shall be taken at or despatched from the site outside thehours of 6am to 8pm Mondays to Fridays and 8am to 1pm on Saturdays and nowork shall take place on Sundays, Bank or Public Holidays”. A later approval ofventilation systems, refuse collection and lighting was subject to a conditionrequiring screen planting adjacent to residential properties in Carteret Way (ref:DC/99/45618).

2.4.2 25/11/2004 – Permission granted for the variation of a Condition 17 of thepermission dated 31/03/1999, to: “For a limited period until 30/11/2005, nodeliveries shall be taken at or despatched from the premises outside the hours of6am to 8pm Mondays to Fridays, 7.30am to 1pm on Saturdays, nor at any time onSundays, Bank or Public Holidays, with the exception of one delivery per dayoutside these times by Kingfield Heath Ltd. After this date no deliveries shall betaken at or despatched from the site outside the hours of 6am to 8pm Mondays toFridays, 7.30am to 1pm on Saturdays, nor at any time on Sundays, Bank or PublicHolidays”. Ref: DC/04/57741.

2.4.3 05/10/2006 – Permission granted for the variation of Condition 17 of thepermission dated 31/03/1999, to: “For a limited period until 30/10/2007, nodeliveries shall be taken at or despatched from the premises outside the hours of6am to 8pm Mondays to Fridays, 7.30am to 1pm on Saturdays, nor at any time onSundays, Bank or Public Holidays, with the exception of one delivery per dayoutside these times by Kingfield Heath Ltd. After this date no deliveries shall betaken at or despatched from the site outside the hours of 6am to 8pm Mondays toFridays, 7.30am to 1pm on Saturdays, nor at any time on Sundays, Bank or PublicHolidays”. Ref: DC/05/61188.

2.4.4 19/08/2009 – Environmental Impact Assessment Scoping Opinion issued by theCouncil (ref: DC/09/71888) in response to a formal request made by WSP onbehalf of Berkeley Homes (Urban Renaissance) Ltd in a letter dated 22/06/2009.The applicant described the proposed development as having the potential todeliver approximately 600 residential units and approximately 3,000 square metresof commercial floorspace, however no building heights or layout information wasprovided.

2.4.5 The current application for planning permission was received on 29/01/2010.

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Adjacent Sites (Relevant Planning History)

2.4.6 25/03/2008 – Planning application received for the demolition of existing buildingsat the Cannon Wharf Business Centre, 35 Evelyn Street SE8 and construction ofbuildings up to 23 storeys, comprising a business centre (3,964 square metres),studio/workshop space (2,405 square metres), commercial units, and a children'snursery (Use Classes B1, A1, A2, A3, A5 & D1), 279 one, 337 two, 78 three bedand 46 studio residential units, plus 5 three, 7 four and 4 five bed two/three storeyhouses, an energy centre, associated landscaping and provision of refuse stores,354 cycle and 484 car parking spaces, with accesses onto Evelyn Street,Rainsborough Avenue and Yeoman Street. Ref: DC/08/68523. Underconsideration.

2.4.7 14/05/2008 – Planning application received for the demolition of the existingbuildings at Marine Wharf East, Plough Way SE16 and construction of 7 single tofive storey buildings, comprising 10,892 square metres of Use Class B1 floorspace (office), cafe (271 square metres), crèche (270 square metres) and gym(389 square metres), together with associated landscaping, provision of serviceareas, refuse stores, 100 cycle spaces and 19 car parking spaces. Ref:DC/08/68907. Under consideration, currently held in abeyance.

2.4.8 26/02/2010 – Planning application withdrawn for the construction of a four to eightstorey building at 7-17 Yeoman Street SE8, comprising ground floor commercialuses (Use Classes A1, A2, A3, B1, D1 – 464 square metres) and 11 one-bedroom, 33 two-bedroom and 6 three-bedroom apartments, together with 22 carparking spaces, 50 cycle and 10 motorcycle parking spaces in basement. Ref:DC/09/72904.

2.4.9 11/03/2010 – Planning application received for the retention of the change of usefrom storage and distribution (Use Class B8) to skip storage, vehicle storage,recycling of building materials, freight distribution and clothes and mattressrecycling (Sui Generis) at land formerly occupied by the Salters Paper Groupwithin the Cannon Wharf site. Ref: DC/10/73735. Application currently underconsideration.

2.4.10 21/09/2010 – Planning application received for the demolition of existing buildingsand the erection of two buildings of 8 and 9 storeys to provide 111 residential unitsand 949 square metres of commercial floorspace (Use Classes A3, B1 and D1) at19 Yeoman Street, SE8. Ref: DC/10/75430. Under consideration. This applicationfollowed the withdrawal of two previous applications (refs: DC/08/68034 andDC/09/70848) for similar developments.

3. PRESENT APPLICATION

3.1 Format of Present Application

3.1.1 The application is for full planning permission with no matters reserved

3.2 General Layout and Uses

3.2.1 The applicant proposes the redevelopment of the site to provide five blocksranging from 3 to 8 storeys in height. Three of these buildings would be courtyardblocks which would enclose (or partially enclose) communal amenity spaces forresidents. The tallest part of the proposed development (in terms of completestoreys) would be at sub-block N1, at the north end of the site. Adjacent to this

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would be the lowest building – a single-storey freestanding pavilionaccommodating a café. The main external spaces would be the linear park (to beprovided along the route of the former Grand Surrey Canal), the 3 courtyards, andthe café and south squares.

3.2.2 A total of 532 residential units are proposed, of which 103 are currently proposedto be affordable homes (78 as an “Extra Care” facility, and 25 shared ownershipunits). A total of 236 car parking spaces, 558 cycle parking spaces and 11motorcycle parking spaces are proposed.

3.2.3 4,126 square metres (gross internal area) of commercial floorspace are included inthe proposals. This would be provided as 1,543 square metres of A1, A2 and/orA3 floorspace, 2,154 square metres of general B1 floorspace, and 429 squaremetres of B1c floorspace. In addition, ancillary uses form part of the Extra Carefacility.

3.2.4 The indicative diagram that follows shows the layout of the proposed development.The proposed blocks are grouped in northern, eastern, central, southern andperimeter zones (or blocks), and are labelled N, E, C, S and P.

(source: Grid Architects)

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3.3 Description of Proposed Buildings and Uses

Northern Zone

3.3.1 Block N1 would be located at the northern tip of the site, fronting Plough Way andstanding adjacent to the vehicular access to Iceland Wharf. It would rise to 29.83metres AOD (8 storeys), arranged as 7 storeys sitting above (and, in part of thenorth elevation, overhanging) a ground floor level plinth. Elevational relief wouldbreak the massing into 3 sections in the north elevation. Block N1 would belocated on the former route of the Grand Surrey Canal, and would terminate thelinear park.

3.3.2 A detached single-storey pavilion building, accommodating a café, would be standin front of block N1’s south elevation, within a small “café square” (referred to inthe Addendum Design and Access Statement as “The Basin”) surrounded on twosides by block N1, and on the west side by future development at the CannonWharf site. A change in levels would occur adjacent to the pavilion, with land to thewest being lower.

3.3.3 771 square metres of A1/A2/A3 floorspace, 429 square metres of B1(c)floorspace, and 77 square metres of other non-residential floorspace are proposedin the ground floor of block N1. The upper floors would accommodate 71 flats (22x1-bedroom, 31x 2-bedroom and 18x 3-bedroom), all for private sale.

3.3.4 A car park for 17 vehicles would be provided adjacent to the north elevation ofblock N1. 34 cycle parking spaces would be provided in two indoor stores. Refusestores, accessed from the car park, are proposed at ground floor level.

3.3.5 A single residential entrance on the south elevation would provide access to twocores. Roof terraces or balconies would be provided for all flats. All elevationswould have windows, although only small secondary bedroom windows areproposed to the west elevation closest to the common boundary shared with theCannon Wharf and 19 Yeoman Street sites.

3.3.6 External elevations would be of brick and metal cladding. Extensive glazing isproposed at ground floor level. The pavilion would have a copper finish roof andglazed walls.

3.3.7 No public access would be available along the space between block N1 and thewestern boundary of the application site.

3.3.8 Landscaping in the Northern Zone would mostly be hard, with some tree andshrub planting proposed around the car park and café square

Eastern Zone

3.3.9 The Eastern Zone occupies the northeast corner of the application site. Block Ehas been designed as an incomplete courtyard block, with the applicant noting thatdevelopment at the Marine Wharf East site has the potential to complete theenclosed courtyard. Sub-block E1 would front Plough Way, and sub-block E2would meet the site’s eastern boundary (an erroneous drawing on page 2 of theAddendum Design and Access Statement mixes up sub-blocks E2 and E3).

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3.3.10 Sub-block E1 would have a maximum height of 22.28 metres AOD and would riseto 4 storeys. Sub-block E2 would rise to 20.98 metres AOD (5 storeys). Sub-blockES would rise to 21.48 metres AOD (5 storeys).

3.3.11 Block E would accommodate 54 flats and 2 maisonettes (12x 1-bedroom, 32x 2-bedroom, 12x 3-bedroom).

3.3.12 Sub-blocks E2 and E3 would be entirely residential (with ancillary uses at groundfloor level), while sub-block E1 would accommodate 335 square metres ofA1/A2/A3 floorspace, 1,614 square metres of B1 floorspace, and 225 squaremetres of other non-residential floorspace.

3.3.13 The 3 sub-blocks would be connected at ground floor level with an indoor car park.Sub-block E1 would be detached from first floor level upwards. Above the groundlevel car park, a raised private communal courtyard would be provided.

3.3.14 A single communal residential entrance would be provided on the south elevationof block E, providing access to two cores. Some units would have their own privateground floor entrances. All elevations would have windows, except for the eastelevation of sub-block E1, and only secondary kitchen/living/dining roomelevations would be provided in the northeast corner of sub-block E2, facing theMarine Wharf East site. Most units would have private amenity spaces in the formof balconies or small patios at ground level.

3.3.15 Brick, in 2 contrasting colours, would be used on the external elevations, whiletimber cladding is proposed for the recessed connection between sub-blocks E2and E3. Glazed shopfronts are proposed to the ground floor elevation of sub-blockE1 facing Plough Way.

3.3.16 A living roof is proposed to sub-block E2. The courtyard of block E would belandscaped with paving, timber decking, cube seats and ornamental shrubplanting. Other landscaping in the Eastern Zone would comprise hard surfacesand shrub planting.

3.3.17 The ground floor car park would accommodate 47 car parking spaces, and 91cycle parking spaces, and 3 motorcycle parking spaces. Separate refuse storeswould be provided for the residential and commercial uses.

Central Zone

3.3.18 Block C comprises sub-blocks C1 (rising to 25.92 metres AOD and 6 storeys at itsPlough Way end and 28.96 metres and 7 storeys fronting the linear park), C2(25.13 metres AOD, 6 storeys) and C4 (29.875 metres and 7 storeys, withaccommodation at 7th floor level). There is no sub-block C3.

3.3.19 As with block E, the applicant proposes a ground floor indoor car park with aprivate communal courtyard above at block C. The vehicular entrance would be onthe block’s south elevation. Sub-blocks C1 and C4 would be detached from firstfloor level upwards, and external steps are proposed within this gap, providing aconnection between the linear park and the courtyard.

3.3.20 At ground and first floor levels, block C would accommodate 437 square metres ofA1/A2/A3 floorspace, 540 square metres of B1 floorspace, and 1,798 squaremetres of other non-residential floorspace, which includes the CHP facility in theground floor of sub-block C4. Sub-blocks C1 and C4 would accommodate an Extra

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Care facility, incorporating a 2-storey lobby accessed via the east elevation, and alaundry and scooter store at ground floor level. At first floor level, a communallounge, dining room and gym/physiotherapy suite would be provided. The 78 flatsof the Extra Care facility would be provided at ground to fifth floor levels.

3.3.21 Not including the flats of the Extra Care facility, block C would accommodate 111flats and maisonettes, comprising 35x 1-bedroom, 54x 2-bedroom and 22x 3-bedroom units. The Extra Care facility would comprise a further 29x 1-bedroomand 49x 2-bedroom units.

3.3.22 2 communal residential entrances to sub-block C1 would be provided on theblock’s north elevation, and sub-block C4’s communal entrance would be on thesouth elevation. Private amenity spaces in the form of balconies would beprovided for most flats in all 3 sub-blocks, however the ground floor Extra Careunits would not have outdoor terraces or private entrances. The courtyard of blockC would have separate allocated areas for Extra Care residents and residents ofthe private units. Patio doors and private entrances are proposed for most of theground floor units facing the linear park. Windows are proposed to all elevations.

3.3.23 External elevations would be of brick and metal cladding. A contrasting brickcolour is proposed at the base of sub-block C2. Timber cladding is proposed toparts of the ground and first floor elevations facing the linear park and for therecessed connection between sub-blocks C2 and C4. Extensive glazing isproposed at ground floor level for the commercial floorspace.

3.3.24 34 car parking spaces, 184 cycle parking spaces, and 4 motorcycle parkingspaces are proposed in the ground floor of block C. 3 refuse stores are proposedat ground floor level.

3.3.25 The courtyard of block C would be landscaped with timber decking, grass, timberbenches and hedge and shrub planting. Other landscaping in the Central Zonewould comprise hard surfaces and hedge and shrub planting.

Southern Zone

3.3.26 Block S is proposed at the south end the application site, adjacent to CarteretWay, and comprises sub-blocks S1, S2 and S3 to the north, and sub-blocks S4and S5 close to the site’s southern boundary. These sub-blocks would enclose acourtyard, to be provided above a ground floor car park. Sub-block S6 wouldextend to the southeast corner of the site.

3.3.27 Heights would vary from 27.585 metres AOD (sub-block S1, 6 storeys) to 17.895metres AOD (sub-blocks S4 and S6, 4 storeys). The top (third floor) storeys ofthese 2 shorter sub-blocks would be set back from the building edge.

3.3.28 The ground floor car park would accommodate 94 car parking spaces, 213 cycleparking spaces (some accessed via the car park, some access from the outside ofthe block) and 3 motorcycle parking spaces. 4 refuse stores are proposed.

3.3.29 Block S would be entirely in residential use. 175 flats and maisonettes would beprovided as 76x 1-bedroom, 86x 2-bedroom, and 13x 3-bedroom units. Of these,11x 1-bedroom, 8x 2-bedroom and 6x 3-bedroom units in sub-block S6 would befor shared ownership.

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3.3.30 The majority of units would have their own private amenity spaces in the form ofsmall ground level gardens, patios and terraces, and balconies on the upperfloors. Windows are proposed to all elevations. The vehicular entrance to the carpark is proposed to the north elevation of the block, communal residentialentrances are proposed to the north, east and west elevations, and external stepsare proposed between the linear park and the private courtyard at first floor level.

3.3.31 Brick and metal cladding would be used on the elevations of sub-blocks S1 and S5facing the linear park, as would timber cladding at ground and first floor level andin the recessed connections proposed between sub-blocks. A contrasting brickcolour is proposed in the lower parts of some elevations.

3.3.32 The courtyard of block S would include a large water feature, ornamental shrubplanting, and timber decking. Elsewhere within the Southern Zone but outsideblock S, grass, hard surfaces and hedge and shrub planting is proposed.

Perimeter Zone

3.3.33 The Perimeter Zone is located along the site’s eastern boundary and comprisessub-blocks P1 (flats, rising to 20.445 metres AOD, 5 storeys) and P2 (9x 3-storey4-bedroom houses, rising to 15.245 metres AOD in height). The 32 flats of sub-block P1 would be provided as 23x 1-bedroom, 6x 2-bedroom and 3x 3-bedroomunits.

3.3.34 Block P would be entirely in residential use.

3.3.35 The communal entrance to sub-block P1 would be located on the north elevation.Adjacent to this would be a store for 27 bicycles, and a refuse store.

3.3.36 Windows are proposed to all elevations. Each house in sub-block P2 would have aprivate rear garden, and balconies are proposed for most of the flats in the upperfloors of sub-block P1.

3.3.37 External materials include brick (in 2 contrasting colours), however much of sub-block P1 would be rendered.

3.3.38 No landscaping proposals for the rear gardens of the 9 houses are proposed,however hard surfacing and hedge and shrub planting are proposed around thesquare that would be surrounded by sub-blocks P1, P2 and S6, and bark mulchsafety surfacing is proposed for the playspace at the centre of the square.

3.4 Residential Accommodation

3.4.1 The proposed development would provide a total of 532 residential units, of which103 are currently proposed to be affordable homes representing 80.6% privatesale units and 19.4% affordable (14.7% social rent and 4.7% shared ownership).The social rented units would be provided within the Extra Care facility in sub-block C2, while the 25 shared ownership units would be provided in sub-block S6.

3.4.2 The unit size and tenure breakdown of the detailed and outline elements of theproposed development are summarised in the table below.

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Table 1: Detailed unit size and tenure breakdown

3.4.3 Further breakdowns of the residential accommodation (including percentages andbreakdowns based on habitable room numbers) are provided later in this report atsub-section 6.6.

3.4.4 A total of 95 wheelchair-accessible and adaptable units would be provided. Ofthese, 78 would be the Extra Care units, 3 shared ownership, and 14 private saleunits.

3.5 Non-residential uses

3.5.1 Commercial floorspace would consist of A1, A2 and/or A3 uses, general B1 uses,and B1c uses. These would be located towards the north (Plough Way) end of thesite. The Extra Care facility also includes ancillary uses.

3.6 Open Space, Playspace and Landscaping

3.6.1 The main landscaped feature and area of public open space to be provided in thedevelopment would be the linear park, to be created along the route of the GrandSurrey Canal. This would extend from the southern boundary of the site (where itmeets the grassed mounds within the grounds of the Pepys Estate northwards tomeet the proposed café square and sub-block N1. Publicly-accessible open spaceis also proposed in the southern and café squares.

3.6.2 Raised private communal podium gardens are proposed within the courtyardblocks. These areas would feature hard and soft landscaping, with a water featureproposed in the southern courtyard. Further private communal space is proposedalong the south and west elevations of block S.

3.6.3 A variety of smaller private amenity spaces are proposed. These would comprisethe small front and larger rear gardens to the houses of block P, and the privatebalconies and terraces to be provided throughout the development. Sharedsurfaces, street trees and limited on-street parking is proposed within the site.

3.6.4 A living roof (referred to as a “combined green and brown roof” by the applicant)would be provided on sub-block E2.

3.6.5 Formal play space, totalling 1,387 square metres in size, would be provided in 2locations – the linear park and the southern square. Further informal play space isalso proposed along the linear park.

1-bedroom 2-bedroom 3-bedroom 4-bedroom TOTALExtra Care(social rented)

29 49 0 0 78

Intermediate(sharedownership)

11 8 6 0 25

Private sale 157 195 68 9 429TOTAL 197 252 74 9 532

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3.7 Parking and Movement

3.7.1 215 residential car parking spaces (171 beneath the courtyards, 44 as surfaceparking) are proposed, representing a provision of 40.4%. In addition, 21commercial parking spaces (4 beneath the eastern courtyard, 17 in the car parkadjacent to sub-block N1) are proposed. Of these 236 spaces, 58 would be baysfor disabled users.

3.7.2 Most of the 11 proposed motorcycle parking spaces would be provided beneaththe 3 courtyards.

3.7.3 558 cycle parking spaces (543 for residents, 35 for the commercial uses), areproposed. Most of this would be provided in dedicated indoor stores.

3.7.4 The main vehicle access into the site would be located in approximately the samelocation as the existing access, off Plough Way. A second vehicular access intothe site – serving only the car park adjacent to sub-block N1 – would be providedoff the existing vehicular entrance to Iceland Wharf, which in turn is accessed fromPlough Way. Vehicular access would be allowed around and between all of theblocks, except for along the pedestrian street between blocks C and N, and alongthe west side of the linear park.

3.8 Servicing and Refuse

3.8.1 All servicing and refuse collection would take place within the site, via the newstreets proposed as part of the development, except in the case of the commercialfloorspace in the ground floor of sub-block N1, which would be serviced from aproposed lay-by on Plough Way. Refuse would be collected from communal storesaccommodating bins within each block, while for the 9 houses refuse would becollected via the street at the front of the terrace.

3.9 Highways Works

3.9.1 The works to the highway currently proposed are confined to Plough Way, where anew servicing lay-by, a vehicular entrance to the site, and new pavement surfacematerials are proposed. Further highway works, including pedestrian crossings atPlough Way and surface works connected to the pedestrian link at Carteret Way,are also being discussed with officers, and are considered in detail in sub-section6.6 of this report.

3.10 Temporary Arrangements

3.10.1 Appendix B (Construction Strategy) of Appendix 1 (Revised Construction andEnvironmental Management Plan) of the Environmental Statement Addendumconfirms that the site would be hoarded during construction works, with hoardingsbeing retreated as each phase is completed, to enable and ensure the safety,amenity and occupation of earlier phases whilst construction works continue onsite. No details of temporary retaining walls, landscaping or highways have beenprovided, and it is understood these are not necessary due to the location andsequence of the phases, the lack of significant changes in levels within the site,and the lack of significant earth movements in the proposed construction.

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3.11 Implementation and Phasing

3.11.1 Appendix 1 of the Environmental Statement Addendum states that construction ofthe proposed development would be carried out in 7 phases over a period of over4 years, beginning with enabling works in April 2011 and ending in December2015/January 2016. If planning permission is granted, development of Phase 1would commence at the north of the site, with sub-block N1 being built first.Construction would continue around the site, with blocks C, S, P and E being builtin that order. The table below sets out the likely time periods for each developmentphase should the scheme be approved.

Table 2: Phasing schedule

3.11.2 The planning application is accompanied by several supporting documentsincluding an Environmental Statement. Details of these are set out in the followingparagraphs.

3.12 Environmental Impact Assessment (EIA)

Introduction

3.12.1 The relevant regulations are the Town & Country Planning (Environmental ImpactAssessment) (England & Wales) Regulations 1999 (the Regulations), as amendedby the Town and Country Planning (Environmental Impact Assessment)(Amendment) Regulations 2006, and the Town and Country Planning(Environmental Impact Assessment) (Amendment) Regulations 2008. Guidanceon procedures under the Regulations was issued in DETR Circular 02/1999, andthe Government has also published a booklet entitled “Environmental ImpactAssessment: A Guide to Procedures” (November 2000).

3.12.2 Prior to submitting the current application for planning permission, the applicantconcluded (in a letter dated 22/06/2009) that EIA will be required. Nevertheless, itis necessary for the Council to consider the proposals against the Regulations andmake its own conclusion as to whether or not EIA is required.

3.12.3 The Regulations identify two types of development projects: Schedule 1developments, for which an EIA is mandatory, and Schedule 2 developments, forwhich EIA may be required. The proposed development at Marine Wharf West isnot Schedule 1 development, but is a Schedule 2 development (under paragraph10(b)), being an “urban development project” with a site area of more than 0.5hectares. Determination of whether EIA is required is then based on a judgementas to whether the proposed Schedule 2 development is likely to have significanteffects on the environment by virtue of factors such as its nature, size or location.When considering the characteristics of the proposed development regard shouldbe had in particular to the size of the development and cumulation with other

Phase Construction Start Construction End

Phase 1 July 2011 April 2013Phase 2 August 2011 August 2013Phase 3 December 2011 April 2014Phase 4 December 2012 November 2014Phase 5 June 2013 April 2015Phase 6 March 2014 July 2015Phase 7 April 2014 January 2016

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development. In relation to location, the existing use of the land should be takeninto account and also the absorption capacity of the natural environment. Circular02/1999 gives further guidance on when a Schedule 2 development requires EIAand 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; andc) for developments with unusually complex and potentially hazardous

environmental effects.

3.12.4 In the case of the proposed development at Marine Wharf West, it is consideredthat the proposed development would not have unusually complex and potentiallyhazardous environmental effects. Accordingly it is considered that criteria (c) doesnot apply.

3.12.5 With regard to criteria (b), it is noted that the site has limited environmentalsensitivity and vulnerability. It includes part of a Site of Nature ConservationImportance and is entirely within an Area of Archaeological Priority. A StrategicViewing Corridor and Strategic Wider Viewing Corridor cross the site. The sitedoes not, however, include any listed buildings, is not within (and does not abut) aconservation area, and is located a significant distance (1.9km as the crow flies)from the nearest part of the Greenwich World Heritage Site (World Heritage Sitesare included in the list of ‘sensitive areas’ provided in Regulation 2(1) of theRegulations, while paragraph 39 of Circular 02/1999 states that “other statutoryand non-statutory designations which are not included in the definition of 'sensitiveareas', but which are nonetheless environmentally sensitive, may also be relevantin determining whether EIA is required”).

3.12.6 In terms of criteria (a) Paragraph 35 of Circular 02/1999 refers to the scale ofdevelopment having ‘wide-ranging environmental effects’. Further advice on theneed for an EIA for an Urban Development Project is given at Annex A18 of theCircular – “In addition to the physical scale of such developments, particularconsideration should be given to the potential increase in traffic, emissions andnoise. EIA is unlikely to be required for the redevelopment of land unless the newdevelopment is on a significantly greater scale than the previous use, or the typesof impact are of a markedly different nature or there is a high level ofcontamination.” Given that the site is currently empty, and until recently onlyaccommodated a 2-storey industrial unit (restricted to certain delivery hours underpermission ref: 42956 dated 31/03/1999) with a single occupant, it is consideredthat the proposed development is on a significantly greater scale than the previoususe, and that the types of impact that the proposed development may cause wouldbe of a markedly different nature than those that may have been caused by thenow-dismantled industrial unit. In a letter dated 22/06/2009 at Scoping stage, theapplicant stated that the proposed development was anticipated to have potentialimpacts on matters including traffic, visual amenity, noise, air quality and ecology.Given the site’s previous industrial uses, it is possible that the site is contaminated(this has been confirmed in the applicant’s subsequent Environmental Statement).It is considered that the proposed development would be of more than localimportance in terms of its environmental impact.

3.12.7 EIA must take account of relevant “committed schemes” to ensure that it assessesthe likely significant cumulative impacts of proposed and committed schemes.Relevant “committed schemes” are normally considered to be those that haveplanning permission, however given current applications on other nearby Strategic

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Sites at Cannon Wharf (application ref: DC/08/68523), Oxestalls Road (applicationref: DC/09/73189) and Convoys Wharf (application ref: DC/02/52533) plus othermajor development sites in LB Southwark, these have been included in theassessment in accordance with Schedule 3 of the Regulations and paragraph 46of Circular 02/1999).

3.12.8 In conclusion, notwithstanding the fact that the site has already been developed inthe past and has limited environmental sensitivity and vulnerability in somerespects, given the location, mix of uses and scale of the proposed development,and its potential for cumulative impacts with other development nearby, it isconsidered that the proposals are ‘major’ and of ‘more than local importance’.Accordingly EIA is required for the proposed development.

3.12.9 In such situations where EIA is required, the Regulations require submission of anEnvironmental Statement (ES) to assess the likely significant environmentaleffects of a proposed development. Such a statement must provide an outline ofany alternative sites/schemes which have been considered and the reasons forselecting the proposed development site. In terms of the effects of the scheme itmust identify the baseline situation, the nature of the impact both direct andindirect, whether it is temporary (demolition and construction) or permanent(operation) and measures to mitigate the likely adverse impacts in each case. Itmust also identify the residual effects after assumed mitigation as well as thecumulative effects of such a scheme in relation to other committed development inthe area. An ES has been submitted by the applicant.

3.12.10 The Council cannot grant planning permission for any development which isrequired to be subject to EIA unless it has first taken the environmental informationinto consideration. The environmental information means the ES, including all ofthe ES volumes listed below, any representations made by any consultee bodiesand any representations made by any other person about the environmentaleffects of the proposed development. The ES is considered below and responsesto consultations and other representations are also considered elsewhere in thisreport.

3.12.11 The Council appointed independent consultants, Capita Symonds, to provideadvice on EIA issues and to help officers scrutinise technical material prepared bythe applicant.

EIA Scoping Opinion

3.12.12 On 19/08/2009, the Council issued an Environmental Impact Assessment ScopingOpinion (ref: DC/09/71888) for the application site. This was issued in response tothe applicant’s request (made in a letter dated 22/06/2009) for an opinion on thescope of issues and methodology that EIA for the emerging proposals shouldaddress, and followed consultation (carried out by the Council) with statutory andnon-statutory consultees. At the time, the applicant described the proposeddevelopment as having the potential to deliver approximately 600 residential unitsand approximately 3,000 square metres of commercial floorspace, however nobuilding heights or layout information was provided.

Environmental Statement Documents

3.12.13 The applicant’s ES comprises the following volumes:

• Environmental Statement Non Technical Summary (January 2010)

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• Environmental Statement Volume 1: Main Text and Figures (January 2010),setting out findings under the following headings:

1 Introduction2 EIA Methodology3 Site Description and Proposed Development4 Transport5 Noise and Vibration6 Local Air Quality7 Ecology8 Archaeology9 Ground Conditions and Contamination10 Water Quality and Resources11 Townscape and Visual12 Socio-Economics13 Waste Management14 Microclimate – Wind15 Cumulative Effects16 Residual Effects

• Environmental Statement Addendum (August 2010)• Environmental Statement Volume 2: Technical Appendices (January 2010)

3.12.14 A summary of the key findings of the applicant’s ES is set out below. The findingsof the ES are addressed in Part 7 of this report, as an integral part of consideringthe merits of the proposals.

Environmental Statement Non Technical Summary

3.12.15 This report sets out a brief summary of the findings and content of the main(January 2010) ES, but not the ES Addendum. The applicant has stated that giventhat the impacts identified in the January 2010 ES (and summarised within theNon Technical Summary) have not changed as a result of the revisions to thescheme, nor as a result of the clarification provided on various matters during thelife of the application, it is not intended to revise the Non Technical Summary.

3.12.16 The unrevised document provides a description of the site and of the pre-amendment proposals. Following a brief summary of the scoping and preparationof the ES, the document sets out 11 headings, under which the environmentaleffects of the proposed development are summarised.

Environmental Statement Volume 1: Main Text and Figures

3.12.17 This document provides further detail of the site, its context and history (includingdetails of the main characteristics of the physical, natural and built environment ofand surrounding the site), further detail of the proposed development (including itsphasing and construction), and sets out in detail the applicant’s findings in respectof the proposed development’s likely significant environmental impacts. The reportalso details the measures that the applicant proposes to adopt to avoid, reduce orcontrol any significant impacts and the main resulting (or residual) impacts.Assessment methodologies used by the applicants are explained. Each relevantenvironmental impact topic is addressed in separate chapters (numbered 4 to 15)of the ES, and are summarised (as amended) below. 2 Further chapters (relatingto cumulative effects and residual effects) complete the document.

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3.12.18 Useful glossaries of terms and acronyms used in the ES is provided in the openingpages of the main report.

Transport

3.12.19 With reference to the submitted Transport Assessment, Chapter 4 of the ES notesrelevant baseline information including traffic and accident data, and predicts whattrips would be generated by the proposed development, and assesses the impactsof these. Parking and cumulative impacts are also assessed.

3.12.20 The applicant concludes that “there are no transport effects that cannot besuccessfully mitigated”.

Noise and Vibration

3.12.21 Chapter 5 examines legislation and policy and the site’s existing baseline noiselevels. It states that the existing dominant sources of noise (that would affectoccupants of the proposed development) are traffic from surrounding roads(Plough Way and distant roads), and activities currently taking place in theadjacent Cannon Wharf site. The applicant states that given that both theapplication site and dwellings in the vicinity of the site are located away from anysignificant sources of vibration, no vibration measurements were considerednecessary. The site falls into noise exposure category (NEC) B (assuming thatcurrent noisy activities at Cannon Wharf would cease), indicating that somemitigation measures will be required for the residential element.

3.12.22 Following an assessment of noise, the applicant recommends minor mitigationmeasures to residential properties facing the edges of the site, namely sound-reducing ventilator strips for outward-facing bedroom and living room windows.Other noise mitigation measures are discussed and recommended.

3.12.23 Residual effects during the development’s operational phase are predicted to benegligible.

Local Air Quality

3.12.24 Chapter 6 of the ES examines baseline air quality at the site, identifies sensitivereceptors (namely, the members of the public who may be exposed to pollutantsfrom the site, and sensitive uses). Wind conditions and existing pollutant sourcesare identified. The pollutants NO2 and PM10 are focussed on.

3.12.25 The applicant states that, following mitigation, residual effects of constructiontraffic are likely to be short term and of minor negative significance, while residualeffects during the operational phase are predicted to be negligible for NO2 andnegligible to neutral for PM10.

Ecology

3.12.26 The assessment set out in chapter 7 of the ES has been undertaken inaccordance with the Institute of Ecology and Environmental Management (IEEM)Guidelines for Ecological Impact Assessment (2006).

3.12.27 The applicant describes the existing ecological interest of the site and surroundingarea, notes that the loss of trees at the south of the site and the developing ruderalcommunity (which are of local interest) would result in a negative effect in terms of

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biodiversity, and goes on to note that the inclusion of a living roof, landscaping andnative planting within the courtyards would result in an overall positive effect onthe site’s biodiversity.

3.12.28 With regard to the designation of part of the site as a Site of Nature ConservationInterest, the applicant notes at paragraph 7.4.19 of the ES that the designated partof the site was reportedly cleared of vegetation prior to August 2007, and that theland can therefore no longer be considered as having local value.

3.12.29 In terms of loss of habitat, the applicant concludes that, following mitigation(namely, compensatory habitat creation), the effects of the proposed developmentwould be positive. In terms of disturbance to birds, after mitigation a negligibleeffect is identified.

Archaeology

3.12.30 Chapter 8 of the ES notes designations and the proximity of the site to heritageassets.

3.12.31 The applicant notes that there is evidence from the study area for activity from theMesolithic period to the present day, but that the level of preservation within thesite is expected to be highly variable given the construction carried out at the site,which would, most likely, have had a considerable deleterious effect upon anyarchaeological deposits within 1 to 2 metres of the modern ground surface.

3.12.32 Mitigation is proposed in the form of archaeological observations integrated withinthe remediation process to allow full and safe observation of the deposits beneaththe made ground.

Ground Conditions and Contamination

3.12.33 Ground conditions and contamination is addressed in chapter 9 of the ES, wherethe historic uses, geology and hydrology of the application site are described. Thefindings of previous site investigations are examined, and contamination recordedat the site is listed. A conceptual site model is provided, and potential effects aredetailed.

3.12.34 Further investigation and assessment work is recommended by the applicant.

3.12.35 Residual effects are assessed as being negligible to moderate positive.

Water Quality and Resources

3.12.36 Chapter 10 of the ES examines legislation and policy, site conditions anddrainage. A flood risk assessment is appended to the ES.

3.12.37 At the operational phase, in terms of contamination of surface waters the proposeddevelopment is predicted to have a negligible residual effect following mitigation.In terms of potential contamination of surface waters from sewers, the proposeddevelopment is predicted to have a negligible to minor negative residual effectfollowing mitigation. In terms of alteration of the surface water drainage regime, aminor residual positive effect after mitigation is predicted. In terms of risk fromfluvial flooding, a negligible residual effect after mitigation is predicted. A minor tomoderate negative residual effect in terms of increased pressure on waterresources (due to an increase in water demand) is predicted, and a negligible to

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minor negative effect in terms of increased pressure on foul sewerageinfrastructure is predicted.

Townscape and Visual

3.12.38 Chapter 11 of the ES provides separate assessments addressing the impact of theproposed development on specific townscape character areas, and on identifiedviews. 32 views are photographed, and Verified Visually Montages have beenprepared for 16 of these.

3.12.39 The applicant’s assessment includes consideration of the protected strategic viewfrom Greenwich to St Paul’s Cathedral.

3.12.40 The applicant, in summary, states that the proposed development “will arrest thedecline of a currently neglected site, regenerating and enhancing the existingtownscape character and quality of the local environment through the delivery of ahigh quality design response to the built form and the areas of public space”.

3.12.41 2 related documents submitted separately to the ES, titled “Visually VerifiedMontages (VVMs) Methodology Statement”, and “Clarification to Townscape andVisual Impact Assessment Plans and Photographs”, provide further clarification onthe applicant’s approach to assessing impacts on protected views.

Socio-Economics

3.12.42 Chapter 12 of the ES examines the likely socio-economic effects of the proposeddevelopment.

3.12.43 A predicted population figure (for the proposed development) of 913 people(including 63 children) is provided at paragraph 12.5.20.

3.12.44 Existing facilities, population, housing, economic activity, education and skills,health, deprivation, crime and open space provision are examined in the ES. Theapplicant goes on to assess the effects of the proposed development on each ofthese matters. These effects are generally identified as being positive.

Waste Management

3.12.45 Chapter 13 of the ES explains what arisings would be generated by the proposeddevelopment during construction. Mitigation, to minimise the amount of wastegenerated, is proposed.

3.12.46 Waste generated by the proposed residential and commercial uses is similarlyassessed, and mitigation is proposed.

Microclimate – Wind

3.12.47 Computational wind testing (or Computational Fluid Dynamics, CFD) of theproposed development carried out by the applicant’s consultant is detailed inchapter 14 of the ES. The Cannon Wharf development, and its effect on wind, hasbeen taken into account in the testing.

3.12.48 The applicant states that the proposed development would have negligible effecton the local wind environment, and further states that “based on the results of thewind studies and taking into consideration the required safety and comfort

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thresholds suggested in the Lawson criteria, no mitigation is required as theproposed wind speeds fall within the recommended criteria and in some instancesalso have a likely beneficial effect”.

Cumulative Effects

3.12.49 All of the ES topics listed above are then considered together in chapter 15 of theES. The combined effects of individual impacts as well as the cumulative effects ofthe construction and operation of the proposed development together with theother committed or proposed developments have been assessed.

3.12.50 The applicant finds that the cumulative effects of the considered developmentshave the potential to be significant, but that during the construction phase will beshort to medium term in nature, with both positive and negative effects. Bothpositive and negative effects are predicted at the operational phase.

Residual Effects

3.12.51 Chapter 16 of the ES provides a summary table of the proposed development’seffects, including residual affects.

Environmental Statement Addendum (August 2010)

3.12.52 This volume and its appendices updates the ES in the light of amendments to theproposals, consultee and officer comments, and changes to legislation andguidance. Some ES chapters are replaced in full, others are supplemented withadditional text and graphical information.

Environmental Statement Volume 2: Technical Appendices

3.12.53 These appendices provide the detailed data, diagrams and other informationreferred to in the main ES report, and include a sustainability statement, a draftConstruction Environmental Management Plan, noise survey results, siteinvestigation information, a flood risk assessment, a townscape impactassessment, and a visual impact assessment. Some information in this volumewas subsequently superseded by appendices to the ES Addendum in July 2010.

3.13 Other Application Documents

Planning Statement

3.13.1 The Planning Statement describes the proposed development (pre-amendment),the site and its surroundings and the site’s history, and lists what the applicantconsiders to be the relevant national, regional and local planning policy context.Background information regarding the regeneration of the area and the SurreyWharf Masterplan prepared by Berkeley Homes is provided. The statementdiscusses relevant planning considerations and the merits of the proposeddevelopment against the identified planning policy context, drawing on the findingsof the ES and other submission documents.

3.13.2 A brochure explaining the applicant’s proposals for an Extra Care facility as part ofthe development is provided at Appendix 4 of the Planning Statement.

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3.13.3 The Planning Statement is supplemented and amended by the letter issued byIndigo Planning dated 19/08/2010 and the revised Accommodation Schedulereceived on 20/08/2010.

Design and Access Statement and Addendum Design and Access Statement

3.13.4 The initial document dated January 2010 opens with a brief chronology of recentevents, noting that the site was purchased by Berkeley Homes in 2007, that adesign competition for the site was held in June 2008, and that a further designcompetition for the masterplanning of the wider Plough Way site (which theapplicant refers to as “Surrey Wharves”) was held in January 2009. It notes thatthe first phase of Hamilton’s work involved the preparation of a masterplanframework for Surrey Wharves, and that the second involved the development ofdetailed proposals for the Marine Wharf West site. Chapter 2 provides a summaryof the Surrey Wharves masterplan, and the 5 key design issues central to thatproject are listed – these are 1) co-ordination with other development sites; 2)repair of the fractured urban fabric; 3) provision of appropriate employment uses;4) improving access to public transport and amenities; and 5) giving up privateland to remove barriers to movement. The following pages explain how themasterplan was then devised, and how – in the opinion of the applicant – itprovides a suitable framework for addressing the problems, constraints andopportunities of the Surrey Wharves area.

3.13.5 Chapter 3 goes into further detail, describing the Marine Wharf West site,development proposed in adjacent sites, access points (existing and potential),views, and above-ground features.

3.13.6 The document discusses the evolution of the design from basic principles, with thecurrent layout – based on key routes through the site intended to resolve the siteand the area’s poor permeability and connectivity – illustrated through a series ofsite plans. Access, levels, the location of sewers, and contamination were takeninto account by the architect.

3.13.7 The proposed scale, uses, detailed design, distances from neighbouringproperties, streets, servicing, landscaping, materials, sustainability and otheraspects of the development are then described in increasing detail. Sitemanagement and the influence of consultation with residents upon thedevelopment of the proposals is explained. The document ends with a study ofeach key element of the proposed development, examining its role, design andcharacter.

3.13.8 The Addendum Design and Access Statement dated August 2010 providesclarifications and an explanation of amendments made to the proposeddevelopment. The topics covered include the connection to Carteret Way, therevised treatment and location of the café at the north end of the linear park,tenure changes, changes to elevations and materials, aspect, entrances at groundlevel, disabled parking spaces, and the CHP facility.

Transport Assessment

3.13.9 The initial assessment dated January 2010 assesses the local highway network,accident data, traffic and accessibility (including public transport accessibility).Noting that the application site has a PTAL rating of 2, the applicant’s consultantargues at page 10 that, due to the methods used to calculate PTAL, the rating of 2underplays the site’s true accessibility.

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3.13.10 The assessment goes on to describe the development proposals, in particular theproposed car parking, car club provision, cycle parking, motorcycle provision,vehicular access, and servicing and refuse collection.

3.13.11 The applicant’s consultant confirms that travel plans will be prepared to encouragetravel to the site by sustainable modes of transport. A travel plan framework isappended to the assessment.

3.13.12 Other mitigation is set out on page 16.

3.13.13 Predictions of levels of trips to and from the site by all modes of transport, for eachproposed use, are made in section 6 of the assessment. Calculations are basedon the modal split for Aragon Tower. The effects of the predicted trip generation onlocal highways and public transport are discussed later in the assessment.

3.13.14 With regard to parking, the applicant’s consultant states that “there is plenty ofavailable parking capacity in the vicinity of the site area”. It is added that theproposed level of parking provision strikes the right balance betweenaccommodating the needs of residents at the site while not encouraging car use.

3.13.15 The applicant commits to preparing a Service Management Plan, and aConstruction Management Plan.

3.13.16 The Transport Assessment Addendum dated August 2010 explains what changeswere made to the proposed amounts of residential car parking, cycle parking andmotorcycle parking, and notes the provision of a pedestrian connection to CarteretWay. The applicant’s consultant states that these changes would not affect theanalysis or conclusions contained within the January 2010 Transport Assessment.

Employment Land Report

3.13.17 This report provides some background to the history and uses of the applicationsite and, together with the information set out in Appendix 4, explains how the sitewas marketed from 2004 onwards.

3.13.18 Details of available employment space in the Borough and outside Lewisham isprovided. The applicant’s consultant offers an assessment of the site, its potentialfor employment use and likely demand for the site for employment uses. The site’sconstraints are noted, as are case studies used for comparison.

3.13.19 The applicant’s consultant concludes that the site is not attractive for employmentuse, that development of the site for employment purposes is unlikely, and thatemployment benefits for local people would be maximised by the proposed misseduse development.

Landscaping Design Statement and Addendum Landscaping Design Statement

3.13.20 The initial statement dated January 2010 provides a detailed study of theapplication site and its landscape context. Regard is had to topography, land use,townscape, existing open space and other aspects. A review of national, regionaland local planning policy is provided, as are several photographs of the site.

3.13.21 Initial landscaping proposals are then worked around the layout of buildingsalready settled on by the applicant, and then explained in more detail. Proposals

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for the linear park are explained with reference to the possible continuation of thepark beyond the boundaries of the application site. A breakdown of public andprivate open space, details of playspace, and hard and soft landscaping detailsare provided. The proposed landscaping is then explained further with thebreaking down of the site into 3 different character areas – the linear park,courtyards and streets. The proposals for each character area are illustrated anddetails of materials and types of planting are provided. The proposed combinedgreen and brown roof to sub-block E2 is described. A list of tree and plant speciesis provided on page 55. Finally, tree removal and landscape management isdiscussed.

3.13.22 The Addendum Landscaping Design Statement dated August 2010 explains theamendments to the proposed development in terms of landscaping. Updatedbreakdowns of public and private open space are provided. The applicant sets outnew proposals for timber gates, stone walls and retained steel railings at the southtermination of the linear park.

Daylight and Sunlight Report and Daylight and Sunlight Report Addendum

3.13.23 The initial report dated January 2010 sets out the methodology and findings ofdaylight and sunlight tests carried out by the applicant’s consultant to assessimpacts upon neighbouring property (at Iceland Wharf, Lighter Close, Plough Wayand Carteret Way) and the proposed development at Cannon Wharf. Theassessments use the Building Research Establishment’s (BRE) Vertical SkyComponent (VSC), Average Daylight Factor (ADF) and Annual Probably SunlightHours (APSH) tests.

3.13.24 The report states that, once the Marine Wharf West development is completed,adjacent residential properties would continue to receive good levels of daylightand sunlight. two measurement points opposite the application site at 155 PloughWay would experience a reduction in daylight in excess of the maximumrecommended by the BRE, and the applicant’s consultant states that this isbecause these south-facing windows currently experience an exceptionally highlevel of daylighting, as the land opposite is currently undeveloped.

3.13.25 The applicant’s consultant states that the Cannon Wharf development would enjoygood levels of daylight and sunlight with the proposed Marine Wharf Westdevelopment in place, and that an overshadowing assessment shows that theamenity spaces at 57 to 91 would comply with BRE guidelines.

3.13.26 The applicant’s consultant states that accommodation in the proposeddevelopment would receive adequate daylight, with all living rooms expected toachieve an ADF level of 1.5% or higher and all bedrooms achieving an ADF levelof 1.0% or higher.

3.13.27 The Daylight and Sunlight Report Addendum dated August 2010 notes that theproposed development was revised, and that the current proposals would result ina good level of daylight and sunlight being maintained to existing residentialproperty. The amendments made to the internal configurations and additionalwindows would improve levels of daylighting in the proposed development.According to the applicant’s consultant, a revised overshadowing assessmentshows that the amenity spaces at 57 to 91 would still comply with BRE guidelines.

Energy Statement Report

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3.13.28 This report was fully revised in October 2010, with a new version replacing thereports dated January 2010 and August 2010.

3.13.29 This report explains how the proposed development responds to the Mayor ofLondon’s energy hierarchy, and explores options for reducing CO2 emissionsthrough energy efficiency measures, the use of heat and power generation, andrenewable technologies. In chapter 10 of the report, a number of renewabletechnologies are assessed.

3.13.30 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 Lof the Building Regulations 2006) of 13.1% through the use of energy efficientmeasures and a total of 46.0% when combined with a community heating systemwith gas-fired CHP (combined heat and power). The report states that “currentlythere is no practical on site renewable technology available that can be applied inconjunction with the above community CHP”.

3.13.31 The report confirms that all residential units will be designed and constructed tomeet the Code for Sustainable Homes (CfSH) level 3 and BREEAM ‘Very Good’.CfSH and BREEAM pre-assessments are appended to the report.

Revised Drainage Strategy Report

3.13.32 This report was fully revised in August 2010, with a new version replacing thereport dated January 2010. It outlines a strategy for drainage from the redevelopedsite. The applicant’s consultant advises that a combination of sustainable drainagesystems are used to retain and slow water entering the sewer system. Porouspaving and green roofs combined with below ground storage systems arediscussed. The applicant’s consultant states that the proposed measures wouldreduce surface water runoff to achieve a 50% reduction from the existingattenuated discharge rate.

3.13.33 The use of rainwater harvesting is committed to.

Tree Survey Report and Arboricultural Impact Assessment

3.13.34 This report assesses each tree on and immediately adjacent to the site inaccordance with BS 5837:2005. Trees are categorised using the standard A, B, Cor R categories, and of the 74 trees assessed, 7 were identified as category Btrees (being of moderate quality and value), 64 as category C (trees of low qualityand value) and 7 as category R (trees in such a condition that any existing valuewould be lost within 10 years). No trees of a high quality and value were identified.

3.13.35 The applicant proposes the retention of a London Plane at the northern tip of theapplication site, adjacent to the vehicular access to Iceland Wharf, and thecollective linear row of Birch and Ash along the eastern boundary of the site(shared with the rear gardens of houses on Carteret Way). All other trees would beremoved.

3.13.36 Mitigation for the proposed tree removal is set out briefly at page 8. Significant treeplanting is proposed, with replacement species to include Oak, Field Maple, PearRowan and Birch.

3.13.37 A drawing titled “Tree Survey and Reference Plan”, and numbered tf 740/TS/100is appended to and forms part of this report.

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Statement of Community Involvement

3.13.38 This statement describes the consultation with, and involvement of, residents ofsurrounding properties, local businesses and other stakeholders in the designprocess.

3.13.39 A series of community workshops began in June 2009, and the developmentwebsite went online in August 2009. Local traders, youth workers, Hyde Housingand Lewisham Homes and representatives of LB Southwark were included in theconsultation programme, which involved meetings, briefings, exhibitions andfurther workshops.

3.13.40 Feedback received at the community workshops is summarised in the document,as is feedback received at an exhibition of emerging ideas, held in July 2009. Moredetailed proposals were presented in an exhibition held in November 2009, andfeedback from this event is also set out in the document. Materials displayed atboth these exhibitions are reproduced in full in the document.

3.13.41 Throughout the above consultation, A5-sized invitations were distributed to localresidents, advertisement banners were displayed, and other means ofcommunication and dissemination of information were used.

4. CONSULTATION

4.1 Introduction

4.1.1 This section outlines the consultation carried out by the Council following thesubmission of the application, and summarises the consultation responses. TheCouncil’s consultation exceeded the minimum statutory requirements and thoserequired by the Council’s adopted Statement of Community Involvement.Comments made in response to the proposals are referred to, where appropriate,in Part 6 of this report and have been addressed by officers as an integral part ofconsidering the merits of the proposals. In addition, Part 7 of this report respondsto the key objections to the proposals, where these have not already beenaddressed in Part 6.

4.1.2 In addition to carrying out consultation relating specifically to the Marine WharfWest planning application, the Council distributed 8,000 copies of a letter dated01/03/2010, informing residents and businesses of the various developmentscoming forward in the north Deptford area, and to update them on the “biggerpicture”. A map of north Deptford was attached to this letter, outlining the locationand main elements of the proposals for the Plough Way, Oxestalls Road andConvoys Wharf sites. An exhibition relating to the future development of the northDeptford area was held at the Evelyn Children’s Centre on Grove Street inFebruary 2010, and a website dedicated to the subject has been maintained bythe Council throughout the consultation period.

4.2 Consultation Process

Statutory Advertisements

4.2.1 The application was advertised in the press on 03/03/2010 (giving 29 days for thesubmission of representations), as an EIA application in accordance with the EIA

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Regulations, and as a departure from the provisions of the Unitary DevelopmentPlan.

4.2.2 Following the receipt of amended drawings and additional information in August2010, a second press notice was published on 01/09/2010 (giving 21 days for thesubmission of representations).

4.2.3 Site notices were also displayed.

Local Residents and Businesses

4.2.4 An extensive mailing exercise was undertaken in relation to the application asoriginally submitted, with 2,400 letters hand-delivered to properties up toapproximately 290 metres of the site (depending upon highway layout) as shownin Appendix 2. Letters dated 01/03/2010 were delivered on and before that date,and gave people at least 31 days (up to 01/04/2010) to comment on the proposals.

4.2.5 Following the receipt of amended drawings and additional information in August2010, a second formal consultation exercise was undertaken, with a further 2,400consultation letters dated 27/08/2010 being hand-delivered to the same addresseson and before that date, giving people at least 21 days (up to 17/09/2010) tocomment on the proposals.

4.2.6 People that commented on the proposed development in response to theCouncil’s first and/or second round of consultation were invited to a local meetingheld at the Pepys 2000 Community Action Centre on 27/09/2010.

4.2.7 Copies of all application documents were published on the Council’s website.

Local Societies, Groups and Organisations

4.2.8 The following local societies and groups were consulted:

• Creekside Forum• Lewisham Cyclists• Pepys Community Forum

Statutory Agencies and Organisations

4.2.9 The following statutory agencies and organisations were consulted:

• Commission for Architecture and the Built Environment• English Heritage – Archaeology• Environment Agency• Fire Prevention Group• Government Office for London• Greater London Authority• Highways Agency• Lewisham Primary Care Trust• London Cycling Network• London Borough of Southwark• London Buses• London Fire and Emergency Planning Authority• London Transport Planning

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• London Wildlife Trust• Metropolitan Police Crime Prevention Unit• Metropolitan Police Property Services Department• National Grid• Natural England• Network Rail• Thames Water• Transport for London

Elected Representatives

4.2.10 The local MP and ward councillors were consulted.

4.3 Consultation Responses

Written Responses from Residents and Organisations

4.3.1 Written comments from were received from a total of 14 addresses of localresidents in response to the initial consultation and reconsultation. Of the writtencomments made, all but one included objections to the proposals, however lettersfrom 3 further addresses also included general support for the redevelopment ofthe estates (objections notwithstanding). 5 letters included comments ondevelopment proposals at other sites (including Oxestalls Road, Convoys Wharfand Cannon Wharf), however the comments summarised below relate only to theMarine Wharf West site, or to the wider and/or cumulative impacts that thedevelopment (including the Marine Wharf West development) may have.

4.3.2 For the purposes of this report every letter received up to the time of writing hasbeen counted, noted below and summarised in detail in Appendix 3. The writtenobjections raise the following key issues, which are placed in order of the numberof instances they are raised:

• Transport, including parking (10)• Building heights (6)• Neighbour amenity (6)• Objections to other development proposals (5)• Local facilities (5)• Support for redevelopment (4)• Design (3)• Crime and safety (2)• Density (2)• Impact during demolition and construction (2)• Landscaping (2)• Sustainability (2)• Carteret Way connection (1)• Housing provision (1)• Land use (1)• Southwark policies (1)• Environmental quality (1)

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

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Local Meeting

4.3.4 Due to the level of response, in accordance with the Council’s Statement ofCommunity Involvement a local meeting was held on 27/09/2010. All those whohad made representations (in response to either the first or second consultationexercise) were invited to the meeting, as were ward Councillors. The publicmeeting was attended by 1 local resident, and was chaired by CouncillorOnuegbu. Notes taken at the local meeting are set out in Appendix 4. Local Societies, Groups and Organisations

4.3.5 No responses received.

Statutory Agencies and Organisations

Mayor of London (GLA Stage 1 Report, 21/04/2010)

4.3.6 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 onlycomprises the provision of houses, flats, or houses and flats) which comprises orincludes the erection of a building or buildings outside Central London and with atotal floorspace of more than 15,000 square metres”), 1C (“development whichcomprises or includes the erection of a building of one or more of the followingdescriptions – the building is more than 30 metres high and is outside the City ofLondon”) and 3E (“development which does not accord with one or moreprovisions of the development plan in force in the area in which the application siteis situated; and comprises or includes the provision of more than 2,500 squaremetres of floorspace”) of the Schedule to The Town and Country Planning (Mayorof London) Order 2008.

4.3.7 The following is a summary of the key points raised by the GLA in its Stage 1report. That report was prepared based on the original application and a number ofthe comments made have been addressed in subsequent amendments to theapplication and/or supplementary information submitted by the applicant. Theextent to which these changes have addressed the GLA’s comments are coveredin Section 6 of this report.

4.3.8 In terms of the principle of mixed use development of a former industrial site theGLA notes that whilst The London Plan does not identify this site as StrategicIndustrial Land, Supplementary Planning Guidance on ‘Industrial Capacity’identifies Lewisham as a ‘limited industrial land transfer’ borough where theCouncil should take account of local variations for demand across the boroughand is encouraged to manage, and where possible, reconfigure its industrialportfolio. The Draft Core Strategy proposes the managed release of thisapplication site from its UDP designation as a Defined Employment Area forcomprehensive mixed-use redevelopment incorporating a proportion (20% of builtfloorspace) of employment provision. Noting that this strategy has been informedby an Employment Land Review for the whole borough (which has been submittedto the GLA for review) the GLA agrees with the proposed release of this site formixed-use redevelopment and therefore the principle of mixed-use development isacceptable. In conclusion the GLA advises that the Council must be satisfied thatthe proposed quantum of employment floorspace satisfactorily achieves its localpolicy requirements and that the proposed extra care home space satisfactorily

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contributes to ‘genuine employment floorspace’ as set out in the Draft CoreStrategy policy.

4.3.9 With regard to affordable housing the GLA refers to London Plan policy 3A.9(regarding borough level targets for affordable housing provision as well as theneed to encourage rather than restrain residential development and taking accountof the individual circumstances of the site including site costs, the availability ofpublic subsidy and other scheme requirements), and policy 3A.10 (requiringboroughs to seek the maximum reasonable amount of affordable housing whennegotiating on individual private residential and mix-use schemes). Noting that theapplication (as originally submitted) proposes a total of 532 units of which 78 areto affordable (social rent) Extra Care homes this equates to 14.5% affordablehousing by unit (13.5% by habitable room). This is below target levels and theproposed tenure split does not reflect London Plan policy. GLA notes that adetailed financial appraisal has been submitted to the Council to justify theproposed level of affordable housing and extra care housing. The GLA has not yetreceived this report.

4.3.10 The proposed 78 Extra Care homes provide an individual, self contained home inaccordance with London Plan policy 3A.13 (on special needs and specialisthousing) and the GLA concludes that in principle these units can contributetowards affordable housing provision. The GLA does however raise a number ofquestions about the facility such as eligibility for occupation, meeting the costs ofother services provided by the facility, public sector funding assumptions and theownership and management of the facility. It also notes that its provision as thesole affordable housing element is not in line with London Plan policy 3A.5 onhousing choice and 3A.9 and therefore additional affordable housing (open to theaffordable housing market) is required to help achieve a mixed and balancedcommunity. In addition, noting the timescales and phasing involved with thisscheme the GLA considers there may be an opportunity to examine the potentialto use a review mechanism to re-assess affordable housing contributions over thelife of the build programme.

4.3.11 In terms of the housing mix, the GLA notes that the scheme is heavily skewedtowards the provision of one and two bed units and (as originally submitted) doesnot propose any larger family affordable units (three and four beds). Thisrepresents a significant difference from the London wide strategic housing mixtarget set out in the London Plan Housing SPG and is not in line with London Planpolicy 3A.5 on Housing choice.

4.3.12 Considering the site’s location and PTAL rating of 3, the London Plan table 3A.2‘Density matrix’ indicates a suitable residential density of between 200 and 450habitable rooms per hectare, or between 45 and 170 units per hectare. Thiscompares with a residential density of 532 habitable rooms per hectare (or 188units). The GLA considers that the applicant should provide figures for theproposed total build floor space (square metres) and the total residential buildfloorspace to determine a more accurate net residential density for this schemeand is likely to result in a higher density. In this regard the GLA notes that it is notunusual for residential schemes in urban London to exceed the density guidanceset out in the London Plan however in considering whether the proposeddevelopment represents an overdevelopment of the site it is necessary to takeaccount of the type and mix of housing, the quantity of affordable housing, thequality of residential units, and other factors such as urban design and amenityspace provision. On the question of housing quality the GLA notes that whilst 36(6%) are single aspect north facing units only two of these are three bed+ units

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and is acceptable. Internal corridors within the residential buildings are minimisedand are there are generally between eight and nine units off each core which isacceptable. At the time of the Stage 1 report the GLA had not received internaldimensions of the units and was therefore unable to assess the proposed unitsagainst the unit sizes set out in the table 3.3 of the draft replacement London Plan(2009) and the Mayor’s draft housing design guide.

4.3.13 More generally in relation to the quality of the design London Plan Policy 4B.1 setsout a series of overarching design principles for development in London and otherdesign polices include specific design requirements relating to maximising thepotential of sites, the quality of new housing provision, tall and large-scalebuildings, built heritage, views, and the Blue Ribbon Network. London Planpolicies 4B.9 and 4B.10 set out specific design requirements for tall and large-scale buildings, and those relating to strategic views are applicable to theproposal. The GLA notes that an illustrative masterplan for the whole Plough Wayarea has been prepared which presents a clear hierarchy of routes, spaces andbuilt form that connects successfully with the wider area and is welcomed. TheGLA considers that the overall design approach in terms of the location ofeast/west routes across the site offers new legible routes that help break down thebulk of the previously inaccessible urban blocks and knit this site into itssurroundings. The inclusion of the north/south linear park on the alignment of theformer Grand Surrey Canal is welcomed as is the design of buildings fronting ontothis route and the location of residential space at ground level along these newroutes, increasing overlooking of the streets. However concerns are raised aboutthe limited number of units with ‘own-door’ access at ground level the connectionof the linear park to land to the south, the opportunity of linking through to CarteretWay and the elevational treatment on other key frontages.

4.3.14 The application site sits within the London View Management Framework (LVMF)protected vista 5A.2 from Greenwich to St. Paul’s Cathedral however the originalapplication did not include a detailed visual assessment as required by the LVMF.As the proposed heights are broadly comparable with existing buildings in thesurrounding area the GLA considers that in principle they do not raise anystrategic planning concerns. The perimeter courtyard block approach to buildingswith communal amenity space for residents is broadly supported although aquestion is raised regarding the size of the proposed water body in the southernresidential block and usability of the remaining amenity space for residents. Inaddition concerns are raised about the quality of the amenity space in the northerncourtyard block due to overshadowing. The overall quantum of play space isacceptable and is in line with London Plan guidance.

4.3.15 The provision of wheelchair accessible housing units meets the London Planpolicy of 10% of units however all are in the Extra Care space and the GLAproposes a mix of wheelchair accessible units across all tenure types. Theapplication proposes 25 blue badge car parking spaces, which equates to 10% oftotal car parking provision but not 10% of total number of residential units and inline with London Plan policy 3A.5 the GLA states that the applicant should provide10% of housing with blue badge car parking. The proposal that 20% of parkingspaces will be equipped with electric vehicle charging points is welcomed by TfL.

4.3.16 TfL notes the level of parking proposed but given the already congested nature ofthe highway it encourages a reduction, along with the implementation of parkingstrategies to discourage peak hour car usage. TfL also requests that a controlledparking zone (CPZ) be implemented prior to the occupation of the development,and that future residents be excluded from eligibility for a permit, in accordance

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with the London Plan policy 3C.23 ‘parking strategy’, and draft replacementLondon Plan policy 6.13 ‘parking’. The provision of cycle parking for the residentialand commercial uses in accordance with TfL’s cycle parking standards, togetherwith an additional twenty visitor parking spaces, in convenient and well lit locationsaround the estate is welcomed by TfL and recommends the provision of showeringand changing facilities for the non-residential uses to encourage cycling to the siteand a cycle lane along Plough Way, in order to further enhance cycling facilities inthe area.

4.3.17 In terms of trip generation and traffic impact TfL raises a number of questionsincluding the potential for people to make use of the high frequency bus servicespassing the site, to access both Jubilee and East London Line services at CanadaWater station with a potential impact on London Underground services and thecapacity of Canada Water station. Concern is also raised about the assumption ofan even distribution of bus trips across all routes and TfL believes that acontribution is likely to be required to mitigate the impact of the development onthe bus network.

4.3.18 TfL notes that a condition survey of all bus stops located within 400-metres of thesite has been carried out by the applicant and proposes a financial contribution toimplement required improvements. In addition improvements to footwayssurrounding the site and provision of informal crossing points on Plough Way isrecommended.

4.3.19 On Energy and Climate Change Policies 4A.2 to 4A.8 of the London Plan focus onhow to mitigate climate change, and the carbon dioxide reduction targets that arenecessary across London to achieve this. The proposals include a range ofpassive design features and demand reduction measures to reduce the carbonemissions of the proposed development 25% below the base line emissions andare considered acceptable. The application is proposing the use of four heatnetworks with the potential to connect these networks in the future and the GLArecommends that a commitment should be made to the establishment of a sitewide communal heat network supplying all the apartments and commercial units.The applicant should also seek to minimise the number of energy centres/plantrooms supplying the network and the potential to link into existing or planneddistrict heating networks in the vicinity including SELCHP. The lack of CHP isnoted although it is acknowledged that the size of the development is close to thethat below which it is difficult to achieve the conditions to ensure the successfullong term operation of CHP. External balconies will provide a reasonable level ofsolar shading to apartments below and the proposed living roofs will assist in thereduction of heat gain to apartments and houses.

4.3.20 The proposal to include a 2,200 kilowatt biomass boiler to provide heating anddomestic hot water to each group of apartment buildings and commercial areasand solar thermal hot water systems for the houses (projected to reduce overallemissions by a further 22.3%) is noted. In line with London Plan policy 4A.11 theapplication includes 430 square metres of green and brown roofs. In addition theapplicant has indicated that the scheme would include sustainable urban drainage(SUDs) techniques although further details and a commitment to which types ofsystem would be implemented is needed.

4.3.21 The application includes a detailed Flood Risk Assessment and the residual risk offlooding is low and as such the proposed application does not raise strategicplanning policy concerns.

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Commission for Architecture and the Built Environment (21/05/2010)

4.3.22 CABE reviewed the original application material and a number of the commentsbelow have been addressed in subsequent amendments to the application and/orsupplementary information submitted by the applicant. The extent to which thesechanges have addressed the CABE’s comments are covered in Section 6 of thisreport.

4.3.23 CABE supports the principle of a wider masterplan that aims to re-establish alegible street pattern and connect this site into the existing urban fabric, andconsiders the layout is generally clear and well considered. However it expressesreservations about the location and distribution of non-residential uses on the site,and the treatment of the line of the former Grand Surrey Canal as a linear parkwhich will need to be safe, well used and well maintained and managed. It isconcerned that a lack of footfall and consequent low level of natural surveillancemight make this a barrier to movement and also a closer collaboration is neededbetween the masterplanner and landscape architect to generate a convincing parkdesign and a clearer demonstration of the interrelationship of the park design andthe design and use of the buildings fronting it. Whilst acknowledging thechallenges faced in connecting this site into Carteret Way the development shouldoffer the possibility for a street connection to be made if it becomes feasible in thelonger term. It also encourages the team to raise the aspirations for sustainabilityand residential quality noting the double-loaded corridors with little potential fornatural light or ventilation, a mix of predominantly one and two bedroom flats,unambitious space standards and a high proportion of single aspect flats withoutthe compensation of increased floor to ceiling heights. It suggest that theresidential proposals are reviewed against the standards contained in the draftLondon Housing Design Guide and that proposals for the environmentalperformance of the scheme targets Code for Sustainable Homes Level 4.

4.3.24 In response the Council’s consultation on the amended proposals, in a letter dated07/10/2010 CABE welcomed the revisions. The connection to Carteret Way inparticular was welcomed, although it was noted that the connection was not yetgenerous enough or well resolved architecturally. CABE were encouraged by thechanges to the material palette, but noted that the metal panels will require highquality detailing of joints and junctions with adjacent materials.

English Heritage (Archaeology) (04/03/2010)

4.3.25 Having considered ES vol.1, section 8: archaeology English Heritage recommendsapproval subject to a condition regarding archaeological fieldwork prior tocommencement.

Environment Agency (15/04/2010)

4.3.26 The EA confirms that it is satisfied that the Sequential Test has been applied andpassed by the Council in accordance with Planning Policy Statement 25. Inrespect of land contamination the Environment Agency is aware that this site hasbeen extensively investigated and remediated however recent investigations andrisk assessment work reported in the ES show that there is still somecontamination present on site. The risk assessment indicates that the majority ofcontaminants are not likely to impact groundwater away from the site and whilst itrelies heavily on no discharge to ground the EA state that the risk assessment isacceptable and no further investigation or remediation is required. Given theresidual contamination present on site the site drainage strategy set out in the ES

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should be completed as specified with no discharge to ground at the site. The EAhas requested a copy of a Piling Risk Assessment to be completed in order toprevent contaminants in the made ground from impacting the groundwaterbeneath the site.

4.3.27 During construction and site development there is the potential for contaminants toimpact groundwater resources, accordingly works on site should be completed inline with the Construction Environmental Management Plan and with EA PollutionPrevention Guidance.

4.3.28 The EA advises that the proposed development will only be acceptable ifconditions relating to flood risk and surface water, site contamination, groundwaterand piling are imposed on any planning permission granted and asks to beconsulted on the details submitted for approval to discharge of conditions and onany subsequent amendments and alterations.

4.3.29 In a letter dated 29/09/2010, the EA stated that the amendments to the proposalsdo not affect the position set out in their letter dated 15/04/2010.

Natural England (18/03/2010)

4.3.30 Natural England states that the scheme does not significantly impact upon anypriority interest areas for Natural England, and therefore do not object to theapplication. They note that although the development site is not within a priorityinterest area for Natural England it is abutted by the Rainsborough AvenueEmbankments Site of Interest for Nature Conservation (SINC) and accordingly theCouncil will need to advise the developer of the restricted habitats within the SINCand ensure that the proposed landscaping and ecology proposals arecomplimentary. The Council should also seek to ensure that the landscaping andecological improvements are completed prior to occupation of the site.

4.3.31 In a letter dated 17/09/2010, Natural England noted that the amendments to theproposals included no changes to the ecological mitigation and enhancementmeasures attached to the development, and confirmed that Natural England hadno further comments to add.

Network Rail (10/09/2010)

4.3.32 No comment.

Highways Agency (20/09/2010)

4.3.33 The Secretary of State for Transport offers no objection.

Thames Water (09/03/2010 and 09/09/2010)

4.3.34 Thames Water raise no objection in respect of sewerage infrastructure. Withregard to surface water drainage Thames Water recommend that the applicantshould ensure that storm flows are attenuated or regulated into the receivingpublic network through on or off site storage. In addition Thames Waterrecommend that no impact piling should take place until a Piling MethodStatement (detailing the type of piling to be undertaken and the methodology bywhich such piling will be carried out, including measures to prevent and minimisethe potential for damage to subsurface water or sewerage infrastructure, and theprogramme for the works) has been submitted to and approved in writing by the

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local planning authority in consultation with the relevant water or sewerageundertaker.

4.3.35 Thames Water also recommend that petrol/oil interceptors be fitted in all carparking/washing/repair facilities and the installation of a properly maintained fattrap on all catering establishments.

Transport for London (09/03/2010)

4.3.36 TfL’s comments are included in the GLA Stage 1 Report, dated 21/04/2010 andsummarised above.

London Borough of Southwark (04/03/2010 and 15/10/2010)

4.3.37 Councillors from the Surrey Docks ward objected to the application on the groundsof the cumulative impact of the Marine Wharf West and Oxestalls Roaddevelopments upon the local road network, and the potential associated traffic andair pollution resulting from the increased trips generated. They requested that LBLewisham discuss with LB Southwark’s transport officers potential mitigationmeasures, including Section 106 contributions towards strategic roadimprovements.

4.3.38 A further objection to the proposed development was received from LB Southwarkon 15/10/2010 on four grounds. The first related to traffic, on the grounds that thedevelopment’s traffic impact on the Lower Road/Rotherhithe NewRoad/Rotherhithe Old Road gyratory had not been assessed and should be testedusing the Rotherhithe Multi-Modal Model. They go on to state that the developershould be expected to contribute appropriately to any mitigation measuresrequired, including measures on the LB Southwark road network. The objectionalso states that a lower parking provision should be proposed, that the modal splitshould not be based on census data for the ward, and that the impact on local busservices has not been properly considered.

4.3.39 The second ground relates to concern over the scale and density of the proposeddevelopment and its impact upon Southwark residents on Plough Way (theseimpacts are not specified). It is stated that the proposed buildings on Plough Waywould contrast starkly with the less dense, leafy character and form ofdevelopment anticipated in the Rotherhithe peninsular.

4.3.40 The third ground relates to the child yield from the proposed development and itsimpact upon schools in LB Southwark. They request that Section 106 educationcontributions be made available for use in Southwark if these school sites aremost local to the development.

4.3.41 Fourthly, LB Southwark note the proposed commercial floorspace, state that 1,543square metres of retail space and whilst they are of the view that this is not likelyto undermine the viability of town centres at Canada Water or Peckham, a largerquantity may affect regeneration plans for those areas. LB Southwark request thatthe extent of the retail areas be defined and limited in any permission granted.

Lewisham Design Panel

4.3.42 The Panel has considered the masterplan and application on 5 occasions, 3 atpre-application stage on 05/05/2009, 30/06/2009 and 22/09/2009, and twice duringthe life of the current application on 06/04/2010 and 21/09/2010.

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4.3.43 At the first review of the masterplan for Marine Wharf and neighbouring sites thePanel commended the methodology used to develop the masterplan which lead toa coherent urban layout in an area presently lacking any structure. It also notedthat some of the proposed building heights, particularly in the centre, may beexcessive given the relatively small size of the courtyard layouts proposed, as wellas in terms of the wider area context, that what limited historical associations thereare on the sites (such as the canal line and railway embankment) should bepositively celebrated and thought needed to be given to the levels of infrastructureand investment needed to activate the nodes, and to get people moving throughthe connecting routes.

4.3.44 At its meeting in June 2009 the Panel considered the design proposals werecarefully thought out and that the architects demonstrated the potential to resolvethe concerns identified, namely how the ‘hub’ concept would work, the needflexible employment space and for the site to compliment and reinforce thesurrounding area and a commercial strategy including measures to deal withinitial, temporarily ground floor uses; the risk of the scheme being unduly uniformand flat; the need for clarity on whether the courtyards would be treated as publicor private spaces and the implications of this in terms of privacy and separationwithout the need for fixed barriers. At its meeting in September 2009 the Panelwas of the view that whilst the scheme had strong urban structural quality thedetailed treatment and variety of the development required further consideration.The Panel was generally enthusiastic about the provision of jobs within Extra Careaccommodation, and the financial strategy for the business units. The Panel feltthat the linear park needed further work and that the reference to the canal neededto be stronger. It was noted that the scheme was dominated by a particular type ofhousing provision which risked homogeneity. The Panel also considered thebuilding at the end of the linear park to have an uncomfortable and unclearrelationship with Plough Way and the service yard spaces immediately to thenorth.

4.3.45 Following submission of the application the Panel reviewed the scheme on twooccasions. At its meeting in April 2010 the Panel noted its disappointment that theproposals had not developed much further since the earlier positive review andexpressed concern regarding access (and the lack of a route from Carteret Way),the landscape strategy (and need for a clear narrative to explain how people wouldnavigate between the external spaces), deliverability of the mixed use space, andthe quality of the residential (including the large corridors, high proportion of singleaspect flats and the type of living environment for people living in shelteredaccommodation). In respect of architectural expression the Panel considered thatto make such large elevations work, the quality of design, materials and detailingis critical whereas the simplicity of most elevations was considered to have beendumbed down rather than celebrated. The Design Panel most recently consideredthe proposed development on 21/09/2010 following submission of amendeddrawings. The Panel welcomed the new link from Carteret Way althoughconsidered that the passage should be wider as it currently has a very domesticscale. The Panel raised concern over the lack of information regarding landscapetreatment and a lack of information on the detached café at the end of the SurreyCanal linear park meant it was unclear how the building would workinternally/externally.

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Internal consultee responses

Environmental Health (09/03/2010 and 10/05/2010)

4.3.46 With regard to chapter 5 (noise and vibration) of the ES, the methodology of thenoise and vibration assessment is satisfactory as the potential impact ofconstruction noise and vibration on sensitive receptors and the potential impact ofnoise on future occupants has been assessed. The report also identified the use ofthe unauthorised skip business on an adjacent site that is likely to have anadverse impact on the future occupants. Conditions are recommended regardingventilation from A3 uses, sound insulation between commercial and residential,protection against road noise, and noise from fixed plant.

4.3.47 With regard to site contamination, whilst it would appear that the contaminativehistory of the site and the extent of contamination may have already beendetermined from the previous intrusive investigations, additional site investigationsand risk assessment may be required in order to fully assess the risk to humanhealth. Any such investigations should be designed on the final scheme to fullydelineate the extent of the contamination encountered, and to derive a remedialstrategy for the various phases of the development. However, it should beappreciated that this will also necessitate "zoning" in specific areas within thephases where known contaminative processes or areas of extensivecontamination have been/ will be determined. Although in general terms possibleremedial options may have been proposed, these and other specific remedialmeasures may need to be tailored to the contaminative characterisationrequirements and the proposed layout plans of each phase.

4.3.48 Consequently in context of the above, Environmental Health would advocate thatthe contamination condition will be specific to each phase.

4.3.49 Although the ES may have considered the mitigation of potential nuisance dusts,the developer will need to submit a detailed method statement to the satisfactionof the Council, setting out the specific mitigation measures that will be taken inorder to protect nearby residents in proximity to the proposed works.

4.3.50 The ES has not made any reference to potential ordnance issues and thenecessity for a comprehensive survey.

Highways and Transportation (12/10/2010)

4.3.51 The proposed site layout is acceptable. It would improve the permeability andconnectivity of the site for pedestrians and cyclists, subject to the public havingright of way across the site.

4.3.52 The level of off-street car parking provision complies with Lewisham’s UDPparking standards and is considered acceptable subject to:-

• The provision of a car club (and guaranteed financial viability for aminimum of 2 years from final completion).

• Section 106 contribution towards consultation and implementation of aControlled Parking Zone (CPZ) in the vicinity of the site.

• The provision of a parking management plan. The plan should providedetails of measures to prevent parked vehicles from obstructing thevehicle route through the site. The plan should also include details

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relating to the allocation of parking spaces within the site and include thelocation of electric vehicle charging points.

4.3.53 The proposed development will generate additional walking and cycle trips to andfrom the site, therefore a financial contribution is required towards improving cycleand pedestrian routes within the vicinity of the site.

4.3.54 A waste management plan is required. The plan should include details of refuseand re-cycling collection points. The plan should illustrate how bins will be broughtout to collection points on collection days and returned.

4.3.55 A construction and logistics plan is required. It should be submitted prior to thecommencement of work on site and should specify how the impacts ofconstruction activities and associated traffic will be managed..

4.3.56 A delivery and servicing plan is required. The plan should rationalise the numberand time of delivery and servicing trips to the development, with the aim ofreducing the impact of servicing activity.

4.3.57 The implementation of the draft travel plan is required to encourage the use ofmore sustainable forms of transport and a financial contribution towardsmonitoring the travel plan, to ensure the travel plan is taken forward and delivered.

4.3.58 A Grampian condition is required, requiring the applicant to enter into a Section278 (of the 1980 Highways Act) agreement with the highway authority to securehighway reinstatement and improvement works adjacent to the site. the Section278 works shall include:-

• Waiting restrictions on Plough Way• An informal pedestrian crossing on Plough Way• Relocation of the bus stops on Plough Way.• Modification of the traffic calming on Plough Way.• reinstatement/improvement works to footways on Plough Way.

Ecological Regeneration Manager (01/10/2010 and 05/10/2010)

4.3.59 Queried why all roof treatments are not living roofs. The site is within an area ofdeficiency in terms of access to nature, and is a key riverside location that has thepotential to support a large quantum of substrate-based roofs. Living roofs do nothave to cost significantly more to construct than a standard roof if part of thedesign concept. Living roofs offer benefits relating to ecology, flood risk,sustainable urban drainage, the urban heat island effect, building and roofmembrane longevity, thermal insulation and energy efficiency.

Sustainability Officer (11/03/2010)

4.3.60 In the absence of engagement with SELCHP and the given the possibility of adecentralised energy (DE) network the proposed development is unacceptable.The Mayor of London's energy hierarchy and the draft London Plan highlight theimportance of DE networks, so excluding this as a viable opportunity is notconsidered to be acceptable. It is considered that the current application does notmaximise the opportunities within the area for CO2 reductions.

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Strategic Housing (28/04/2010)

4.3.61 Affordable housing provision is insufficient. General needs rent and/orintermediate housing should be provided. Not clear if wheelchair units have beendesigned to SELHP standards, which require 2 lifts. Code for Sustainable Homeslevel of at least 4 is expected. Each wheelchair unit should have a disabledparking space. Financial viability appraisal is needed.

5. PLANNING POLICIES AND GUIDANCE

5.1 Introduction

5.1.1 In considering and determining applications for planning permission the localplanning authority must "have regard to the provisions of the development plan, sofar 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 thePlanning and Compulsory Purchase Act (2004) makes it clear that thedetermination of planning applications must be made in accordance with thedevelopment plan unless material considerations indicate otherwise. Thisapproach is reflected in PPS 1, where, at paragraph 8 (and again at paragraphs28 and 31), it is confirmed that, where the development plan contains relevantpolicies, applications for planning permission should be determined in line with theplan, unless material considerations indicate otherwise. The development plan forLewisham comprises the saved policies in the adopted Lewisham UDP (July 2004)and policies in the London Plan (2004, consolidated with alterations 2008).

5.1.2 The UDP is in the process of being replaced by Development Plan Documents(DPDs) and Supplementary Planning Documents (SPDs) that will comprise theBorough’s Local Development Framework. On 19/02/2010 the Council publishedits proposed submission version of the Core Strategy (referred to in this report asthe “Draft Core Strategy”). This is the principal DPD and, once adopted, willreplace many of the saved policies in the current UDP. Whilst it will not form partof the Development Plan for the Borough until it is formally adopted, Governmentadvice on the weight to be attached to emerging DPD policies is that this isdetermined by the stage of preparation or review, increasing as successive stagesare reached. Although yet to be the subject of an Independent Examination inPublic (currently programmed for January 2011) the Core Strategy (ProposedSubmission Version) including the evidence base that supports the policies hasbeen the subject of public consultation. The Mayor of London has reviewedLewisham’s Draft Core Strategy and has agreed with the proposed release ofcertain sites (that were previously Defined Employment Areas), including thePlough Way site, for mixed use development. This is confirmed in the GLA Stage1 Report on the current application dated 21/04/2010. Emerging LDF policy istherefore a material consideration in the determination of this application althoughit cannot be afforded as much weight as development plan policies.

5.1.3 The draft replacement London Plan is also a material consideration in this case.

5.2 Planning Policy Guidance and Planning Policy Statements

5.2.1 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)

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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

5.2.2 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)

5.3 London Plan

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

5.3.2 The Overall Strategy2A.1 Sustainability criteria2A.5 Opportunity Areas2A.7 Areas for Regeneration2A.10 Strategic Industrial Locations

5.3.3 Living in London3A.2 Borough housing targets3A.3 Maximising the potential of sites3A.5 Housing choice3A.6 Quality of new housing provision3A.7 Large residential developments3A.8 Definition of affordable housing3A.9 Affordable housing targets3A.10 Negotiating affordable housing in individual private residential and mixed-use schemes

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3A.17 Addressing the needs of London’s diverse population3A.18 Protection and enhancement of social infrastructure and community facilities3A.21 Locations for health care3A.23 Health impacts3A.24 Education facilities3A.28 Social and economic impact assessments

5.3.4 Working in London3B.1 Developing London’s economy3B.2 Office demand and supply3B.4 Industrial Locations3B.5 Supporting innovation3B.8 Creative industries3B.11 Improving employment opportunities for Londoners

5.3.5 Connecting London – improving travel in London3C.1 Integrating transport and development3C.2 Matching development to transport capacity3C.17 Tackling congestion and reducing traffic3C.18 Allocation of street space3C.20 Improving conditions for buses3C.21 Improving conditions for walking3C.22 Improving conditions for cycling3C.23 Parking strategy

5.3.6 Enjoying London3D.1 Supporting town centres3D.8 Realising the value of open space and green infrastructure3D.13 Children and young people’s play and informal recreation strategies3D.14 Biodiversity and nature conservation3D.15 Trees and woodland

5.3.7 Climate change and London’s metabolism4A.1 Tackling climate change4A.2 Mitigating climate change4A.3 Sustainable design and construction4A.4 Energy assessment4A.5 Provision of heating and cooling networks4A.6 Decentralised Energy: Heating, Cooling and Power4A.7 Renewable energy4A.9 Adaptation to Climate Change4A.10 Overheating4A.11 Living Roofs and Walls4A.13 Flood risk management4A.14 Sustainable drainage4A.16 Water supplies and resources4A.19 Improving air quality4A.20 Reducing noise and enhancing soundscapes4A.21 Waste strategic policy and targets

5.3.8 Designs on London4B.1 Design principles for a compact city4B.2 Promoting world-class architecture and design4B.3 Enhancing the quality of the public realm4B.5 Creating an inclusive environment

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4B.6 Safety, security and fire prevention and protection4B.10 Large-scale buildings – design and impact4B.11 London’s built heritage4B.13 Historic conservation-led regeneration4B.14 World Heritage Sites4B.15 Archaeology4B.16 London View Management Framework4B.18 Assessing development impact on designated views

5.3.9 Blue Ribbon Network4C.4 Natural landscape4C.20 Development adjacent to canals4C.21 New canals and canal restoration4C.23 Docks

5.3.10 The sub-regions5D.1 The strategic priorities for South East London

5.3.11 Implementing the London Plan6A.4 Priorities in planning obligations6A.5 Planning obligations

5.3.12 The Mayor of London published a draft replacement London Plan for consultationin October 2009. The consultation draft was open for public comment until12/01/2010. An Examination in Public, led by an independent panel, is takingplace throughout the summer and autumn of 2010. Following the Examination inPublic, the panel will report to the Mayor of London recommending changes to thedraft London Plan. The Mayor of London will then prepare a final version forapproval or further amendment by the Secretary State. The new London Plan isexpected to be published in late 2011. Given that the draft replacement LondonPlan has been the subject of an Examination in Public it should be affordedgreater weight than Lewisham’s Draft Core Strategy.

5.3.13 Relevant emerging policies – which are referred to in this report where appropriate- are considered to be:

5.3.14 Context and Strategy1.1 Delivering the strategic vision and objectives for London

5.3.15 London’s Places2.3 Growth Areas and Co-ordination Corridors2.13 Opportunity Areas and Intensification Areas2.14 Areas for Regeneration2.15 Town Centres

5.3.16 People3.1Ensuring equal life chances for all3.2Addressing health inequalities3.3Increasing housing supply3.4Optimising housing potential3.5Quality and design of housing developments3.6Children and young people’s play and informal recreation facilities3.7Large residential developments3.8Housing choice3.10 Mixed and balanced communities

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3.11 Definition of affordable housing3.12 Affordable housing targets3.13 Negotiating affordable housing on individual private residential and mixed useschemes3.14 Affordable housing thresholds3.17 Protection and enhancement of social infrastructure3.18 Healthcare facilities3.19 Education facilities

5.3.17 Economy4.1 Developing London’s economy4.2 Offices4.3 Mixed use development and offices4.4 Managing industrial land and premises4.7 Retail and town centre development4.12 Improving opportunities for all

5.3.18 Climate Change5.1 Climate change mitigation5.2 Minimising carbon dioxide emissions5.3 Sustainable design and construction5.5 Decentralised energy networks5.6 Decentralised energy in development proposals5.7 Renewable energy5.9 Overheating and cooling5.10 Urban greening5.11 Green roofs and development site environs5.12 Flood risk management5.13 Sustainable drainage5.14 Water quality and sewerage infrastructure5.15 Water use and supplies5.16 Waste self-sufficiency5.18 Construction, excavation and demolition waste5.20 Aggregates5.21 Contaminated land

5.3.19 Transport6.3 Assessing transport capacity6.4 Enhancing London’s transport connectivity6.9 Cycling6.10 Walking6.11 Smoothing traffic flow and tackling congestion6.12 Road network capacity6.13 Parking

5.3.20 Living Places and Spaces7.1 Building London’s neighbourhoods and communities7.2 An inclusive environment7.3 Secured by design7.4 Local character7.5 Public realm7.6 Architecture7.7 Location and design of tall and large buildings7.8 Heritage assets and archaeology7.10 World Heritage Sites

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7.11 London View Management Framework7.12 Implementing the London View Management Framework7.13 Safety, security and resilience to emergency7.14 Improving air quality7.15 Reducing noise and enhancing soundscapes7.18 Protecting local natural space and addressing local deficiency7.19 Biodiversity and access to nature7.21 Trees and woodlands7.27 Blue Ribbon Network: supporting infrastructure and recreational use7.30 London’s canals and other rivers and waterspaces

5.3.21 Monitor and Review8.2 Planning obligations8.3 Community infrastructure levy

5.3.22 The Mayor of London has also published a number of strategies, SupplementaryPlanning Guidance (SPG) and Best Practice Guidance (BPG) notes in order tohelp implement London Plan policies. The following strategies, SPGs and BPGsare 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)• Housing SPG (2005) and draft revised interim Housing SPG (2009)• Sustainable Design and Construction SPG (2006)• London View Management Framework Revised SPG (2010)• 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)

5.3.23 The South East London Housing Partnership's Wheelchair Homes DesignGuidelines (August 2009) are not published by the Mayor of London and do notset out planning policy, but are nonetheless considered relevant to this application.

5.4 Adopted Unitary Development Plan

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

5.4.2 Urban Design And Conservation

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STR.URB 1 and STR.URB 4URB 1 Development Sites and Key Development SitesURB 3 Urban DesignURB 4 Designing out CrimeURB 8 ShopfrontsURB 12 Landscape and DevelopmentURB 13 TreesURB 14 Street Furniture and PavingURB 21 ArchaeologyURB 22 Important Local Views and LandmarksURB 24 Thames Policy AreaURB 29 Art in Public Places

5.4.3 Open SpaceSTR.OS 1, STR.OS 2 and STR.OS3OS 7 Other Open SpaceOS 8 Areas of Public Open Space DeficiencyOS 10 Trees in Open SpaceOS 12 Nature Conservation on Designated SitesOS 13 Nature ConservationOS 17 Protected Species

5.4.4 Environmental ProtectionSTR.ENV PRO 1 and STR.ENV PRO 3ENV.PRO 10 Contaminated LandENV PRO 11 Noise Generating DevelopmentENV.PRO 12 Light Generating DevelopmentENV.PRO 13 AggregatesENV PRO 15 Sustainable Surface Water Drainage in New DevelopmentENV PRO 17 Management of the Water Supply

5.4.5 HousingSTR.HSG 3HSG 2 Housing on Previously Developed LandHSG 4 Residential AmenityHSG 5 Layout and Design of New Residential DevelopmentHSG 6 Dwelling MixHSG 7 GardensHSG 14 Provision of Affordable HousingHSG 15 Creating Viable and Balanced CommunitiesHSG 22 Consultation on Housing Developments

5.4.6 Sustainable Transport and ParkingSTR.TRN 1, STR.TRN 3 and STR.TRN 4TRN 1 Location of DevelopmentTRN 2 Travel Impact StatementsTRN 3 Developer ContributionsTRN 4 Access for Public TransportTRN 5 Green Travel PlansTRN 6 Employment AreasTRN 8 Use of River ThamesTRN 10 Protection and Improvement of Public TransportTRN 14 Cycle Parking (and related Table TRN2)TRN 15 Provision for Cyclists and WalkersTRN 16 Developing Pedestrian and Cycle Networks

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TRN 20 Improving Road SafetyTRN 22 Home ZonesTRN 23 Car Free Residential DevelopmentTRN 25 Controlled Parking ZonesTRN 26 Car Parking Standards (and related Table TRN1)TRN 28 Motorcycle Parking

5.4.7 EmploymentSTR.EMP 1 and STR.EMP 3EMP 1 Land and Premises for Employment PurposesEMP 2 Promotion and Retention of Creative IndustriesEMP 3 Defined Employment AreasEMP 6 New Office Development

5.4.8 Shopping And Town CentresSTC 1 The Shopping HierarchySTC 2 Location of New Stores (Sequential Test)STC 9 Restaurants, A3 Uses and Take Away Hot Food ShopsSTC 12 Mixed Use Development

5.4.9 Leisure, Community Facilities And EducationSTR.LCE 1 and STR.LCE 2LCE 1 Location of New and Improved Leisure, Community and Education FacilitiesLCE 4 Places for Children to PlayLCE 5 Day Nursery and Child Care Facilities

5.4.10 Implementation, Resources And MonitoringSTR.IRM 2 and STR.IRM 3IRM 2 ImplementationIRM 3 Community Benefit and Planning LossIRM 4 Consultation

5.4.11 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 (the part of the site that includes the

former route of the Grand Surrey Canal);• 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 (cross the

site).

5.4.12 In August 2006 the Council adopted the Residential Standards SupplementaryPlanning Document. This document sets out guidance and standards relating todesign, sustainable development, renewable energy, flood risk, sustainabledrainage, dwelling mix, density, layout, neighbour amenity, the amenities of thefuture occupants of developments, backland development, safety and security,refuse, affordable housing, self containment, noise and room positioning, roomand dwelling sizes, storage, recycling facilities and bin storage, noise insulation,parking, cycle parking and storage, gardens and amenity space, landscaping, playspace, Lifetime Homes and accessibility and materials.

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5.4.13 Lewisham’s Housing Market Assessment 2007-8 (2009) and the LewishamLeisure and Open Space Study Final Report (2010) are also considered relevantto this application as they provide the evidence base for the Local DevelopmentFramework.

5.5 Local Development Framework

5.5.1 The Draft 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 to6). Emerging Policy SSA5 identifies a Strategic Site at Plough Way and sets outspecific requirements for mixed-use development. This and other policies ofrelevance to this application are:

5.5.2 Spatial PoliciesSP1 – Lewisham Spatial StrategySP2 – Regeneration and Growth Areas

5.5.3 Cross Cutting PoliciesCS1 – Housing provision, mix and affordabilityCS3 – Strategic Industrial Locations and Local Employment LocationsCS4 – Mixed Use Employment LocationsCS5 – Other employment locationsCS6 – Retail hierarchy and location of retail developmentCS7 – Climate change and adapting to the effectsCS8 – Sustainable design and construction and energy efficiencyCS9 – Improving local air qualityCS10 – Managing and mitigating the risk of floodingCS11 – River and waterways networkCS12 – Open space and environmental assetsCS13 – Addressing Lewisham’s waste management requirementsCS14 – Sustainable movement and transportCS15 – High quality design for LewishamCS16 – Conservation areas, heritage assets and the historic environmentCS17 – The protected vistas, the London panorama and local views, landmarksand panoramasCS19 – Provision and maintenance of community and recreational facilitiesCS20 Delivering educational achievements, healthcare provision and promotinghealthy lifestylesCS 21 – Planning obligations

5.5.4 Strategic Site Allocation PoliciesSSA1 – Requirements for strategic site allocationsSSA5 – Plough Way

5.5.5 In order to support the Draft Core Strategy the Council is working closely withother local partners to prepare and implement an Infrastructure Delivery Plan(IDP), relating to physical, social and green infrastructure in Deptford and NewCross. The IDP is overseen by the Sustainable Development Partnership (one ofthe thematic partnerships that reports to the Local Strategic Partnership Board)and is being driven forward by Lewisham’s Asset Management Board (comprisingsenior officers from the Council and local partners – including the Primary CareTrust and Hospital Trust).

5.5.6 As noted in 5.1.2 above the Council has published its proposed submissionversion of the Core Strategy which, once adopted, will form part of the statutory

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development plan for the borough. Policies in the Draft Core Strategy are amaterial consideration in the determination of this application. The policies andbackground evidence have been the subject of consultation, and the overallstrategy of release of certain employment sites including the Plough Way site formixed use development has been accepted by The Mayor of London following hisreview of the Draft Core Strategy. In the circumstances Members are advised thatthe two Draft Core Strategy policies that relate specifically to the Plough Way site(SSA1 and SSA5) are important in setting the context within which the currentplanning application is assessed and determined. However as emerging policy,strict compliance with (or reasoned justification for an exception from) thesepolicies is less critical at this particular time, and general compliance with them isacceptable.

6. PLANNING CONSIDERATIONS

6.1 Introduction

6.1.1 As noted above, determination of planning applications must be made inaccordance with the development plan unless material considerations indicateotherwise. The development plan in this case comprises the saved policies in theadopted Lewisham UDP (July 2004) and policies in the London Plan (2004,consolidated with alterations 2008). The UDP is however in the process of beingreplaced by Development Plan Documents, including a Core Strategy andSupplementary Planning Documents that will comprise the borough’s LocalDevelopment Framework. On 19/02/2010 the Council published its proposedsubmission version of the Core Strategy (referred to in this report as the DraftCore Strategy). Once adopted the Core Strategy will become the relevantdevelopment plan however in the meantime the Draft Core Strategy (including theevidence base that supports the policies) has been the subject of publicconsultation, including a formal response from the GLA, and is a materialconsideration in the determination of this application. The draft replacementLondon Plan, which has recently been the subject of an Examination in Public, isalso a material consideration in this case.

6.1.2 The key planning considerations relevant to the proposed development areconsidered 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

6.1.3 Each of the topics is assessed below in relation to policies set out in thedevelopment plan and other material considerations together with the informationset out in the Environmental Statement. The following discussion refers to theproposed development as amended by the drawings and documents (including theES Addendum) submitted in August 2010 and supplemented by correspondencereceived from the applicant since the application was submitted.

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6.1.4 Environmental impacts and mitigation are addressed in the applicant’s ES areassessed at Part 7 of this report. Financial viability and delivery is also consideredseparately at Part 8.

6.2 Principle of Development

Introduction

6.2.1 The application site is located within an area identified in the adopted UDP asDefined Employment Land. This designation, the Plough Way DefinedEmployment Area (DEA), also includes Cannon Wharf, Marine Wharf East, 7-17Yeoman Street, 19 Yeoman Street, Thames Water’s Earl Pumping Station andland between Yeoman Street and Croft Street. Saved UDP policy EMP 3 (seebelow) identifies the uses the Council would normally consider appropriate for landwithin DEAs. It also sets out the criteria against which proposals for other uses willbe assessed. In this case it is considered that the first step in determining theacceptability of the application is whether the criteria set out in EMP 3 have beenadequately addressed as they relate to the application site and whether theevidence submitted justifies the release of this site for mixed use development. Inthe light of the conclusion from that assessment other policy considerations canthen be addressed.

6.2.2 The boundaries of the Plough Way DEA in the UDP coincide with the Plough WayStrategic Site designation in the Draft Core Strategy. As noted, the Draft CoreStrategy is a material consideration in the determination of this application and ofparticular relevance is Strategic Site Allocation 1 (SSA1). This sets out a numberof requirements relating to how proposals for the identified strategic sites,including Plough Way (of which Marine Wharf West forms part) should comeforward. Strategic Site Allocation 5 (SSA5) provides more detailed guidance inrespect of the Plough Way site itself.

Saved UDP Policy

6.2.3 The application site comprises land previously in industrial use and no part of thesite is, or has recently been, in residential use. Saved UDP policy EMP 1 (Landand Premises for Employment Purposes) states that:

“The Council will aim to ensure a satisfactory supply of land and premises foremployment uses, by protecting where appropriate those existing sites andbuildings which it considers to be particularly suitable and by providing oridentifying additional sites for new development in suitable locations, including,where appropriate, Town Centres.”

6.2.4 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 planningpermission for other uses within the Defined Employment Areas shown on theProposals Map.”

6.2.5 EMP3 goes on to identify the matters that will be taken into account whenconsidering exceptions to this Policy. These are set out in the next paragraph.

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6.2.6 Section 7 of the submitted Planning Statement sets out the applicant’sassessment of the Marine Wharf West site as it relates to the matters that will betaken into account when considering exceptions to policy EMP 3. Officers havereviewed this evidence and other material such as the Council’s Employment LandSurvey (Roger Tym and Partners, November 2008) and comment as follows:

a) Other appropriate employment generating uses, especially those supportiveof the business/industrial function of the area which do not conflict with theother policies in this Plan

The application includes a proportion of employment generating floorspacefor a mix of B1, A1, A2, A3 purposes plus there will be employment within theExtra Care facility. Officers consider that the B1 space is supportive of thebusiness/industrial function of the area and that the A Class uses and ExtraCare employment would not conflict with other policies in the UDP.

The site is currently vacant (and cleared of buildings) and so realisticallycould only be used for open storage unless redeveloped for industrialpurposes. In terms of complete redevelopment for commercial use, officersaccept that on the basis of the financial information submitted with theapplication there is little prospect that Marine Wharf West would beredeveloped solely for commercial purposes unless some form of subsidywere available. Even so, if used solely for open storage or redeveloped forindustrial purposes only officers consider that given the size of the site (withaccess only via Plough Way) issues of impact on nearby residentialproperties which had constrained previous operations on the site wouldremain.

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

The applicant estimates that 264 to 270 full-time equivalent jobs would beaccommodated on site if the 4,126 square metres of commercial floorspacethat has been applied for was fully occupied. This compares with 133 full-timestaff who were employed by Jet Stationery as at October 2007 (page 9 of theapplicant’s Employment Land Report). Although the applicant has notcalculated the number of jobs that could be created if the entire site wasredeveloped for employment uses, officers accept that the proposeddevelopment would result in an increase in jobs on the site when comparedwith the last recorded employment numbers. Given the overall financialviability of the scheme officers consider that the number and mix of jobs thatwould be provided on site is acceptable.

c) The length of time the site has been vacant, and demonstration by anyapplicant that the site has been actively and appropriately marketed forbusiness/industrial reuse or redevelopment

Appendix 4 of the applicant’s Employment Land Report provides a marketingreport prepared by CBRE and Kalmars Commercial. It states that “reactivemarketing” (where potential occupants known to be seeking such a propertyare referred to this particular site) of the now-dismantled building wasundertaken by the previous owners from 2004, and that active marketingbegan in March 2007. The active marketing involved the targeting of largecompanies involved in industrial processes and warehousing, the preparationof marketing brochures, the placing of an advertisement in Property Week inFebruary 2008 and subsequent advertisement in the Estates Gazette, mass

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mailing exercises, details of the property being forwarded to activecommercial agents, the display of 3 marketing boards at the site, and internetadvertisements. The property was offered as a short-term and long-term let,or for sale. The building was marketed as a single standalone unit of 12,252square metres on the grounds that it was not considered suitable forsubdivision. Following the dismantling of the building on the site by the newowners (the current applicant) in 2008 the site was offered on an “AllEnquiries” basis.

The site has been vacant for 3 years and officers consider that sufficientevidence has been submitted that demonstrates the site has been activelyand appropriately marketed for re-use or redevelopment for employmentpurposes, that interest was low and that it did not lead to a successful sale orletting for industrial purposes.

d) Any provision within an approved planning brief

There is currently no planning brief applicable to the site. Emerging LDFpolicy is discussed elsewhere in this report.

e) Possible conversion to modern business or industrial use

The now-dismantled building on the site comprised two double height pitchedroof ‘sheds’ with two storey ancillary offices. During the early marketingstages the then-owners concluded that the bespoke warehouse building didnot lend itself to subdivision. An inspection of the buildings by officers prior todemolition noted that it was in a reasonable condition however in the absenceof a single user for the entire building its structure meant that conversion ofthe main part of the building to provide a number of smaller business unitswas likely to have required significant alteration including the installation offalse ceilings and/or mezzanine floors and partitioning. Even with thisadaption the building was unlikely to have provided modern business space.

Another constraint to conversion and re-use of the former building and sitecited by the applicant is that the planning permission for the previous buildingincluded a condition that restricted hours of deliveries to the site. Anapplication to vary this condition to allow one delivery per day outside theprescribed times by a specified company was granted on a temporary oneyear basis and subsequently renewed for a further year (see PlanningHistory, above). Officers consider that the scope for further relaxation of thecondition is limited due to the site’s location and proximity of sensitivereceptors such as housing. These restrictions are described by the applicant’sadvisers as being of “extreme detriment to the marketability of the Unit”.Given the proximity of existing residential properties to the site officers acceptthat such a restriction makes the site less attractive for modern large scaleindustrial/warehouse operations similar to that previously on the site.

f) Significant local and regeneration objectives

The proposed development includes 4,126 square metres (gross internalarea) of commercial floorspace, to be provided as 2,154 square metres of B1floorspace, 429 square metres of B1c space and 1,543 square metres of A1,A2 and/or A3 floorspace. Whilst this is significantly less than the 12,252square metres previously provided in the now-dismantled Jet Stationerybuilding officers consider that the new commercial space would be more

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suited to current and local needs for employment floorspace. In additiongiven the size and nature of the space proposed in the current planningapplication officers consider the uses are likely to be more compatible withadjacent residential uses than the previous use of the site which had givenrise to complaints from residents.

London Plan policies listed above encourage the provision of housing and sethousing targets for boroughs. To this end, the London Plan suggests thatsurplus industrial or commercial land be used for residential or mixed usedevelopment. Although these policies do not necessarily override otherpolicies relating to employment in the London Plan, they are a materialconsideration. The role of the redeveloped site in relation to the Council’swider objectives and strategy for north Deptford is discussed elsewhere in thisreport.

The proposed development includes landscaping of the route of the formerGrand Surrey Canal providing pedestrian connections north and south fromthe site. This forms a key part of the Council’s North Lewisham Links Strategyand together with the mixed use development of the site and potential toconnect into adjacent sites, the proposals will contribute to local regenerationobjectives.

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

The submitted Employment Land Report identifies a range of vacant industrialand warehouse floorspace within north Deptford and nearby parts of LBSouthwark and LB Greenwich, suggesting that the range of availableemployment sites would not be significantly reduced or harmed by the mixeduse development of the Marine Wharf Site. Indeed, as the proposedcommercial floorspace has the potential to be of a much higher quality thanthe employment space that currently exists at the cleared site, and would bedivided into smaller more flexible units it is considered that the range andquality of available employment floorspace would be enhanced, rather thannegatively impacted.

Saved UDP policy EMP 2 states that the Council will seek to promote thedevelopment of new premises for the creative industries and officers considerthat the proposed new business floorspace would match the space needs of awide 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 inthe Council’s Employment Land Survey carried out in 2008. This noted thatthe DEA as a whole (of which the application site forms part) had critical massand was a ‘strategic’ site with good access that had the potential to deliversignificant new employment space close to an established commercial centre.However it also noted that the DEA comprised a collection of sites with avariety of different uses of varying age and quality, was accessed fromvarious points but without continuous internal circulation. In addition much ofthe area was surrounded by well established and also new, high qualityhousing. Taking into account the existing and potential future supply ofindustrial space in the area the report concluded that the site should be

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reallocated from its DEA designation and identified for mixed employmentuses, including significant elements of light industrial and office uses.

i) Employment land demand

The applicant, referring to the unsuccessful marketing of the Marine WharfWest site, more recent market conditions, and site constraints has presentedevidence in their Employment Land Report accompanying the applicationregarding a lack of demand for the significant scale of floorspace thenavailable on the Marine Wharf West site. Officers accept this evidence of alack of demand and also that, on grounds of viability, a predominatelyemployment-based development is highly unlikely to come forward at thePlough Way site.

6.2.7 In the light of the information submitted by the applicant and its assessment byofficers it is considered that the matters to be taken into account when consideringexceptions to policy EMP 3 have been given due consideration and that, onbalance, there is sufficient justification for allowing the release of this site for mixeduse development. The Mayor of London has reviewed Lewisham’s Draft CoreStrategy and has agreed with the proposed release of certain sites (that werepreviously Defined Employment Areas), including the Plough Way site, for mixeduse development. This is confirmed in the GLA Stage 1 Report on the currentapplication dated 21/04/2010.

6.2.8 Members are advised that the current application has been advertised by theCouncil as a “departure” (i.e. a development proposal that does not conform withUDP policy). From the analysis above, officers are satisfied that the weight of theevidence in relation to the matters specified in the UDP Policy EMP 3, ascomprised in the application and from the Council's own studies, demonstratesthat there is a sound case for an ‘exception’ to the requirement of Policy EMP 3have been met and that the departure can be justified.

Plough Way Strategic Site

6.2.9 Marine Wharf West forms part of the Plough Way Strategic Site, one of four sitesthat is identified in the Draft Core Strategy as being a catalyst for regeneration ofthe Deptford and New Cross area through mixed use redevelopment.Redevelopment of these sites can deliver a comprehensive range of regenerationoutcomes in the Borough's most deprived areas focused on the provision ofhousing, jobs, accessibility improvements (public transport, pedestrian and cycle),public realm improvements and infrastructure provision (physical, social andgreen) that collectively can transform the physical environment and achieve place-making objectives. In the light of the conclusions regarding policy EMP 3, and priorto assessing the proposals against other saved policies in the UDP (as well aspolicies in the Draft Core Strategy), it is appropriate to consider how theapplication relates to policies in the Draft Core Strategy regarding strategic sites.

6.2.10 The Draft Core Strategy sets out a vision for the Borough up to 2026 and seeks tofocus new development within the Regeneration and Growth areas of DeptfordNew Cross, Lewisham and Catford (Spatial Policy 2). Within the Regeneration andGrowth areas ‘strategic sites’ have been identified that are of such a scale andsignificance that – individually and collectively – they are considered central to theachievement of the Lewisham Spatial Strategy (Strategic Site Allocation 1 –SSA1). In Deptford and New Cross these sites are: Convoys Wharf, Surrey Canal

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Triangle, Oxestalls Road and Plough Way (principally Marine Wharf East andWest and Cannon Wharf).

6.2.11 In view of the importance and complexity of the strategic sites, Draft Core StrategyPolicy 4 states that specific proposals will need to be progressed in the context ofa site-wide masterplan to be submitted as part of a planning application. Details ofthe approach are set out in Strategic Site Allocation 1 (SSA1), the supporting textto which states that:

“In view of the importance and complexity of the strategic sites, to ensure acomprehensive approach to their development and enable local communities tohelp further shape the proposals, specific proposals will need to be progressedin the context of a site-wide masterplan. The masterplan will need to beprepared by the prospective applicant and will be based on an analysis of thesite and its context and set out an overall development strategy that will formthe basis of a planning application for the site.”

6.2.12 Policy SSA1 goes on to identify the necessary components of a masterplan andPolicy SSA5 sets out specific guidance in respect of the Plough Way StrategicSite. Policy SSA1 and SSA5 envisage an planning application based on acomprehensive masterplan for the entire strategic site which in the case of PloughWay comprises three main parcels of land (in three separate ownerships) thattogether make up approximately 90% of the Strategic Site designation, togetherwith four smaller parcels (including the operational Earl Pumping Station site)which make up the remainder. The current planning application for Marine WharfWest relates to only part of the Plough Way Strategic Site (approximately 35% ofthe designation).

6.2.13 In the light of emerging policy in the Draft Core Strategy and the Council’srequirement that a masterplan be prepared for the Plough Way Strategic Site as awhole the applicant undertook a masterplanning exercise for the Plough Way Site.This covered the majority of the strategic site, though excluding the operationalEarl Pumping Station. This process included consultation with the Council,adjoining land-owners and the public and provided a framework within whichproposals for the Marine Wharf West site were developed. The masterplan setsout development principles for the strategic site in terms of site layout and linkagesacross the area, on the location of commercial uses and on scale and massing ofdevelopment across the site. The masterplan is included as part of the Designand Access Statement submitted with the planning application, and forms part ofthe application.

6.2.14 At the time of the preparation of the site-wide masterplan by the Applicant,planning applications for Cannon Wharf and Marine Wharf East had already beensubmitted to the Council by the respective owners of those parts of the site.These were submitted in early 2008, in advance of the current version of the DraftCore Strategy, and remain valid, though undetermined. Given this context, themasterplan prepared by the Applicant for Marine Wharf West properly examinestwo scenarios for the development of the strategic site: 1) a single, comprehensivescheme for the entire site; and 2) the redevelopment of the Strategic Site based onthe current applications/proposals for Marine Wharf West, Marine Wharf East andCannon Wharf each coming forward independently, with, in either case, MarineWharf West being developed as ‘Phase 1’.

6.2.15 Officers consider that the masterplan analysis of the strategic site and its contextis based on an appropriate understanding of the problems, constraints and

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opportunities of this part of the borough and that the masterplan provides acoherent basis within which the strategic site can come forward. The masterplansatisfactorily demonstrates that, whichever scenario is considered, the submittedproposals for Marine Wharf West are physically compatible with thecomprehensive development of the Plough Way Strategic Site, and that thedevelopment of the Marine Wharf West site as submitted would not prejudice theredevelopment of the entire strategic site in a manner that would deliver thegeneral and site specific objectives set out in the Draft Core Strategy.

6.2.16 It should be noted that whilst the masterplan is comprehensive in terms of its landcoverage, taking in all of the land that makes up the Plough Way Strategic Site(other than the Earl Pumping Station), unsurprisingly, given the separate landownerships, it does not consider the detailed mix of uses and floorspace acrossthe site, nor the overall financial viability and deliverability. In terms of delivery, theapplicants for the other parcels of land that make up the strategic site will berequired to prepare delivery strategies for their proposals, as they progress. In thiscontext the applicant for Marine Wharf West has prepared a strategy thataddresses issues relating to implementation of development on their site only, onthe basis that this will comprise the first, detailed phase. Nonetheless it isconsidered that the development of the Marine Wharf West site will have acatalytic effect on the regeneration of the area and, in the circumstances of thiscase, is considered an acceptable approach. This is considered in more detail insection 8 below (Financial Viability and Deliverability).

6.2.17 Given the framework set by the site-wide masterplan that has been submitted withand forms part of the Marine Wharf West planning application, the way in whichthe Marine Wharf West proposal sits within the masterplan, the nature and thetiming of the separate applications for Cannon Wharf and Marine Wharf East, andthe fact that there is no single, dominant landowner or other likely site assemblyissues, it is considered that there is no necessity for a single planning applicationand delivery strategy and/or the prior assembly/acquisition of the balance of theentire strategic site, in order to achieve the policy objectives relating to the PloughWay Strategic Site.

6.2.18 Although this approach is not fully consistent with the detailed requirements setout in the Draft Core Strategy, on balance the Council is satisfied that themasterplanning material submitted provides sufficient context within which toconsider the current planning application and how its fits into the wider PloughWay Strategic Site and the Council's aspirations and emerging policy for it.Therefore whilst the policies envisage a single comprehensive redevelopmentbased on a single masterplan, for the reasons set out above, it is considered thatthe submitted masterplan demonstrates that policy SSA5 can be delivered byseparate proposals for the individual sites that make up the Plough Way StrategicSite. In the circumstances it is concluded that the determination of separateapplications for parts of the Plough Way Strategic Site is acceptable.

6.3 Land Use: Employment

Introduction

6.3.1 The assessment of the application against saved UDP policy EMP3 (at paragraph6.2.4 above) concluded that, in principle, releasing the site from employment usefor mixed-use development of the site is acceptable. Before assessing details ofthe proposed development against other saved UDP policies and policies in theDraft Core Strategy it is relevant to consider the proposal against policy SSA5 in

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the Draft Core Strategy as it relates to the provision of employment floorspace. Inthis regard paragraphs 8.33 and 8.34 of the Draft 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

6.3.2 Paragraph 8.35 refers to the Council’s most recent Employment Land Survey, andnotes that, on balance, redevelopment of the Plough Way strategic site wouldincrease the intensity of uses, provide a greater mix of business uses, and replacesome of the existing buildings with modern facilities.

Commercial Floorspace

6.3.3 Policy SSA5 requires, amongst other things, that redevelopment provides at least20% of the built floorspace developed on the site to be for a mix of business spacewithin Use Classes B1(c), B2 and B8. This application includes 4,126 squaremetres (gross internal area) of commercial floorspace comprising 1,543 squaremetres of A1, A2 and/or A3 floorspace, 2,154 square metres of unrestricted B1floorspace, and 429 square metres of B1c floorspace. The Design and AccessStatement Addendum states that a further 2,100 square metres of non-residentialfloorspace would be provided (including cycle parking, refuse storage and plantincluding the CHP facility). Of this, 1,152 square metres would be within the ExtraCare facility (including its lobby) located in sub-block C1.

6.3.4 At 2,583 square metres of B1 and B1c floorspace the proposal amounts to only5.2% of the built floorspace. Although not specifically referred to in draft policySSA5, when the proposed A1, A2 and/or A3 floorspace is included in thecalculation this figure rises to 8.3%. This excludes the space in the Extra Carefacility which will provide employment opportunities as part of the service toresidents but is not identified as commercial floorspace.

6.3.5 Whilst the absence of B2 and B8 uses from the current proposals is consideredappropriate given the potential impact of such uses on adjoining residentialproperties, the commercial floorspace proposed is significantly below that requiredby policy SSA5. The applicant has submitted evidence regarding demand forindustrial space in the area and also a financial appraisal of the scheme. The latterdemonstrates that the non-residential floorspace provides a limited contribution tothe gross development value of the scheme and not in proportion to itscontribution to the overall floorspace. In other words, the provision of this space iscross-subsidised in part by the residential content of the development and soincreasing the commercial floorspace would inevitably have a negative impact onscheme viability. In addition given that the scheme is already a high densitydevelopment, increasing commercial space whilst maintaining the number ofhousing units is not considered appropriate on this site. Furthermore, given theoverall weak financial viability of the scheme the displacement of residential spacewith commercial space would have a disproportionate and further negative impacton viability. In the circumstances, and taken with the other aspects of the proposeddevelopment it is considered that the proposed amount of commercial floorspaceis acceptable but should not be seen as setting a precedent for the remainder ofthe site (subject to further viability assessment).

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6.3.6 The proposed location of the B1 and B1c floorspace along Plough Way isconsidered acceptable and would give occupants a street presence and goodaccess, and would contribute to a cluster or hub of business spaces, formed bythe existing Tavern Quay Business Centre to the north, and the rebuilt CannonWharf Business Centre as and when it comes forward (currently proposed towardsthe northeast corner of the Cannon Wharf site).

6.3.7 In terms of potential employment opportunities on the site, the applicant estimates

that a total of around 264 full-time equivalent jobs would be created by thedevelopment. Based on typical employee:floorspace ratios for different uses setout in English Partnerships’ “Employment Densities” report (2001) the B1 spacewould accommodate between 120-130 employees. The additional employmentgenerated by the proposed A1, A2 and/or A3 floorspace will vary depending onwhat proportions of the 1,543 square metres of space are occupied by each use.As the applicant seeks a planning permission that would allow flexibility in the useof this floorspace depending on demand, it is not possible to estimate accuratelyhow many A1 jobs, A2 jobs and A3 jobs would be provided. However, if forexample the 771 square metres in block N1 were occupied for A1 purposes, the437 square metres in sub-block C1 for A3, and the 335 square metres of sub-block E1 for A2, then up to 41, 34 and 18 jobs could be provided respectively.Paragraph 5.8 of the submitted Planning Statement states that the proposed ExtraCare facility would create around a further 35 to 40 jobs. Officers have reviewedthese estimates and consider that an overall figure of 260-270 full time equivalentjobs is reasonable.

6.3.8 Given the importance of securing a mixed use development on the strategic sitesand the low level of commercial floorspace provision on this part of the PloughWay site it is appropriate for the Council to seek some certainty that the B1 andB1c floorspace would be constructed in full. Accordingly it is recommended thatthe Section 106 agreement attached to any permission granted for the proposeddevelopment includes clauses preventing the occupation of residentialaccommodation in certain blocks, until the proposed B1 and B1c floorspace withinthat block has been provided.

6.4 Land Use: Housing

Introduction

6.4.1 At national level, PPS 1 (paragraph 14 onwards) and PPS 3 recognise the need todevelop socially inclusive communities, creating a suitable mix (both market andaffordable) of housing. PPS 3 (paragraph 29 onwards) requires the Council to seta plan-wide target for affordable housing, and targets relating to the mix in terms ofsocial and intermediate housing, size and type. In addition, PPS 3 requires theCouncil to set a threshold above which developments would be expected toachieve such targets and an approach for seeking developer contributions towardsthe provision of affordable housing.

6.4.2 The Lewisham Housing Market Assessment 2007-8 (HMA) published in December2009 states (paragraph 35) that a net 6,777 dwellings should be provided over thecurrent 5-year period to meet current identified need. This is equivalent to theprovision of 1,345 dwellings per annum. Table 3A.1 of the London Plan sets out atarget of 9,750 additional homes to be built in Lewisham in the 10 years from2007/8 to 2016/17, which is reflected in a monitoring target of 975 additionalhomes per year. As part of the overall need for housing in Lewisham, there is aspecific need for affordable housing. The HMA states (paragraph 36) that over

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80% of all new housing built would need to be affordable in order to meet identifiedneed.

6.4.3 Given that the application site is within reasonably close proximity to local servicesand access to the necessary social infrastructure it is considered suitable foraffordable housing in accordance with saved UDP policy HSG 14. This policy alsocommits the Council to negotiating for an element of affordable housing to beprovided in any major residential development. The supporting text of HSG 14adds that the Council considers it pragmatic to seek an affordable provision of35% of the residential content in developments, although it should be noted thatLondon Plan policy 3A.9 refers to a higher target of 50% (as does Draft CoreStrategy policy CS1). With regard to tenure mix, the supporting text of HSG 14refers to a target proposed by the Mayor of London in 2001 of 70% social rent /30% intermediate housing within affordable housing provisions. The more recentLondon Plan policy 3A.9 confirms that, within affordable housing provisions, aLondon-wide objective of 60% social housing and 40% intermediate provisionshould be applied. Different proportions are supported by the most recentpublished HMA which states (paragraph 37) that affordable housing provision inLewisham should comprise 85% social rented housing, and 15% intermediatehousing, in order to meet the identified need.

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

Housing Provision and Tenure Mix

6.4.5 The proposed development would provide 532 residential units including 103affordable units comprising 78 ‘Extra Care’ units (a form of housing whichpromotes independence with a variety of care and support services) and 25shared ownership units. It is proposed that the Extra Care units would betransferred to a Registered Provider to manage the facility. The proposed unitsizes, habitable room numbers, and tenure breakdown of the detailed and outlineelements of the proposed development are summarised in the tables below.

Table 3: Detailed unit size and tenure breakdown

1-bedroom 2-bedroom 3-bedroom 4-bedroom TOTALSocial Rented(Extra Care)

29 49 0 0 78

SharedOwnership

11 8 6 0 25

Private Sale 157 195 68 9 429TOTAL 197 252 74 9 532

1-bedroom 2-bedroom 3-bedroom 4-bedroom TOTALSocial Rented(Extra Care)

58 147 0 0 205

SharedOwnership

22 24 24 0 70

Private Sale 314 585 272 63 1234TOTAL 394 756 296 63 1509

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Table 4: Detailed habitable room figures

6.4.6 Based on this mix the development would comprise 14.7% social rented units,4.7% shared ownership units and 80.6% private sale units. Based on habitableroom numbers, the development would comprise 13.6% social rented, 4.6%shared ownership and 81.8% private sale. Based on unit numbers, the combinedaffordable element would be 19.4%, 18.1% based on habitable room numbers dueto the large number of 1- and 2-bedroom units and lack of family-sized unitsproposed in the Extra Care facility.

6.4.7 These figures fall significantly short of the 35% affordable housing figure referredto in saved UDP policy HSG 14, and the 50% target referred to in London Planpolicy 3A.9. The applicant has submitted a confidential financial appraisal for thescheme which has enabled the Council, advised by specialist consultants, toassess the overall viability of the scheme and its ability, in financial terms, to meetpolicy in terms of affordable housing provision. Further consideration of financialviability is set out at sub-section 8 of this report however in summary the financialappraisal demonstrates that, when taken with other policy requirements such asthe provision of employment space and other site specific objectives, the proposeddevelopment provides the maximum viable amount of affordable housing at thistime. The GLA has noted in its Stage 1 response that the level of affordable isbelow target levels (and that the proposed tenure split does not reflect LondonPlan policy) but also that it has yet to receive the financial viability report thatunderpins the scheme. This will be provided when the application is referred backto the GLA following determination by the Council.

6.4.8 It should be noted that the financial viability appraisal assumes a level of grant tosupport the proposed Extra Care social rented units. Given recent centralgovernment funding announcements there is no guarantee that grant will beavailable and the applicant has proposed that should public funding not beavailable for the affordable units or at a reduced level than assumed then acascade mechanism, to be included in the Section 106 agreement attached to anyplanning permission for the proposed development, would apply. In essence thiswould seek to maintain the overall level of affordable housing by retaining the 25shared ownership units, resulting in a proportion of the Extra Care units changingfrom social rented to other tenures. If grant is not available it is proposed that theRegistered Provider would agree a revised tenure mix with the Council (whichcould include intermediate rents, shared ownership and private sale) and wouldseek to minimise the amount of private sale.

6.4.9 Whilst it is accepted that the provision of a larger proportion of affordable housingis not possible at this time, given the shortfall in affordable housing provisionrelative to the levels set out in planning policies it is appropriate that this is keptunder review. To this end a mechanism is to be incorporated as part of theSection 106 to secure funding for additional affordable housing should valuesincrease to a level where this would be financially viable.

6.4.10 Notwithstanding the overall level of provision of affordable housing it is appropriateto secure a mix of tenures. In this regard based on grant funding assumptions bythe applicant and the financial viability of the scheme overall, the applicationproposes 78 social rented units which represent 75.7% of the affordable housing,and the 25 shared ownership units would make up the balance of 24.3%. Theseproportions are broadly similar to the 70% social rented / 30% intermediatehousing proportions set out in saved UDP policy HSG 14 and London Plan policy3A.9 and it is recommended that this tenure mix is accepted.

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6.4.11 In terms of the location and timing of provision of affordable housing in thedevelopment the applicant’s drawings show the Extra Care units located close tothe centre of the proposed development in sub-blocks C1 and C2 and to beprovided in Phase 2, with the 25 intermediate units in sub-block S6 close to thesite’s southern boundary and to be provided in Phase 5. The timing of provisionand location of the affordable housing (the majority being provided in the earlierstages and in the centre of the development) is considered acceptable and wouldbe secured through the Section 106 agreement.

Extra Care facility

6.4.12 The proposed Extra Care facility would provide 78 units over six floorsincorporating a ground floor lobby and mobility scooter store, and a first floorcommunal lounge, dining room, gym and physiotherapy suite with communalseating areas at first to fifth floor level. The applicant states that care and supportprovided to residents would vary – some residents may require significant levels ofcare from their first day of occupancy, however others may move in while able-bodied, and would not require care for several years. When needed, the carewould be provided on-site and would obviate the need for residents to move homewhen their needs become greater. The applicant has referred to successful ExtraCare facilities already operational in Cheltenham and Milton Keynes, while afacility is to be built by the applicant as part of the redevelopment of the FerrierEstate at Kidbrooke.

6.4.13 The Council’s Adult Services team are supportive of the proposed Extra Carefacility in principle, subject to detail as to how it would be funded and managed.Initial proposals have been submitted to the Council and subject to agreementregarding details of the funding and running of the facility, to be secured by way ofSection 106 agreement, it is considered that the proposed Extra Care facility isacceptable. It is also considered that the 78 Extra Care units can be counted asforming part of the development’s affordable housing provision. This is consistentwith the Homes and Communities Agency’s acceptance of Extra Care as apotential form of affordable housing.

Size of accommodation

6.4.14 The size breakdown of the 532 residential units proposed would be as follows:

• 197 (37%) would be 1-bedroom units• 252 (47.4%) would be 2-bedroom units• 74 (13.9%) would be 3-bedroom units• 9 (1.7%) would be 4-bedroom units

6.4.15 The proposed size mix includes 83 units (15.6% of the units) as family-sizedaccommodation. Whilst none of the 4-bedroom houses would be affordable, six 3-bedroom units are proposed as shared ownership. The applicant has justified thislevel of provision on the basis of financial viability and in the circumstances officersconsider the proposed unit size mix is acceptable.

6.4.16 All of the residential units would meet the dwelling size (overall floor area)standards set out under paragraph 3.4 of the Council's Residential StandardsSPD. Minimum room sizes set out in the Residential Standards SPD would also becomplied with, and in many instances exceeded. In addition, none of the units orrooms would have a layout which would compromise their use. The applicant

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proposes combined kitchen, dining and living spaces in some units and this isconsidered acceptable.

6.4.17 Stacking of the units is also considered to be generally satisfactory. Although therewould be some instances of living spaces being located directly above bedrooms(for example, in sub-block E3, unit E3-2-06 would have a living/diningroom/kitchen above a bedroom in the flat below), such arrangements are limitedwithin the proposed development and it is considered that overall the proposedstacking can be accepted.

Accessibility

6.4.18 Policy HSG 5 of the UDP states that the Council will only permit new residentialdevelopment which provides physical accessibility for all members of thecommunity including people with disabilities. Where appropriate the Council willseek the provision of new homes designed, or capable of adaptation, to housingfor long term needs. The supporting text later confirms that the Council willencourage developers to provide facilities that improve upon those statutorilyrequired and that the Council will encourage the provision of units that aredesigned to the Joseph Rowntree Foundation's Lifetime Homes Standards.

6.4.19 The Council’s Residential Standards SPD (2006) reflects London Plan (pre-2008version) policy 3A.4 Housing Choice. This stated that UDP policies should seek toensure that all new housing is built to Lifetime Homes standards and to ensurethat 10% of the new housing is designed to be wheelchair accessible or easilyadaptable for residents who are wheelchair users. These standards are repeatedin the updated (2008) London Plan, at policy 3A.5 and Core Strategy Policy 1 inthe Council’s Draft Core Strategy.

6.4.20 At paragraph 5.14 of the Planning Statement the applicant has confirmed that allresidential units have been designed to Lifetime Homes standards. The applicanthas also verbally confirmed that the wheelchair accessible/adaptable units havebeen designed to meet South East London Housing Partnership standards, thelatest iteration of which is dated August 2009, and both this and the LifetimeHomes standard should be secured by condition.

6.4.21 95 units are proposed as wheelchair accessible/adaptable, 81 being affordable (all78 Extra Care and 3 shared ownership) and 14 for private sale. This represents18% of the units which although above the policy target of 10% reflects the natureof the Extra Care facility which is designed specifically for those needing orpotentially needing care. The size breakdown of these units would be as follows:

Unit size Social Rent Shared Ownership Private Sale1 bedroom 29 0 12 bedroom 49 2 133 bedroom 0 1 04 bedroom 0 0 0

Total: 78 Total: 3 Total: 14

Table 5: Wheelchair/adaptable unit breakdown

6.4.22 Notwithstanding that the majority of the wheelchair units are within the Extra Carefacility, the proposed size, tenure mix and distribution of the balance of thewheelchair accessible/adaptable units across the site is considered acceptable.

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Residential Amenity

6.4.23 The majority of the residential units either face west, east or south, or are dualaspect however 22 units would be single aspect units reliant on daylight fromnorth-facing windows. Whilst single-aspect north-facing units should be avoidedwherever possible the applicant has reduced the number of affected units throughrevisions to the scheme and on balance the layout and orientation of theresidential accommodation is considered acceptable. The dual-aspect layout of asignificant number of residential units would also allow for natural cross-ventilationand thereby reduce the need for mechanical ventilation.

6.4.24 The Daylight and Sunlight Report (and Addendum) submitted with the applicationdemonstrates that habitable rooms within the proposed development wouldreceive an acceptable level of daylight. Given the proposed position of windows(and the number of primary and secondary windows proposed) it is consideredthat habitable rooms within the proposed development would receive adequatelevels of natural light.

6.4.25 In terms of outlook, windows serving habitable rooms would not be enclosed byadjacent development or other parts of the proposed development. Privacy withinthe proposed residential units would also be satisfactory due to the relationshipbetween the blocks and the existing residential properties on surrounding streets.The relationship of the proposed housing to that adjacent is considered in 6.9below and on balance is considered acceptable.

6.4.26 The Council’s Residential Standards SPD does not specify minimum amenityspace requirements for new residential development but does recommendgardens for houses are at least 9m in depth. The applicant proposes a variety oftypes of amenity space for residents around the site, some as private gardens forindividual units and other areas being shared amongst flats within a block. Themajority of the proposed residential units would be provided with their own privateoutdoor amenity spaces in the form of balconies or roof terraces, small gardens forsome ground floor units and 9m+ long gardens to the rear of the 4-bedroomhouses in block P. Almost all of the proposed balconies and gardens would beaccessed from the living spaces, with some units in block N1 also having thepossibility of a second access from a bedroom. In addition to the private outdooramenity spaces communal courtyard garden areas are proposed within blocks C,S and E. Officers consider that the type, location and size of provision isacceptable.

6.4.27 Living roofs are not normally suitable for use as outdoor amenity spaces, and theroof of sub-block E2 has therefore not been counted as forming part of the amenityspace provision. Overall, the proposed provision of private and communalresidential amenity space is considered acceptable for a development of thisnature and density. Public open space is considered in 6.9 below.

6.5 Land Use: Retail

Introduction

6.5.1 Given the amount of retail (A Class) floorspace proposed as part of thedevelopment it is appropriate to consider the land use implications and the impactof these uses on existing centres. UDP policy STC 2 sets out a sequential testapplicable to substantial retail development, confirming that such developmentshould be located in the first instance in major and district centres. London Plan

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policy 3D.1 states that boroughs should encourage retail uses in town centres anddiscourage them outside the town centres. Draft Core Strategy policy 6 sets outthe retail hierarchy and location of retail development across the borough andpolicy SSA5 notes that development of the Plough Way Strategic Site will provideretail uses to serve local needs that do not adversely impact on existing towncentres.

6.5.2 PPS4 requires applications for main town centre uses that are not in a centre andnot in accordance with an up to date development plan be assessed against anumber of criteria. Guidance on impact assessment accompanying PPS4 statesthat comprehensive assessments will only generally be needed if a scheme is over2,500 square metres, although they can be required for developments of less than2,500 square metres which are likely to have a significant impact on smaller towncentres. In this case the proposals are for a total of 1,543 square metres of A1, A2and/or A3 floorspace although the site is outside an existing town centre and theremay be impacts on existing local centres.

Retail Impact

6.5.3 Although in this case a retail impact assessment was not submitted with theapplication the site has been assessed by specialist retail consultants appointedby the Council as part of a wider assessment of the potential impact on existingtown centres of the retail floorspace proposed on the strategic sites in the area. Asimple capacity analysis for the Marine Wharf West site (based on the number ofadditional residents and typical convenience expenditure per head) indicates that,in isolation, the scheme could justify around 120 square metres (net) of localconvenience goods floorspace provision by the year 2014. This though does nottake account of the additional housing likely to come forward on the rest of thePlough Way strategic site and associated additional spend by new residents. Thesite-wide masterplan submitted with the Marine Wharf west application indicatesthat the location of the proposed commercial uses has been designed to link intothe adjacent Cannon Wharf site (as well as Marine Wharf East) and quantitativeanalysis by the Council’s retail advisers shows that there is capacity for a smallfoodstore to serve both Cannon Wharf and Marine Wharf West sites.

6.5.4 Although the Council’s consultants calculate that on its own the Marine WharfWest scheme could justify only around 120 square metres (net) of localconvenience goods floorspace (compared with up to 1,543 square metres ofA1/A2/A3 space applied for) they advise that the retail provision proposed atMarine Wharf West should not result in the development becoming a retaildestination drawing trade from existing centres within the Borough. Given thedistance of the site from Deptford High Street they consider that its potentialimpact on this existing centre is likely to be limited.

6.5.5 Given the proximity of the strategic sites to each other they also consider thepotential cumulative impact of the proposed retail floorspace. The Plough WayStrategic Site is between 600 metres and 1 kilometre from the nearest existingretail provision at Evelyn Street Triangle which is a relatively small centre withlimited convenience provision. There is also a store on Grove Street close to itsjunction with Oxestalls Road and shopping further afield on Lower Road and atSurrey Quays. However the Council’s advisers consider that the surrounding retailprovision is not likely on its own to be sufficient to meet the needs of the newresidential accommodation and employment uses on the Marine Wharf West andCannon Wharf sites.

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6.5.6 The total of 1,543 square metres of A1/A2/A3 space proposed on the MarineWharf West site is not broken down by use but would be split between threeblocks with the largest amount being 771 square metres in one block (N1). Noneof these 3 units alone would meet the definition of “substantial” provided underUDP policy STC 2 although it would clearly be greater than the 120 square metres(net) of local convenience goods floorspace that the Marine Wharf Westdevelopment itself might justify. Overall, whilst it is considered that the retail unitsare likely to mainly serve residents of the completed development the Council’sretail consultants advise that it is appropriate to control the retail floorspace withinthe development and restrict the maximum amount of A1 floorspace by way ofplanning condition.

6.6 Urban Design

Introduction

6.6.1 UDP policy URB 3 Urban Design states that the Council will expect a highstandard of design in new development or buildings, whilst ensuring that schemesare compatible with, or complement the scale and character of existingdevelopment, and its setting. Scale, mass, layout, access, townscape, height,alignment, quality and use of materials, ornamentation, and energy/resourceefficiency will be taken into account. The Council will consider the preservationand creation of urban form which contributes to local distinctiveness such as plotwidth, building features and uses, roofscape and open space. Other UDP policies(including HSG 4 and HSG 5), and the Residential Standards SPD, similarly stressthe importance of good design.

6.6.2 Relevant national guidance is provided in PPS 1 and PPS 3, and the documentsBy Design and the Urban Design Compendium. At a regional level, London Planpolicies 4B.1 and 4B.2 are relevant.

6.6.3 Emerging LDF policy is also a material consideration in the determination of thisapplication. As noted above, policy SSA1 in the Draft Core Strategy states that foreach strategic site allocation, a site masterplan must be prepared by theprospective applicant(s) with the involvement of landowners, local communities,the local planning authority and other interested parties. Draft policy SSA5, whichrelates specifically to the Plough Way strategic site, reiterates the Council’srequirement for redevelopment to be carried out in line with an approvedmasterplan.

6.6.4 Paragraph 4.119 of the London Plan defines tall buildings as those that aresignificantly taller than their surroundings and/or have a significant impact on theskyline and are larger than the threshold sizes set for the referral of planningapplications to the Mayor. In this case no part of the proposed development wouldexceed 8 storeys in height. Whilst this is taller than some of the buildingsimmediately adjoining the site there are a number of taller buildings in the vicinityas well as in the wider area. Consequently this report does not assess theproposed development against national, regional and local policies and guidanceon tall buildings however as the site lies within the Greenwich to St Paul’sCathedral viewing corridor the impact on this view has been assessed and this isconsidered in section 7 below as part of the review of the ES.

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Masterplanning

6.6.5 As noted earlier in this report, in accordance with draft policies SSA1 and SSA5,the applicant prepared a masterplan framework for the Plough Way strategic site(which the applicant refers to as “Surrey Wharves”), albeit excluding the EarlPumping Station on Yeoman Street which has been identified by Thames Wateras being required as part of their ‘Thames Tunnel’ (combined sewer overflowcapture) proposals.

6.6.6 Chapter 2 of the submitted Design and Access Statement provides a summary ofthe Surrey Wharves masterplan, and the 5 key design issues central to that projectare listed – these are 1) co-ordination with other development sites; 2) repair of thefractured urban fabric; 3) provision of appropriate employment uses; 4) improvingaccess to public transport and amenities; and 5) giving up private land to removebarriers to movement. The main elements of the masterplan (of which thisapplication forms part) are considered to be:

• An accessible linear park along the former route of the Grand SurreyCanal;

• The termination of this park at its north end with a commercial hub;• Secondary hubs in the centres of the Marine Wharf West and Cannon

Wharf sites;• East-west connections, between Plough Way and Yeoman Street (through

the commercial hub) and between Grove Street and Evelyn Street(through the two secondary hubs);

• A route from the commercial hub northeastwards to meet Plough Way;• Perimeter or courtyard blocks, flanking the linear park and other routes

through the site;• The arrangement of the tallest buildings along the linear park, and the

shortest positioned adjacent to residential property to the east and west;and

• Road connections at Evelyn Street, Grove Street, Rainsborough Avenueand Plough Way.

6.6.7 The masterplan presents two scenarios, one based on a comprehensive approachto the Plough Way Strategic Site and the other with the current planningapplication for Cannon Wharf and Marine Wharf East included. This approachrecognises the need for a comprehensive masterplan for the whole of the strategicsite whilst also acknowledging that applications for other parts of the strategic sitehave been submitted though are yet to be determined. Following completion of themasterplan the applicant commissioned architects to work up specific proposalsfor their Marine Wharf West site. The main elements of the proposals areconsidered to be:

• Built development predominantly on the site of the former factorybuilding/car park and provision of open space on the route of the formerGrand Surrey Canal;

• The termination of this park at its north end with an 8-storey building anda detached pavilion accommodating a café;

• A series of perimeter or courtyard blocks fronting the linear park andother routes through the site

• An east-west route connecting Hockett Close with the linear park, and apedestrianised route connecting Plough Way with the linear park;

• A north-south route connecting Plough Way with Carteret Way;

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• The arrangement of the tallest block (8 storeys) at the north of the site,with 7-storey sub-blocks lining the linear park, and 3- and 4-storey sub-blocks adjacent to existing residential properties on Carteret Way;

• The location of commercial floorspace along Plough Way; and• The location of an Extra Care facility between Plough Way and the

centre of the site.

6.6.8 The layout and massing described above generally follows the principles set downat the earlier masterplanning stage. Some minor deviations from the masterplanhave been included as a result of further consideration and testing of the detaileddesign, and following discussions with officers and consultees. In addition, someadjustments have been made at the northern end of the Marine Wharf West site,including the siting of the pavilion at the end of the linear park, in order to betterintegrate two key parts of the Plough Way Strategic Site.

6.6.9 Overall, it is considered that the preparation of the site-wide masterplan respondsappropriately to the approach set out in Draft Core Strategy policy SSA1 and 5and provides a coherent framework for the development of the Plough WayStrategic Site. The proposals for the Marine Wharf West site build successfully onthe key elements of the masterplan (see 6.6.6 above), respond well to the site andits context, and demonstrate that key issues such as connectivity and permeabilityhave been given appropriate consideration. The masterplan also demonstratesthat the Marine Wharf West proposals can integrate with and be the catalyst forthe Plough Way Strategic site whether as one site coming forward independentlywithin the context of a wider framework or in combination with the other sites as asingle comprehensive development, and can do so without compromising theoverall delivery of that masterplan.

Density

6.6.10 With the UDP policies on density (HSG 16) and sustainable living areas (HSG 17)now deleted, the appropriate density for this site is to be considered in the contextof London Plan policy 3A.3 taking account of the site's PTAL score andsurrounding residential densities – these vary from an estimated 95 units perhectare to the south to the higher densities of Iceland Wharf and Baltic Quay – aswell as the design, massing, land uses, amenity space and quality of the proposedresidential accommodation.

6.6.11 London Plan policy 3A.3 and the related table 3A.2 indicate that at "Urban" siteswith PTAL scores of 2 to 3, a density range of 200 to 450 habitable rooms perhectare can be appropriate. This translates as 45 to 170 residential units perhectare, depending on the average dwelling size. The site is not within theDeptford Creek/Greenwich Riverside Opportunity Area, therefore additional densityconsiderations set out in London Plan policy 5D.2 do not apply in this case.

6.6.12 With 532 residential units (accommodating 1,507 habitable rooms) proposed in asite of approximately 2.83 hectares (including the former canal route), thedevelopment would have a residential density (averaged across the site) of 532habitable rooms per hectare, and 188 units per hectare. It should also be notedthat, given the amount of non-residential floorspace also to be provided on the sitethe development’s residential density is in fact likely to be higher. Commenting ondensity, the GLA have noted that it is not unusual for residential schemes in urbanLondon to exceed the density guidance set out in the London Plan however, asnoted above, in considering whether the proposed development represents anoverdevelopment of the site it is necessary to take account of the type and mix of

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housing, the quantity of affordable housing, the quality of residential units, andother factors such as urban design and amenity space provision.

6.6.13 Although the proposed density is above the range set out in the London Plan thisis considered acceptable given the conclusions made elsewhere in this reportregarding, massing and design, public transport capacity and amenity spaceprovision.

Height and Massing

6.6.14 Heights in the proposed development vary from 1 to 8 storeys, with the tallestelement being block N1, at the north western part of the site. The developmentthen generally scales down in height towards the southeast, with buildings frontingthe linear park proposed at 7 storeys (sub-blocks C1 and C4), falling to 5 and 4storeys at sub-block S5. At the southeast corner of the site, terraced dwellingswould be 3 storeys in height. Moving east along the site’s Plough Way frontage,buildings would be 8 storeys in height (block N1), then 6 (sub-block C1, then 4(sub-block E1).

6.6.15 London Plan policy 4B.10 states that all large-scale buildings including tallbuildings should be of the highest quality design, and should meet several criteria.The building heights proposed by the applicant have also been influenced by therequirements of London Plan policy 4B.16 (which deals specifically with theLondon View Management Framework) and the Mayor of London’s 2010 LondonView Management Framework (LVMF) Revised SPG. Draft Core Strategy policy17 seeks to manage protected vistas, the London panorama and local views,landmarks and panoramas in accordance with this guidance.

6.6.16 In the applicant’s Design and Access Statement at page 28 it is stated that theproposed buildings follow the height parameters set by the masterplan, providing atransition between the two differing scales of the surrounding context i.e., the tallerbuildings that exist at Iceland Wharf and Baltic Quay (and that are proposed atCannon Wharf), and the lower buildings to the east of the Plough Way StrategicSite). This rationale is accepted and the proposed 8-storey height of block N1 isconsidered acceptable in the context of the adjacent Iceland Wharf and BalticQuay and would not appear unduly obtrusive in the Plough Way street scene.

6.6.17 When viewed from the south (along the route of the former canal) and east (alongPlough Way) the proposed height of block N1 is considered acceptable. Officersconsider that a strong termination of the linear park is needed here, especiallygiven the poor definition that the buildings of Iceland Wharf would otherwiseprovide. The design of the building and proposed materials have been amended inresponse to comments from the Council, Lewisham Design Panel, GLA and CABEand now provides an appropriate termination to these vistas.

6.6.18 Heights further along Plough Way are also considered acceptable. These wouldhelp to strengthen the edge of the site and provide some definition to the southside of the road (which is currently lacking on the north side, due to the spacing,setting back and orientation of buildings, and the amount of car parking provided).The proposed heights are also intended to mark the public centre of thedevelopment, or “hub”, where commercial uses are proposed and where publicactivity would be concentrated.

6.6.19 Heights fronting the linear park would begin (at its north end) at 8 storeys,descending to 4 storeys at its south end where sub-block S5 would stand adjacent

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to 2-storey properties on Carteret Way. This scaling down is consideredappropriate and demonstrates that adequate thought has been given to the scaleof adjacent existing development. Consideration has also been given to thecurrent proposals for the opposite side of the linear park at the Cannon Wharf site,where 7-storey blocks would line the edge of that site, interrupted only by a 20-storey tower. Whilst the height of buildings on the opposite (north) side of PloughWay is lower than that proposed on the application site the relationship isconsidered acceptable given the distance between them and benefits of having awell-defined frontage to Plough Way which is not achieved by the buildings to thenorth. Other heights in the proposed development are similarly consideredacceptable with due regard having been given to the scale of existing buildings ofthe Pepys estate, which border the application site to the south and east.

6.6.20 In terms of massing proposed across the site as a whole this is broken up by theproposed streets, avoiding overbearing elements and relating better to the layoutsand grain of surrounding development. The massing of the courtyard blocks isfurther broken up through east- and west-facing gaps beginning at first floor level,together with relief and other elevational detailing and interruptions, while variationin rooflines would further assist in preventing blocks from appearing monolithic.Views through the gaps in the elevations of the courtyard blocks would give thedevelopment a more open character whilst maintaining the definition andenclosure that these blocks were designed to achieve. Views of soft landscapingwithin the courtyards would also be provided by the openings.

Streets and Routes

6.6.21 Draft Core Strategy policy 4 states that Mixed Use Employment Locations(including Strategic Sites) will, through comprehensive redevelopment, be requiredto provide improvements to the overall environmental quality of these locations byproviding where appropriate the provision of new, or improvement of existing,walking and cycling routes to public transport services and local facilities. As notedearlier in this report, the proposed layout of the development is consistent with thesite-wide masterplan. The inclusion of important east-west and north-south routeswill ensure good permeability and connections with the surrounding area, andassist in addressing some of the existing barriers to movement in the area. Theproposed layout of streets also compliments, and forms a component of the NorthLewisham Links programme currently being promoted by the Council.

6.6.22 One area of concern relates to the car park proposed at the north of the siteadjacent to block N1 which as well as being visible along Plough Way, the car parkalso provides a poor termination to the historic path (though not currently a publicright of way) known as Tarry Lane, which runs roughly southwest-northeastbetween the Cannon Wharf and 19 Yeoman Street sites. The decision not to buildon this land and instead use it as a car park reflects the fact that a Thames Watersewer runs west-east under this part of the site and constrains developmentabove. In terms of its appearance from Plough Way it is considered thatlandscaping of the car park can mitigate this impact and this would be controlledvia a landscaping condition. In terms of the route of Tarry Lane, whilst proposalson the Cannon Wharf and Yeoman Street sites have sought to coordinate theirdesigns to accommodate a route along Tarry Lane, this is very much a secondaryroute with the main east-west movement further south within the Plough WayStrategic Site. This main east-west connection is incorporated into the proposalsfor both Marine Wharf West and Cannon Wharf and is considered an acceptableroute for pedestrians and cyclists.

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6.6.23 During the life of the application, in response to comments from officers, theDesign Panel, CABE, the GLA and a resident of Carteret Way, the applicantsubmitted amended drawings showing a 3.5 metre wide passage through sub-block S6, connecting Carteret Way with the square to the southeast corner of theapplication site. This passage would be two storeys high at each end however afirst floor glazed corridor would cross over the passage, reducing the passage 1storey in height for part of its length. The inclusion of this pedestrian connection isconsidered important in connecting the site with the wider area and thisamendment is welcomed. The connection would also provide a direct,unobstructed line of sight from Carteret Way to Plough Way.

6.6.24 It is noted that the north side of Carteret Way has no pavement, and that two rowsof parking spaces, set perpendicular to the road, currently meet the boundary ofthe Marine Wharf West site. To provide a satisfactory pedestrian connection withCarteret Way 2 of these parking spaces would need to be removed and new kerbsand surfaces provided to connect to the pavement on the south side of CarteretWay. From site visits it appears that these spaces are under-used and their loss isunlikely to give rise to parking problems locally. The applicant has agreed inprinciple to fund or carry out this work and this would be secured via a Section 106obligation. Although CABE and the Design Panel have outstanding concernsregarding the design of this connection, officers consider that its size, design,location and legibility are acceptable, and that the connection would be attractiveenough to ensure it would be used. Although the applicant proposes that this routeis gated it is considered that it should be permanently available as a pedestrianroute.

6.6.25 The proposed building heights would give clarity and definition to the streets withinthe proposed development, and routes through the site would be clear and legible.Also of relevance to successful streets is the way properties are oriented andwhere entrances are located. Following discussions with officers, the applicant hasincreased the number of private entrances to those blocks that would haveresidential accommodation at ground floor level. As a consequence there is now amix of maisonettes and townhouses with their own front doors and some flats thatwould have secondary external doors onto their private amenity spaces (inaddition to their main entrances off internal communal corridors), with othershaving patio doors opening onto small terraces facing onto the street. This isconsidered acceptable. The proposed linear park would also communal entrances,private entrances, patio doors opening onto terraces, and stepped entrances tothe courtyard gardens along its eastern edge. In addition a small number ofparking spaces are provided along this edge providing further scope for activity.

6.6.26 Ground floor external doors to the south elevation of sub-blocks S4 and S6 wouldhelp to ensure that the proposed development properly related to Carteret Way.Most of the remaining residential units at ground floor level would have no externaldoor or entrance and access to the Extra Care facility would be via a securecommunal entrances which is considered appropriate.

6.6.27 The appearance of the commercial space at ground floor level has not beendetailed in the submitted drawings, however these ground floor treatments can bedealt with at conditions stage. Of note, the submitted floor plans suggest that therewill be scope for significant stretches of glazing at ground floor level, which wouldenable the uses within to animate the streets that they would line, and wouldimprove natural surveillance of the street.

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6.6.28 Overall, the experience of residents of and visitors to the developed site at streetlevel is considered acceptable.

Materials and elevational detail

6.6.29 Section 07 of the Design and Access Statement describes the architecture,appearance and materials of the proposed development. A mix of architecturalstyles and materials is proposed for the buildings responding to the context ofdifferent parts of the site. Amendments have been made to the design andmaterials in response to comments from officers and other consultees and theseare welcome.

6.6.30 The three main buildings facing onto the linear park combine brickwork and timberpanels at the lower parts of the elevations with panellised metal cladding above.3D images submitted with the application suggest that this cladding material wouldhave the appearance of oxidised metal. For sub-block C1 (which fronts the linearpark at its northern end and forms the frontage to the pedestrian link to PloughWay), the applicant proposes a “floating” brickwork box above a glazed base,while balconies would have glass balustrades. Block N1 (at the end of the linearpark) would be predominately finished with brick and metal cladding. Further intothe site, mixed stock bricks are proposed for external walls, however sub-block P1would be rendered. Coloured projecting balconies are also proposed.

6.6.31 Material details shown on the submitted drawings and in the Design And AccessStatement are considered sufficient at this stage, and indicate that the proposedmaterials should be of some quality and consistency. The very limited use ofrender is welcomed. The predominant use of brick towards the south and east ofthe site is considered appropriate given the proximity of these blocks to theexisting brick buildings of Carteret Way. The proposed metal cladding wouldreference the industrial heritage of the area. Although the use of timber claddingwas objected to by one local resident, deterioration in the appearance of thismaterial can be avoided through suitable treatment, installation and maintenanceand its use is considered acceptable.

6.6.32 The proposed elevations (as revised) have been detailed to prevent the blockshaving a monolithic appearance. Most of the windows throughout the developmentwould have a consistent vertical emphasis. The extensive use of balconies wouldillustrate the residential use of the majority of the blocks. Rooflines would begenerally horizontal, however those blocks facing the linear park would havepitched roofs, arranged to make the buildings resemble warehouses and shedsthat once fronted historic wharfs and canals. This reflection of the docksidewharves heritage of the area is considered appropriate. The elevational treatmentof the pavilion terminating the linear park is considered acceptable and extensiveuse of glazing would animate the café square and the key pedestrian route thatpasses it.

6.6.33 In order to ensure that the quality of design and materials indicated in thesubmitted documents are actually provided it is appropriate that samples andspecifications of brick types and metal cladding specification as well as details ofwindow, door and panel materials are submitted for approval by the Council,secured by way of a condition.

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Design and crime

6.6.34 Draft Core Strategy policy 15 (High quality design for Lewisham) states that for alldevelopment the Council will ensure design acts to reduce crime and the fear ofcrime. In terms of measures incorporated into the design of the Marine WharfWest site, public open space in the proposed development would be overlooked,and would have private and communal entrances opening onto them, as wouldpublicly-accessible routes through the site. With the exception of the relativelysecluded entrance to block N1, entrances to all blocks would be located onelevations passed which residents and members of the public can walk or cycle,and these entrances would benefit from good visibility. Elderly and potentiallyvulnerable residents of the Extra Care facility would access their flats via a securecommunal entrance.

6.6.35 The proposed private communal courtyards would not be accessible to public.Sub-courtyard parking areas would be gated. Cycle parking would be providedwithin the blocks. The proposed internal layouts of the residential units is generallyacceptable with corridors and cores serving a small number of flats. Given theabove, the proposed layout and design raises no significant concerns in terms ofcrime and the fear of crime. No response to the Council’s consultation wasreceived from the Metropolitan Police Crime Prevention Unit.

6.7 Transport

Introduction

6.7.1 This section of the report addresses issues relating to traffic impact and tripgeneration, highways works, car and motorcycle parking, cycling and cycleparking, servicing and construction traffic. National guidance on transport mattersis found in PPG 13 (Transport) and PPS 3 (Housing). The most relevant generalUDP policy is TRN 1 Location of Development - this policy directs high tripgenerating development to places where there are high levels of public transportaccessibility and capacity, sufficient to meet the transport requirements of thedevelopment. UDP policy TRN 6 Employment Areas states that the Council willseek to improve public transport, cycling and pedestrian access to DefinedEmployment Areas. London Plan policy 3C.1 (Integrating transport anddevelopment) sets out a similar policy position whilst 3C.2 (Matching developmentto transport capacity) and 3C.3 (Sustainable transport in London) seek to ensurethat development is related to transport capacity and that measures are taken toencourage movement to more sustainable modes of transport. Other more specificrelevant local and London-wide policies are referred to later in this report, whereappropriate.

Traffic impact and trip generation

6.7.2 Relevant UDP policies are TRN Location of Development, TRN 2 Travel ImpactStatements, TRN 3 Developer Contributions, TRN 4 Access for Public Transport,TRN 5 Green Travel Plans, TRN 10 Protection and Improvement of PublicTransport and TRN 20 Improving Road Safety. Relevant London Plan Policies are3C.9 (Increasing the capacity, quality and integration of public transport to meetLondon’s needs), 3C.13 (Improved Underground and DLR services), 3C.14(Enhanced bus priority, tram and busway transit schemes), 3C.17 (Tacklingcongestion and reducing traffic), 3C.18 (Allocation of street space), 3C.20(Improving conditions for buses), and 3C.21 (Improving conditions for walking).

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6.7.3 The submitted Transport Assessment estimates vehicle trips that the proposeddevelopment would generate for different modes (private car, taxi motorcycle,public transport (bus, tube, rail) cycle and walk) and assesses their impact on theexisting network and services. Given that the former use of the site has ceasedand the building on the site has been demolished all trips generated from theproposed development are new/additional.

6.7.4 The trip generation arising from the proposed development has been estimatedusing TRAVL data and modal split data from the 2001 census data. Due to the factthat census data is now dated and there have been changes in the area, in thecase of residential trips the applicant has supplemented this data with surveyevidence from trips at Aragon Tower which was extended/refurbished by BerkeleyHomes. In the case of the proposed B1 use, sites from the TRAVL database werefor inner London locations with a PTAL rating of less than 3 (the site has a ratingof 2). For A1 uses the applicant has assumed that 75% of trips will be linked/pass-by trips i.e. travelling to the site will not be the primary purpose of that trip. It isconsidered that

6.7.5 Using this information the applicant estimates the following total week day peakhour trip generation:

Mode AM Peak PM PeakIn Out Total % In Out Total %

Car (driver) 15 25 40 8% 25 30 55 11%Car (passenger) 6 11 17 4% 12 12 24 5%Taxi 1 3 4 1% 2 2 4 1%Motorcycle 3 7 10 2% 5 4 9 2%Bus 29 77 106 22% 53 42 95 19%Tube 33 96 129 27% 63 45 108 22%Rail 19 51 70 15% 34 28 62 12%Walk 29 54 83 18% 65 62 127 26%Cycle 4 10 14 3% 7 6 13 3%

Table 7: Estimated weekday peak hour trip generation

6.7.6 This compares with the Council’s own estimates (undertaken by Alan BaxterAssociates as part of an assessment of the cumulative impact of developmentsproposed in the Deptford and New Cross area) which identifies a similar (slightlylower) overall trip generation from the site. This assumes that a proportion of tripsare internal (i.e. to/from within the site) and only 5% of retail trips are additionalrather than pass by. The assessment estimates bus usage at a similar level, butwith a higher percentage of trips by private car and walking and a lowerpercentage using the tube. The Council’s assessment also includes a proportion(7% of AM and PM peak trips) using the riverboat service at Greenland Pier whichis not accounted for in the applicant’s Transport Assessment.

6.7.7 The Transport Assessment assesses the impact of these trips on the highwaynetwork looking at four key junctions: Rotherhithe New Road / Lower Road /Plough Way Evelyn Street; Oxestalls Road / Evelyn Street; Evelyn Street / AlloaRoad / Rainsborough Avenue; Grove Street / Evelyn Street with developmenttraffic has been distributed on the surrounding highway network in accordancewith existing traffic flows. The capacity of these junctions during the AM and PMweekday peak has been assessed for four scenarios: i) the existing situation, ii)the existing situation plus traffic from ‘committed’ schemes in the vicinity (Convoys

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Wharf, Cannon Wharf, Marine Wharf East and Yeoman Street plus 6 sites inSouthwark) referred to as the Base Case; iii) the Base Case plus traffic fromMarine Wharf West and iv) a sensitivity test including traffic from the proposeddevelopment of the Oxestalls Road. The Surrey Canal Road Strategic Site has notbeen included in the assessment on the grounds that the site is situated asignificant distance from Marine Wharf West.

6.7.8 LINSIG and PICADY modelling shows that whilst the degree of saturationgenerally increases as a consequence of the proposed development, under allscenarios all but one of the junctions works within its theoretical capacity. Theexception is the Grove Street/Evelyn Street junction when the proposed OxestallsRoad development is added. The applicant argues that this scheme may not comeforward, noting that without the traffic from the Oxestalls Road site this junctionoperates within capacity, and that many junctions in inner London exceed theirtheoretical capacity during peak times. Notwithstanding this assertion the applicantalso states that they are prepared to consider a package of mitigation measures(in addition to the Travel Plan to be implemented for the proposed development)including traffic/transport related contributions to be paid by each developerclosely linked to the scale/nature of each individual planning application.

6.7.9 In terms of the impact on public transport the applicant’s Transport Assessmenthas examined the impact on buses, underground (at Canada Water) and rail (atSurrey Quays). The applicant estimates that there would be an additional 29arrivals and 77 departures during the AM peak and 53 arrivals and 42 departuresduring the PM peak that would use bus services i.e. a maximum of 106 trips to andfrom the site during the AM peak. Existing bus services and bus frequency in thearea (including the 199 which runs past the site) provide 23 services in eachdirection during the peak hour. The Transport Assessment states that the 106 tripsto and from the site in the AM peak equates to just over two extra passengers perbus and concludes that this will not result in a material impact on existing buses.This does however assume that passengers will be spread evenly across all theservices. The Transport Assessment does not consider likely preferences andconcludes that even if certain buses take twice the average number of passengersthis would amount to more than 4 additional passengers which it is implied wouldnot have a material impact on existing services.

6.7.10 The impact on bus services has been assessed by TfL who consider that given the199 provides a direct link to both Surrey Quays and Canada Water stations, it islikely that people will use this service to access overground rail and theunderground at these stations. In addition, routes 47, 188 and 225 arguablyduplicate links provided by the underground and East London Line. In thecircumstances it is considered that the majority of bus trips are likely to occur onthe 199 and as a consequence it is appropriate that a financial contribution ismade to mitigate the impact of the proposed development on the bus network. TheCouncil’s own assessment, based on proximity of services to the site rather thanroutes/connections, indicates that passengers will use services 199, 47 and 188equally and in favour of the 225 which is further away.

6.7.11 With regard to overground rail and underground services the applicant estimatesthat the number of passengers from the site using East London Line and JubileeLine services will represent a very small percentage (less than 0.5%) of overallcapacity on these services.

6.7.12 In conclusion it is considered that the Transport Assessment and its assumptionsare reasonable and that the applicant’s conclusions regarding impacts in terms of

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the local highway network are generally accepted although the cumulative impactof this scheme with others in the area means that a contribution to highwayimprovements (including for pedestrians) are appropriate . In the case of publictransport, a financial contribution to bus services is required and the applicant hasindicated their willingness to do this.

Highways works

6.7.13 The development would necessitate various works to the public highway, namely:

• Provision of dropped kerbs and loading bay on Plough Way• Provision of pedestrian crossing(s) and refuge close on Plough Way.

6.7.14 The loading bay forms part of the application proposals and is consideredacceptable. The location of the pedestrian crossing(s) is the subject of ongoingdiscussion and will be finalised as part of the negotiations on the legalagreements.

Car and motorcycle parking

6.7.15 Relevant UDP Policies are TRN 6 Employment Areas, TRN 23 Car FreeResidential Development, TRN 25 Controlled Parking Zones, TRN 26 Car ParkingStandards and the related Table TRN 1, and TRN 28 Motorcycle Parking.Relevant London Plan policies are 3A.3 (Maximising the potential of sites) and therelated Table 3A.2 (Density Matrix), 3C.1 (Integrating transport and development)and 3C.23 (Parking strategy).

6.7.16 Table TRN 1 of the UDP indicates maximum car parking standards and theprovision of spaces at a ratio of 40%, in combination with measures set out in theTravel Plan to encourage non-car modes and contributions to public transportservices, is considered acceptable for this site. A concern raised by TfL has beenthe proposed development’s possible impact on parking in surrounding streets dueto the number of parking spaces proposed. At the moment this part of the boroughis not covered by a CPZ although Plough Way to the west of the site (in LBSouthwark) is part of a CPZ. Given the scale of proposed development in thevicinity (the Plough Way sites, Oxestalls Road and Convoys Wharf all located tothe east of Evelyn Street) it is appropriate that at an appropriate time consultationwith local residents is undertaken on a CPZ in the area and the applicant hasagreed to a financial contribution towards this. Should a CPZ be agreed then it isintended that residents of the development would not be able to apply for on-streetresidents parking permits within the Zone.

6.7.17 In addition, to further reduce residents’ need to own vehicles the applicant isproposing up to five spaces for car club vehicles on the site to be provided on aphased basis. This would be delivered as part of the Section 106 agreementincluding membership for occupiers (residents and businesses) of thedevelopment. The facility would also be available for use by the general public.

6.7.18 The provision of 53 car parking spaces for blue badge holders around the site isconsidered acceptable and compliant with relevant planning policy.

6.7.19 Parking for commercial uses comprises a total of 21 spaces located in the parkingarea to the north of building N1. This is broken down as 4 spaces for the B1 and17 for the retail. This compares with a maximum level of 4 and 82 spacesrespectively based on the London Plan standards. This is considered an

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acceptable level of provision, however further details of allocation of car parking(which should clarify or correct the excessive provision for the retail floorspace)are required under a recommended condition.

6.7.20 11 motorcycle parking spaces are proposed within the secure parking areas andwhilst no standard is set out in the adopted UDP this level of provision isconsidered acceptable.

Cycling and cycle parking

6.7.21 Relevant UDP Policies are TRN 6 Employment Areas, TRN 14 Cycle Parking,TRN 15 Provision for Cyclists and Walkers and TRN 16 Developing Pedestrianand Cycle Networks. The most relevant London Plan policy is 3C.22 (Improvingconditions for cycling).

6.7.22 558 cycle parking spaces (543 for residents, 35 for visitors), are proposed.Visitors’ cycle parking would be provided outside the buildings, with mostresidents’ cycle parking to be provided in the secure parking areas within each ofthe blocks. The proposed provision for residents meets the requirements set out inUDP policy Table TRN 2, and the visitor’s cycle parking is welcomed.

Servicing

6.7.23 All servicing (other than servicing for the proposed retail units which would takeplace in the loading bay on Plough Way) and refuse collection would take placefrom within the site. A swept path diagram appended to the Transport Assessmentindicates that refuse collection vehicles would be allowed good access around thedevelopment.

Demolition and construction traffic

6.7.24 The relevant UDP Policy is HSG 4 Residential Amenity. The impact of constructiontraffic is described in the Construction Methodology Statement appended to theES Addendum. This estimates average construction vehicle movement to be in theorder of 70 to 80 vehicles per day for the peak of the construction period. TheConstruction Methodology Statement includes indicative construction traffic routingvia Plough Way however it proposes details are discussed and agreed withLewisham, Southwark and TfL prior to works commencing on site.

6.7.25 Given the total number of vehicle movements and the likely limited and temporarydisruption to roads surrounding the site it is considered that the impact of theproposed demolition and construction works in terms of highway capacity andpedestrian amenity are not likely to be significant.

Travel Plan

6.7.26 A Framework Travel Plan, setting out overall strategy and specific measures andtargets to promote sustainable modes of transport by both businesses andresidents on the site is included as an appendix to the Transport Assessment. Itproposes that a Site Travel Plan Manager will be appointed at least three monthsprior to first occupation and will be responsible for overseeing the management,development, implementation, monitoring and review of the Travel Plan. BerkeleyHomes would fund the Travel Plan Manager until the first buildings are occupied atwhich point the cost would be part of the management service charge. Followingfeedback on the planning application supplementary information has been

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submitted by the applicant including a draft Parking Management Strategy to formpart of the Travel Plan.

6.7.27 It is considered that these key principles and proposals form an appropriate basisfor a detailed Travel Plan. No objections relating to this matter have been receivedfrom officers in the Council’s Highways and Transportation team, or fromTransport for London. It is recommended that the preparation, submission andimplementation of a full Travel Plan (separately for residents and occupiers) besecured as part of the Section 106 agreement.

6.8 Environmental Sustainability

Introduction

6.8.1 UDP policy URB 3 refers to the contribution that developments make to energyand natural resource efficiency. Other UDP policies relating to energy in theEnvironmental Protection chapter of the plan have been deleted. Paragraph 2.4 ofthe Council's Residential Standards SPD encourages the inclusion of energyefficient and renewable energy technology and design. The SPD also refers toLondon Plan (pre-2008 version) policies regarding energy efficiency, renewableenergy, water supplies and sustainable design and construction. These policieshave been revised and strengthened in the extant (2008) London Plan – policies4A.3, 4A.4, 4A.6, 4A.7, 4A.9, 4A.10, 4A.14, 4A.16 and 4B.1 are considered to beof most relevance to this case. In particular, policy 4A.7 Renewable Energy statesthat boroughs should “adopt a presumption that developments will achieve areduction in carbon dioxide emissions of 20% from on site renewable energygeneration… unless it can be demonstrated that such provision is not feasible”.London Plan policy 4A.1 (Tackling climate change) establishes an energyhierarchy based around using less energy, in particular by adopting sustainabledesign and construction (being ‘lean’), supplying energy efficiently, in particular byprioritising decentralised energy generation (being ‘clean’) and using renewableenergy (being ‘green’). This approach is reflected in Draft Core Strategy CoreStrategy Policy 8 (Sustainable design and construction and energy efficiency)which states that the Council will explore opportunities to improve the energystandards and other sustainability aspects involved in new developments and thatit will expect all new development to reduce CO2 emissions through a combinationof measures including maximising the opportunity of supplying energy efficientlyby prioritising decentralised energy generation for any existing or newdevelopments (and in the Regeneration and Growth Areas using SELCHP as anenergy source) and meet at least 20% of the total energy demand through on-siterenewable energy.

Sustainability proposals

6.8.2 The Revised Energy Report (October 2010) states that all residential units will bedesigned and constructed to meet Code for Sustainable Homes (CfSH) Level 3and the commercial space will achieve BREEAM rating ‘Very Good’. CfSH andBREEAM pre-assessments are appended to the applicant’s Revised EnergyReport. CfSH Level 3 requires, amongst other things, that the Dwelling EmissionRate (the estimated carbon dioxide emissions in kg per m² per annum arising fromenergy use for heating, hot water and lighting i.e. regulated energy) to be at least a25% improvement over the Target Emission Rate (the maximum emission ratepermitted by Part L1A Building Regulations 2006).

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6.8.3 The report presents a number of scenarios for addressing CO2 reduction targets:communal heating systems and biomass boilers, gas-fired or biomass CHP(combined heat and power) with district heating, and site-wide gas-fired CCHP(combined cooling, heat and power). Given the location of the application sitewithin an Air Quality Management Area and potential for air quality impacts arisingfrom a biomass fuel based technology the applicant has proposed a gas-firedenergy solution. Notwithstanding the potential air quality issues of biomass fueleach of the options is assessed using the Mayor’s energy hierarchy and thereduction in CO2 that can be achieved over and above the baseline emission i.e.the emissions from the development built in compliance with Part L of the currentBuilding Regulations.

6.8.4 Gas-fired CHP with district heating is identified as the preferred solution for whichthe Revised Energy Report identifies a 13.1% carbon saving through the use ofenergy efficient measures (i.e. lean), increasing to 46.0% through the use of acommunity heating system with gas-fired CHP coupled with high efficiencycondensing boilers providing domestic hot water and space heating to the entiredevelopment. (i.e. clean). In terms of renewables (green) the report asserts thatthere is no practical on site renewable technology available that can be applied inconjunction with the community CHP and as a consequence the carbon savingfrom renewables under this scenario would be zero. Whilst it is debateablewhether this is actually the case, the scheme would achieve an overall carbonsaving of 46% which is significantly above the London Plan target of 20% and inthe circumstances the failure to include renewables is accepted.

6.8.5 The proposed single CHP facility responds to advice from the GLA that thenumber of energy centres should be minimised. In addition the Council’sSustainability Officer and the GLA also advised that connection should be made toa district heating network, such as the network powered by SELCHP. This systemis not however yet in place and the applicant has therefore stated that theproposed development would allow for the possibility of a future connection toSELCHP subject to this being technically and financially viable and compatiblewith the construction programme. In the circumstances it is accepted that, at thepresent time a commitment to connecting to SELCHP being made prior to thedetermination of this application is not feasible.

6.8.6 As noted above a CfSH pre-assessment has been submitted to demonstrate howCfSH Level 3 would be achieved however in addition it is appropriate for theCouncil to require by condition the submission of confirmation that the proposedscore has been achieved in each phase post-construction. Although notspecifically referred to in current UDP policies, achieving CfSH Level 3 isconsidered to be an appropriate means of ensuring compliance with UDP policyENV.PRO 13 Aggregates, and London Plan policies 4A.3 Sustainable Design andConstruction and 4A.16 Water Supplies and Resources.

6.8.7 London Plan policy 4A.11 (Living roofs and walls) expects major developments toincorporate living roofs and walls where feasible. Living roofs can take many formsin order to maximise their benefits in a given location. Vegetated roofs, includingterraces and gardens, can improve the thermal performance of the building,reduce the urban heat island effect, absorb rainfall to reduce flash flooding, andenhance biodiversity. A living roof is proposed on one sub-block.

6.8.8 The applicant has not referred specifically to the Mayor of London’s SustainableDesign and Construction SPG and has not confirmed that all essential standardsset out in the SPG that can be addressed have been or will be met or exceeded.

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However achieving CfSH Level 3 involves, in addition to Energy and CO2

Emissions, addressing standards on a number of topics: Water, Materials, SurfaceWater Run-off, Waste, Pollution, Heath and Wellbeing, Management and Ecology.The CfSH pre-assessment sets out how many ‘credits’ are attributed to thescheme under each heading and overall the scheme at design stage wouldcomfortably achieve Level 3 would address many London Plan requirements atleast to an acceptable level. Achieving at least CfSH Level 3 is the minimumacceptable and to ensure implementation of the proposed measures a post-construction assessment and sign-off by an accredited assessor is consideredappropriate, to be secured by condition.

6.9 Other Planning Considerations

Neighbour amenity - introduction

6.9.1 Policies HSG 4 Residential Amenity and HSG 5 Layout and design of NewResidential Development seek to ensure that new developments are designed sothat the amenities of existing residential properties are not unacceptably harmed.Policy ENV.PRO 11 Noise Generating Development aims to resist developmentthat could lead to unacceptable levels of noise. The Council’s ResidentialDevelopment Standards SPD states that developers will be expected todemonstrate how privacy would be provided for occupiers of neighbouringhousing, noting that unless otherwise demonstrated that privacy can bemaintained through design, there should be a minimum separation of 21 metresbetween directly facing habitable room windows which would need to be increasedwhere higher buildings are involved.

Privacy and overlooking

6.9.2 The majority of the proposed residential accommodation would be positionedgenerally in excess of the 21m from neighbouring properties and have nosignificant impact on privacy. A distance of only 15 metres would be achievedbetween the rear of the 3-storey houses of block P and existing houses at 75 to 83Carteret Way. A similar situation would arise at 38 to 44 Carteret Way, where adistance of 18 metres would be achieved. Whilst this is below the normallyaccepted minimum of 21m it is considered that the existing trees which are to beretained along this common boundary will reduce potential overlooking. Noobjections to the proposed development have been received from the occupantsof these houses in Carteret Way.

6.9.3 The applicant has also considered the distance between the proposeddevelopment and current proposals at the adjacent Cannon Wharf site. Buildingson either side of the proposed linear park would be 30 metres apart.

Outlook

6.9.4 Noting the distinction between views (over significant distances and land not in theownership of the viewer) and outlook, it is considered that residential propertiessurrounding the application site at Iceland Wharf, Plough Way, Hockett Close andCarteret Way would not experience a significant loss of outlook nor anunacceptable increase in sense of enclosure caused by the proposeddevelopment, due to the distances between existing and proposed developmentdescribed above.

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Overshadowing

6.9.5 The applicant has submitted a Daylight and Sunlight Report, which has beenamended by a Daylight and Sunlight Addendum in the light of amendments madeto the proposals during the life of the application. The assessment uses the BRE’sVertical Sky Component (VSC) and Average Daylight Factor (ADF) tests, andfinds that the proposed development would preserve a good level of daylight andsunlight to existing neighbouring residential properties. Although two measurementpoints opposite the application site at 155 Plough Way would experience areduction in daylight in excess of the maximum recommended by the BRE, theapplicant notes that this is because these south-facing windows currentlyexperience an exceptionally high level of daylighting, as the land opposite iscurrently undeveloped. The applicant is of the view that these windows in factwould continue to receive an adequate level of daylight, and this conclusion isaccepted by officers. The applicant states that all assessment points pass theAnnual Probably Sunlight Hours (APSH) test.

6.9.6 Impacts upon daylight and sunlight to the proposed Cannon Wharf site have alsobeen tested, and the applicant has found that all but one living room would pass orexceed the BRE’s ADF standard. Overshadowing testing to the rear gardens of 57to 91 Carteret Way indicate that compliance with BRE guidelines.

6.9.7 The above findings show negligible impacts to the majority of receptors, includingthose properties positioned nearest to the boundaries of the application site. Theproposed development’s impact upon daylight and sunlight currently enjoyed byneighbouring residents is considered acceptable.

6.9.8 Sunpath analysis has also been undertaken which indicates that whilst part of thedevelopment would cast a shadow over adjoining properties at particular times ofthe day these would be transitory and would not be so great as to warrant refusalof planning permission.

Impacts of increased population

6.9.9 The submitted ES Addendum states that the 532 residential units proposed wouldaccommodate 927 permanent residents.

6.9.10 With regard to the impacts of increased population, such as extra demand forservices and public transport as well as parking locally – considered elsewhere inthis report – it is considered that the mitigation proposed adequately addressesthese issues.

Publicly accessible open space and landscaping

6.9.11 The applicant has recognised the importance of carefully designed, high qualitylandscaping, and officers agree that appropriate landscaping is crucial to thesuccess of a development of this scale and density.

6.9.12 The submitted Design and Access Statement includes a description of thepublicly-accessible areas of open space to be provided in the proposeddevelopment, while the Addendum Landscaping Design Statement states that11,866 square metres of public realm, 4,281 square metres of private communalspace (mostly provided in the courtyards of blocks C, S and E), and 707 squaremetres of Extra Care private communal space (in the courtyard of block C) wouldbe provided.

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6.9.13 Comparison with other submitted drawings confirms that all public amenity spaceswould be overlooked by residential properties in the proposed development andwould be accessible, while all private amenity spaces would be suitably enclosedby the perimeter blocks, or by boundary treatments such as hedges. There wouldbe clear definition of, and separation between, the public and private spaces, andhierarchy of spaces within the development would be clear.

6.9.14 The arrangement of public and private spaces along the development’s streetswould be relatively informal, with hard landscaping in the proposed streets brokenup by planters and landscape buffer strips. This is considered acceptable anddoes not detract from the clear routes through the site for pedestrians and cyclists.On-street parking would be limited so that parked vehicles would not dominate thestreet scene.

6.9.15 A key feature of the urban design principles for the Plough Way Strategic Site setout in Draft Core Strategy policy SSA5 is to create accessible cycle and pedestrianlinkages along the route of the former Surrey Canal to provide a safe, attractivepublic route celebrating this historical use and helping to tie the site with theOxestalls Road strategic site and the nearby Pepys estate. This is provided forwithin the site-wide masterplan for the Plough Way site and is a key part of thelandscaping strategy for the site. This would provide open space for the PloughWay site as well as connect with sites to the north and south. It will accommodatehard surface walking and cycling routes and grassed areas for general recreationas well as dedicated play areas, in part to meet play space standards set out in theLondon Mayor’s SPG ‘Providing for Children and Young People’s Play andInformal Recreation’ (2008).

6.9.16 The Landscaping Design Statement sets out the design vision for the linear park,explaining that, as well as providing an important north-south route that wouldextend southwards beyond the site into the Pepys Estate and the Oxestalls Roadsite, the park would celebrate the site’s historic uses, with landscaping being usedto reference the timber industries of the area (installations along the park wouldrepresent trees being transformed into timber products). The applicant hasconfirmed that surviving stones and paving materials of the canal’s towpath andedges would be reused in the landscaping, and the proposed bound gravel pathwould follow the north-south route of the towpath. Further detail of the boundarytreatments at the south end of the linear park (to be secured via condition) isrequired to ensure that the layout of the route between the site and land to thesouth is acceptable.

6.9.17 In terms of the amount of public open space proposed, it is noted that all of theapplication site is within an area of public open space deficiency. UDP policy OS 8states that, at sites within deficient areas, the Council will negotiate withdevelopers for new provision of public open space, and that public open space willbe sought within housing schemes. It is considered that with the provision of thelinear park this policy requirement is met.

6.9.18 The enclosed private communal courtyards for residents would provide thedevelopment’s largest amenity spaces not accessible to the public. Althoughconcerns have been expressed by the GLA regarding permanent overshadowingof these spaces, generally it is considered that they would provide attractiveoutdoor space for the residents of the proposed development, and are consideredacceptable. The size and shape of the water feature in the courtyard of block S isconsidered acceptable given the provision of hard and soft-surfaced amenity

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space elsewhere in the development, and the feature itself would contributepositively to the setting of the residential accommodation that would surround it.

Trees

6.9.19 A Tree Survey Report and Arboricultural Impact Assessment was submitted withthe application. The applicant assessed the quality of each tree on andimmediately adjacent to the site in accordance with BS 5837:2005. Of the 74 treesassessed, 7 were identified as being of moderate quality and value (category B),64 as being of low quality and value (category C) and 7 as being in such acondition that any existing value would be lost within 10 years (category R). Notrees of a high quality and value were identified.

6.9.20 The applicant proposes the retention of a London Plane at the northern tip of theapplication site, adjacent to the vehicular access to Iceland Wharf, and the linearrow of Birch and Ash along the eastern boundary of the site (shared with the reargardens of houses on Carteret Way). All other trees would be removed includedthe line of trees along the southern boundary of the site (adjacent to parkingspaces on Carteret Way. These proposals are considered acceptable given thepoor condition and age of the majority of the existing trees, and given theopportunities for coherent, comprehensive and high quality landscaping that theredevelopment of the site offers.

6.9.21 Conditions, requiring the adequate protection of trees to be retained, and thereplanting of any trees that fail within 5 years of planting, are recommended. It isalso considered appropriate that a final landscaping scheme is submitted forapproval including details of plant species.

6.9.22 It is understood that maintenance of the proposed development’s landscapingwould be the responsibility of the development’s management team. A condition,requiring details of the maintenance of the proposed landscaping, isrecommended.

Ground levels

6.9.23 No basements or underground car parks are proposed, and the site is relativelylevel. It is understood that the proposed development would not involve significantearth movement or other changes to levels, however some excavation may berequired in relation to site contamination remediation, and the landscaping of partof the former route of the Grand Surrey Canal, which is recommended to beincluded in the Section 106 agreement attached to any permission granted for theproposed development.

Telecommunications interference

6.9.24 Given the height of buildings proposed which rise to a maximum of 8 storeys andtaller buildings in the vicinity it is not anticipated that the proposed developmentwould affect local television and radio broadcast and reception.

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7. ENVIRONMENTAL IMPACT ASSESSMENT

7.1 Introduction

7.1.1 The planning application is accompanied by an Environmental Statement (ES) thatreports on likely significant impacts arising from the proposed development andproposed mitigation. The ES considers the impact of the development in terms ofthe following topics:

• Transport• Noise and Vibration• Local Air Quality• Ecology• Archaeology• Ground Conditions and Contamination• Water Quality and Resources• Townscape and Visual• Socio-Economics• Waste Management• Microclimate – Wind• Cumulative Effects• Residual Effects

7.1.2 The ES has been reviewed by specialist consultants, Capita, appointed by theCouncil and the following sets out the Council’s consideration of the identifiedimpacts and proposed mitigation based on advice from its consultants. Transportis considered earlier in this report at 6.7.

7.2 Noise and Vibration

7.2.1 The national, regional and local planning policy relevant to noise is found in PPG24, London Plan 4A.20 (Reducing noise and enhancing soundscapes), and UDPpolicy ENV.PRO 11 Noise Generating Development

7.2.2 Noise information and mitigation set out in chapter 5 of the ES states that theexisting dominant sources of noise (that would affect occupants of the proposeddevelopment) are traffic from surrounding roads (Plough Way and distant roads),and activities currently taking place in the adjacent Cannon Wharf site. Theapplicant states that given that both the application site and dwellings in thevicinity of the site are located away from any significant sources of vibration, novibration measurements were considered necessary. This conclusion is acceptedfor the completed development.

7.2.3 Overall the noise and vibration chapter of the ES represents a clear andcomprehensive assessment, and no major concerns have been identified with themethodology, results or overall conclusions. The construction period is likely togive rise to the most significant noise and vibration impacts on surroundingproperties Within-phase noise impacts during construction (i.e., the noise impactupon occupants of early phases experienced whilst work on later phasescontinues) are likely to be significant, however with appropriate mitigation (such aslimiting hours of works) and given that the construction phase would be temporary,this impact can be accepted. A condition, requiring the preparation and submissionof a Construction Management Plan including such noise mitigation measuresduring the construction period, is recommended. This should include a

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reassessment of peak site traffic levels, to confirm that anticipated noise nuisanceremains “not significant”.

7.2.4 Assuming that current noisy activities at Cannon Wharf would cease the ES statesthat the site falls into noise exposure category (NEC) B, indicating that somemitigation measures will be required for the residential element. Noise impact uponthe proposed development during the operational phase (i.e., once thedevelopment is completed and occupied) would most likely be caused by trafficnoise from Plough Way. The applicant recommends minor mitigation measures toresidential properties facing the edges of the site, namely sound-reducingventilator strips for outward-facing bedroom and living room windows. Appropriatesoundproofing between the residential and non-residential uses within theproposed development can be secured by condition.

7.2.5 No assessment was made by the applicant of the potential effects of noise fromthe proposed non-residential uses. Given that the commercial (B Class) uses arelimited to those that can operate within a residential environment withoutdisturbance due to noise and fumes this is considered acceptable, subject tocontrols over hours of servicing. In terms of the retail (A Class) space the specificoccupiers are not yet known although it is understood that the A1 retail space islikely to be a local food/convenience type store. It is considered that local impactsin terms of servicing as well as noise and fumes from any A3 (restaurant) uses canbe controlled by condition. Specifically, conditions controlling the opening hours ofany A3 use and requiring the details of any plant and noise breakout preventionmeasures are recommended. Delivery hours for any A1 use, and soundproofingbetween the residential and non-residential uses, are also referred to in therecommended conditions. Of note, no A4 drinking establishments or A5 hot foodtakeaways are included in the proposed development.

7.2.6 As current noise-generating uses being carried at the adjacent Cannon Wharf sitedo not currently have planning permission (a planning application, ref:DC/10/73735, is currently under consideration) and are understood to betemporary until that site undergoes mixed use development, it is not considerednecessary to apply conditions requiring additional soundproofing of the windows ofresidential accommodation at the Marine Wharf West site.

7.2.7 It is considered that the proposed development would provide an acceptableresidential living environment in terms of noise exposure.

7.3 Air Quality

7.3.1 With the UDP policy on air quality (ENV.PRO 8) now deleted, reference must bemade to London Plan policy 4A.19 (Improving air quality), which states that“boroughs should…achieve reductions in pollutant emissions and public exposureto pollution by…ensuring at the planning application stage, that air quality is takeninto account along with other material considerations, and that formal air qualityassessments are undertaken where appropriate, particularly in designated AirQuality Management Areas”.

7.3.2 Chapter 6 of the ES addresses local air quality. It states that, following mitigation,residual effects of construction traffic are likely to be short term and of minornegative significance, while residual effects during the operational phase arepredicted to be negligible for NO2 and negligible to neutral for PM10. Chapter 6 ofthe ES represents an adequate assessment and the methodology, results andoverall conclusions of the assessment do not raise significant concerns.

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7.3.3 The applicant’s assessment has, however, had to make certain assumptionsregarding the proposed CHP facility, and it predicts that NOx levels within the site(affecting new residents) are likely to be above target levels. Because the detailsof the CHP facility are yet to be specified and designed in detail it is consideredthat the conclusions in the ES should be revisited to establish whether they wouldneed to be changed in the light of this further information. Therefore a conditionrequiring a further air quality assessment to be submitted for approval by theCouncil prior to the commencement of any construction of the CHP facility isrecommended.

7.4 Ecology

7.4.1 UDP policy OS 13 Nature Conservation states that the Council will have regard tothe nature conservation value of all sites to be developed, and will seek to protectand enhance these. London Plan policy 3D.14 is also relevant.

7.4.2 The part of the application site that includes the former route of the Grand SurreyCanal forms part of a Site of Nature Conservation Interest. This designationcontinues southwards beyond the application site along the former canal route,and also westwards along the former railway embankment that runs parallel toRainsborough Avenue. All of the site is in an Area of Nature ConservationDeficiency, as set out at Map 3.3 in the Unitary Development Plan.

7.4.3 The applicant’s ecological assessments are provided in chapter 7 of the ES. Theapplicant describes the existing ecological interest of the site and surroundingarea, notes that the loss of trees at the south of the site and the developing ruderalcommunity (which are of local interest) would result in a negative effect in terms ofbiodiversity, but goes on to note that the inclusion of a living roof, landscaping andnative planting within the courtyards would result in an overall positive effect onthe site’s biodiversity.

7.4.4 With regard to the designation of part of the site as a Site of Nature ConservationInterest, the applicant notes at paragraph 7.4.19 of the ES that the designated partof the site was reportedly cleared of vegetation prior to August 2007, and that theland can therefore no longer be considered as having local value.

7.4.5 The applicant’s ecological assessment are generally considered acceptable andhave been undertaken in accordance with the Institute of Ecology andEnvironmental Management (IEEM) Guidelines for Ecological Impact Assessment(2006). Furthermore, it is generally accepted that measures proposed by theapplicant (including the planting of native trees including Lime, and the provisionwildflower meadow grassland along the linear park) would result in a positiveresidual effect in terms of the site’s ecological interest and biodiversity. There is,however, scope for further measures to enhance the site, including the provision ofbird and bat boxes, and log piles attractive to invertebrates. A condition, requiringmeasures and implementation of a full scheme of ecological enhancement as partof the landscaping details is therefore recommended, as is a condition requiringthe submission of a habitat management plan. This plan should contain a built-inreview period and a commitment to post-completion ecological surveying todemonstrate and promote the success of the ecological enhancement required ofand proposed by the applicant.

7.4.6 Living roofs provide significant opportunities for the enhancement of biodiversity,particularly in locations close to the River Thames and London Plan policy 4A.11

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(Living roofs and walls) expects major developments to incorporate living roofsand walls where feasible. A living roof is proposed to sub-block E2 however this isa relatively limited provision for a development of this size. The scope foradditional areas being dedicated as living roofs has been discussed with theapplicant however they consider that given the improvements to biodiversity whichthe ground floor landscaping areas (including the route of the former canal) willprovide, further living roofs are not necessary and given their cost would furtherreduce the viability of the scheme. Whilst further enhancements would bedesirable officers conclude that given other biodiversity measures the level ofprovision is acceptable.

7.5 Archaeology

7.5.1 PPS 5 sets out national planning policy in relation to the historic environment. Atthe regional level, London Plan policies 4B.11 (London’s built heritage), 4B.14(World heritage sites) and 4B.15 (Archaeology) are relevant. Lewisham UDPpolicy URB 21 Archaeology is relevant.

7.5.2 All of the application site is within an Area of Archaeological Priority in the UDPhowever it is not within a conservation area and includes no listed or locally listedbuildings. The nearest listed buildings are the Grade II listed Royal Victoria Yardentrance and cannon posts on Grove Street, approximately 120 metres away fromthe southeast corner of the application site. Beyond these, further southeast, areother Grade II listed buildings that formed part of the historic dockyard. To theeast, over 200 metres away from the application site, is the Grade II listed parishboundary stone (dated 1819), wall and pier at St George’s Wharf. The nearestconservation area within the Borough is at Deptford High Street, some 1.2 km tothe southeast, while the Thorburn Square and St Marys Rotherhithe conservationareas are located further away within LB Southwark. The Maritime GreenwichWorld Heritage Site is located approximately 1.9 km away from the applicationsite.

7.5.3 Given the building heights proposed at Marine Wharf West, the site’s location inrelation to the above listed conservation areas and listed buildings, and theintervening development, it is considered that the proposed development wouldnot adversely affect the setting or appreciation of these heritage assets.

7.5.4 London Plan policy 4B.14 states that boroughs should take account of and giveappropriate weight to the provisions of the World Heritage Site ManagementPlans, and the 1998 Maritime Greenwich World Heritage Site Management Planhas duly been referred to by officers. This document discusses the importance ofthe setting of the WHS and important river views, but does not set out policy orguidance on appropriate building heights at sites as far away from the WHS asMarine Wharf West. The proposed development would not be visible from theMaritime Greenwich World Heritage Site (WHS), due to the intervening topographyand buildings. Some wide views from the Isle of Dogs may take in both the WHSand glimpses of parts of the buildings proposed at Marine Wharf West, howeverthe proposed development would not affect the setting of the WHS.

7.5.5 The assessment of archaeology and cultural heritage provided in chapter 8 of theES notes that the application site lies within Archaeological Priority Area (APA) 7 –Deptford – the Strand, Sayes Court and the Royal Naval Dockyard. Details ofknown archaeological remains in the area are provided, and map evidence isstudied. Noting that the location of the site would have made it potentiallyattractive to settlement over a considerable period of time, and that there is

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evidence of human activity in the surrounding area from Mesolithic times onwards,the applicant recommends mitigation in the form of archaeological observationintegrated within the remediation process. It is also noted that pile foundations areto be used, and that development at the site and the excavation of the GrandSurrey Canal would have had a considerable deleterious effect upon anyarchaeological deposits within 1 to 2 metres of the modern ground surface.

7.5.6 Chapter 8 of the ES is considered to be an acceptable assessment of the site’spotential for archaeology and cultural heritage and English Heritage (Archaeology)have raised no objection to the proposed development. The submission of aspecification of archaeological work (if a geotechnical site survey is to be carriedout before this application is determined) is, however, recommended. If nogeotechnical site work is to be carried out before this application is determined,English Heritage recommend that the archaeological position be reserved throughthe use of a condition requiring the implementation of a programme ofarchaeological work in accordance with a written scheme for investigation to beapproved by the Council. Such a condition is included in the recommendations atsection 9 of this report.

7.5.7 A stone set into the site’s existing perimeter wall on Plough Way (opposite LighterClose) reads “This stone marks the former Kent/Surrey boundary”. Although thestone itself is not believed to be of any significant age and need not be retained, itwould be appropriate to again mark this historic boundary in the landscaping andboundary treatments at this part of the application site. Details of its incorporationinto the landscaping and boundary treatment proposals should be referred to inthe relevant landscaping condition.

7.6 Ground Conditions and Contamination

7.6.1 National planning policy relating to contaminated land is set out in PPS 23. UDPpolicy ENV.PRO 10 Contaminated Land is also relevant.

7.6.2 Ground conditions and contamination is addressed in chapter 9 of the ES(superseded in full by the revised chapter 9 appended to the ES Addendum),where the historic uses, geology and hydrology of the application site aredescribed. The findings of previous site investigations are examined, andcontamination recorded at the site is listed. A conceptual site model is provided,and potential effects are described.

7.6.3 The Council’s consultant has confirmed that further investigation of the site isnecessary. A condition is therefore recommended requiring the submission of adetailed investigation and assessment of the site in relation to possiblecontamination together with full details of any remediation required, and the finalsubmission of a closure report. Although site contamination information includingdetails of site investigations already carried out at the site has already beensubmitted at application stage, given the history of the site and potential forcontaminants to be revealed by further site investigation works this is notconsidered sufficient to obviate the need for an appropriate condition related tosite contamination.

7.6.4 The Environment Agency has responded to the Council’s consultation in respect ofcontaminated land and has recommended a series of conditions to be attached toany permission granted with which officers concur and these are recommendedaccordingly.

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7.7 Water Quality and Resources and Flood Risk

7.7.1 The national planning policy relevant to flood risk is found in PPS 25. London Planpolicies 4A.13 (Flood risk management), 4A.14 (Sustainable drainage) and 4A.16(Water supplies and resources) are also relevant, as are UDP policies ENV.PRO15 Sustainable Surface Water Drainage in New Development and ENV.PRO 17Management of the Water Supply.

7.7.2 Chapter 10 of the ES addresses water quality and resources. This chapter isconsidered generally satisfactory. The application site is within Flood Zone 3a,where a high probability of flooding exists. A Flood Risk Assessment is appendedto the ES and states that the flood risks associated with the site are not unusual orcontentious.

7.7.3 The Council concurs with this assessment and, as proposed by the EnvironmentAgency, a condition regarding development in accordance with the submittedFlood Risk Assessment is recommended. These are included in therecommendations at the end of this report. A further condition, requiring details ofsurface water drainage at the site, is also recommended.

7.7.4 The comments made by Thames Water regarding infrastructure and water supplyare included as an Informative. An appropriate condition relating to surface waterdrainage is recommended.

7.8 Townscape and Visual

7.8.1 The applicant, in chapter 11 of the ES, has provided separate assessmentsaddressing the impact of the proposed development on specific townscapecharacter areas, and on identified views.

7.8.2 Townscape character areas have been identified by the applicant, based on acombination of topography, land cover and land use, open space, built form, urbangrain, structure, scale, massing and vegetation. For each of the 15 townscapecharacter areas, townscape quality, townscape value and sensitivity to change isnoted. The applicant has divided the townscape impact assessment into 3 stages(site enabling works, construction and operation).

7.8.3 During the short-term site enabling and construction stages, moderate negative,minor negative and negligible impacts are anticipated by the applicant, and thisassessment is considered reasonable, given that – as is to be expected – MarineWharf West will have the appearance of a building site, with scaffolding, cranes,equipment, unfinished surfaces and incomplete buildings being visible in the shortterm.

7.8.4 When the proposed development is completed the applicant anticipates negligible,minor positive, moderate positive and major positive impacts. This assessment isconsidered accurate, given the current condition of the site, the dramaticimprovements that would be made to the site in visual terms, and the resultantimprovements to the setting of existing residential development to the north, eastand south of the application site.

7.8.5 The location and direction for the views set out in chapter 11 of the ES werediscussed between the applicant team and officers prior to the submission of theapplication and provide a comprehensive illustration of the visibility and impact ofthe completed development from key locations around the application site. The

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applicant has used as-existing images of each of the views, and prepared VerifiedVisual Montage (VVMs) for selected locations with the proposed developmentoverlaid as wireframe or solid blocks.

7.8.6 The applicant has categorised the considered views into those of regionalimportance, those of local importance as identified by the Council, and other localviews. A description of the sensitivity of each of the views considered is alsoprovided, and distances between each viewpoint and the application site arenoted. As with the townscape impact assessment, the applicant has divided theview impact assessment into 3 stages (site enabling works, construction andoperation), and as with the applicant’s townscape assessment, moderate negative,minor negative and negligible impacts upon views are anticipated by the applicantat site enabling and construction stages (i.e., the short term), with major negativeimpacts anticipated on view 22 (Hockett Close, due to the proposed erection ofhoardings, emerging built form, and cranes) and view 26 (linear open space to thesouth of the application site, for the same reasons).

7.8.7 For the completed development’s impacts on selected views would be as follows:

View Location Impact1 Greenland Dock Moderate positive2 East India Pier Negligible3 Sir John McDougall Gardens Negligible4 Great Eastern Pier Negligible6 Pepys Park Negligible7 Grove Street Negligible9 General Wolfe statue Negligible11 Deptford Park Negligible15 Plough Way/Tavern Quay Moderate positive16 South Dock Moderate negative18 Plough Way/Calypso Way Moderate negative22 Hockett Close Moderate negative26 linear open space Major positive27 Windlass Place Minor negative28 Oxestalls Road Minor positive31 Chiltern Grove/Yeoman Street Minor negative

Table 6: Views with applicant’s assessment of impact

7.8.8 While assessing impact on views is to an extent subjective, officers generallyagree with the assessment made by the applicant (and summarised in Table 6above).

7.8.9 Given the proposal to remove the row of conifers on the southern boundary of thesite (bounded by Carteret Way) a VVM was prepared for view 24 (Carteret Way)and included in the ES Addendum. This illustrates the impact of the proposeddevelopment on this view. The applicant identifies this impact as moderatepositive.

7.8.10 The ES Addendum also included a re-assessment of some of the views listed inTable 6 above, in the light of the design changes made during the life of theapplication. Only 1 such re-assessment resulted in a change to the conclusionsset out in Table 6 above: the impact on view 18 (Plough Way/Calypso Way) is now

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identified as moderate positive due to the change made to the proposed buildingmaterials, and the provision of a positive termination to the vista.

7.8.11 The townscape and visual amenity assessment provided by the applicant inchapter 11 of the ES is considered to be an adequate explanation of the impactsof the proposed development, and its methodology and findings are consideredacceptable. The negative impacts of the proposed development are largelyanticipated in the short term only, and with some mitigation measures proposed(such as minimising crane heights), these impacts can be accepted.

Impacts on Protected Views and Vistas

7.8.12 UDP policy URB 22, deals with local views and identifies those considered to be ofimportance and London Plan policies 4B.10, 4B.14, 4B.16 (which deals specificallywith the London View Management Framework) and 4B.18, and the Mayor ofLondon’s 2010 London View Management Framework (LVMF) Revised SPG –which designates views of London and some of its major landmarks – are alsorelevant. The UDP proposals map identifies a Strategic Viewing Corridor andStrategic Wider Viewing Corridor (Greenwich Park to St Paul’s Cathedral) thatcross the north of the Borough and the Marine Wharf West application site,however more recent policy and guidance issued by the Mayor of London usesdifferent terms in relation to this protected view. In the LVMF, Designated View 5(Greenwich to Central London), is classified as a “London Panorama” view, andcomprises a Landmark Viewing Corridor, a Landmark Lateral Assessment Area,and a Landmark Background Assessment Area. The identified Viewing Location isclose to the General Wolfe statue in Greenwich Park, and the designated viewtakes in the River Thames, the Convoys Wharf site, and Aragon Tower. IcelandWharf 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 beseen. The background of St Paul’s Cathedral in the view is mostly unimpeded,with a silhouette of the dome clearly visible.

7.8.13 The applicant has addressed the impact of the proposed development upon thedesignated view in chapter 11 of the ES. The applicant recognises that thesensitivity of this receptor (which is the view itself) is high, and concludes that theimpact during site enabling works would be negligible, that the impact duringconstruction would be minor negative (due to the likely visibility of temporarycranes) but the impact during the operational phase would be negligible, as theproposed building would be below 30 metres AOD in order to maintain the view ofTower Bridge and St Paul’s Cathedral. Appendix 11 of the ES provides baselinephotographs of the existing view from Greenwich to Central London (which theapplicant refers to as Viewpoint 9), and a VVM illustrating how visible theproposed development would be in this view. This VVM, together with moredetailed wireframe VVMs included in a subsequent document titled “Clarification toTownscape and Visual Impact Assessment Plans and Photographs”, confirms thatthe proposed development would not obstruct views of The Monument, TowerBridge and St Paul’s Cathedral, and that much of the development – when viewedfrom Greenwich Park – would in fact be obscured by existing intervening trees andbuildings.

7.8.14 At page 26 of the LVMF SPG, it is noted that the foreground and middle ground ofLondon Panoramas must be given careful attention, as development within theseareas can greatly affect the designated view. The Marine Wharf West site fallswithin the middle ground in this case, however it is considered that the proposed

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development, due to its heights, grain and materials, would not appear overlyintrusive or prominent to the detriment of the view.

7.8.15 Given the limited heights and impact described above, it is not necessary toconsult or seek the comments of London Boroughs along the route of thisdesignated view (namely LB Greenwich, LB Tower Hamlets, City of London andLB Camden), however the GLA, CABE, English Heritage and LB Southwark havebeen consulted in accordance with guidance set out at pages 10 to 13 of theLVMF SPG.

7.8.16 In terms of local views, the nearest listed in Schedule 1a of the UDP are thosepanoramic views (northwest, northeast and southeast) of the River Thames fromDeptford Foreshore (site reference LV7). Due to the building heights proposed atMarine Wharf West, and the intervening distance and buildings, it is consideredthat these local views would not be obstructed or otherwise adversely affected bythe proposed development.

7.9 Socio-Economics

7.9.1 London Plan policy 3A.28 (Social and economic impact assessments) relates tosocial and economic impact assessments for major developments within Areas forRegeneration. Policy 2A.7 of the London Plan, and the related Map 2A.2, confirmthat the application site is within such an Area for Regeneration (thesedesignations correspond with London’s most deprived wards). Policy 3A.28requires that the proposed development be subject to a social and economicimpact assessment. This is effectively provided at chapter 12 of the ES, asamended by the ES Addendum.

7.9.2 The applicant’s submission represents a comprehensive assessment. It concludesthat Council Tax receipts generated by the proposed development will be£719,227 per annum at 2009/10 rates, that increased consumer spending wouldhave a major positive effect, that the effect of temporary construction employmentwould be moderately positive, that permanent employment generated by theproposed development would have a long-term major positive effect, and that theprovision of training opportunities would have a moderate positive effect.

7.9.3 The ES Addendum provides a revised population figure (of the proposeddevelopment) of 927 people, of which 70 would be children aged 0 to 15.

7.9.4 It is recommended that the Section 106 agreement to be attached to any planningpermission for the proposed development should be used to capture the benefitsof the training to be offered during construction at the site.

Community facilities

7.9.5 Chapter 12 of the ES considers social infrastructure including the impact of theproposed development on schools, health and community facilities. The ESAddendum estimates a total population of 927 residents living in the proposeddevelopment (including 70 children) which will increase demand for school places,health and other community facilities locally. Although a child yield for the site hasbeen prepared and existing schools within the vicinity of the site identified the ESstates that in the absence of up-to-date and school-specific data on current andprojected pupil capacity for the schools closest to the proposed development theapplicant has been unable to assess the full impact of the proposed development

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on local schools. It concludes that the development is expected to generate afairly modest number of children and therefore it is not anticipated that mitigationwill be necessary although it acknowledges that this will need to be reviewed in thelight of relevant data. In terms of health facilities the ES states that the increaseddemand would have a minor negative effect and that the increased demand forother community facilities would also have a minor negative effect.

7.9.6 The Council has been undertaking its own assessment of school places and, withthe PCT, health facilities in the Deptford and New Cross area as part of theInfrastructure Delivery Plan and this has informed its consideration of the impact ofthe proposed development on these facilities. A review by the Council of existingschool places in the borough and forecast population growth has identified a needby 2019 for 15 forms of entry at Primary School level across the borough(assuming a two form entry school is provided at Convoys Wharf) and 400 to 600Secondary School places. A proportion of this new demand would be from theMarine Wharf West site and whilst the type and location of new school places(expansion of existing schools or new provision) to accommodate the growth inpopulation is currently under review, to mitigate the impact of the new population afinancial contribution towards new school places is required.

7.9.7 In the case of health facilities the PCT has advised the Council that improvementsto existing premises rather than any significant increase in capacity is required tomeet the extra demand. In terms of local community facilities whilst built provisionof facilities in the area surrounding the site is generally considered adequate theiroperation and facilities that are likely to be used and be of benefit to the occupantsof the proposed development require support. The applicant has agreed to makefinancial contributions to support the provision of additional Primary andSecondary school places together with improvements to existing healthcarepremises and community facilities to be secured through the Section 106agreement. This is considered acceptable and mitigate the impact arising from theadditional population

Playspace

7.9.8 Whilst the site is within an area of public open space deficiency it is not within anarea deficient in facilities for children and young people, as set out in theLewisham Leisure and Open Space Study (May 2010). As noted the ES estimatesa child yield of 70 children, requiring 700 square metres of playspace based on theGLA’s 10 square metres of playspace per child formula (980 square metres usingthe GLA play space child yield formula). The ES Addendum states that a total of1,387 square metres of playspace would be provided, not including the informalplayspace that would be provided in addition to play space within the linear parkfor designated child play. In addition, the square towards the southeast corner ofthe site, surrounded by blocks S and P, would be designated for play. Provision forolder age groups is also available further away (for example in Deptford Park).

7.9.9 With this provision, it is considered that the matter of on-site play space, and therequirements of UDP policy LCE 4, have been satisfactorily addressed.

7.10 Waste Management

7.10.1 London Plan policy 4A.21 (Waste strategic policy and targets) is consideredrelevant and Chapter 13 of the original ES deals with waste management. It statesthat excavation works at the application site would result in waste arisings, whichwould be minimised through the implementation of measures to be set out in a

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Site Waste Management Plan and a Construction Environmental ManagementPlan. In the ES Addendum it is clarified that no significant excavation work wouldbe required other than the removal of the site’s existing concrete slab, which wouldbe crushed on-site and reused to form hard pack surfacing. Some excavationwastes would also be generated as a result of the construction of undergroundsurface water storage, building foundations and possibly site contaminationremediation.

7.10.2 In order to mitigate the possible minor negative effect predicted by the applicant interms of waste generated during construction, in addition to crushing and reuse ofthe concrete slab, arisings would be tested to ascertain whether on-site reuse ispossible. For the completed development, waste arisings would comprise a mix ofmunicipal solid waste and commercial waste. Segregation and storage of wastefor recycling would be facilitated in the residential element. Space for recyclingwould similarly be provided for the commercial floorspace.

7.10.3 The applicant’s assessment of likely impact of waste arisings, waste disposalinfrastructure and waste management practices during the construction works andonce the proposed development is complete, is considered comprehensive andthe mitigation measures are considered acceptable.

7.10.4 Access for refuse collection in the completed development is discussed under theTransport sub-section of this report.

7.11 Microclimate – Wind

7.11.1 The applicant has opted for computational wind testing (or Computational FluidDynamics, CFD) of the proposed development, rather than physical model testing.The applicant’s testing, detailed in chapter 14 of the ES, has been assessed byBMT Fluid Mechanics on behalf of the Council’s consultant Capita Symonds.Whilst wind tunnel testing remains best practice, and is the most appropriatemethod for assessing wind impacts caused by developments that include tallerbuildings or that have layouts or contexts that may complicate wind impact, CFD isbecoming the industry standard. At Marine Wharf West it is considered that giventhe proposed heights and massing of the proposed development wind tunneltesting is not required.

7.11.2 Following concerns expressed by the Council’s environmental consultantregarding the wind assessment in the original ES the applicant provided revised aappendix 14.1 to chapter 14 in the ES Addendum. This included furtherinformation and assessment including a baseline scenario without the proposedCannon Wharf development. In the applicant’s opinion the results of the windassessments both for pedestrian comfort and safety indicate that the proposeddevelopment would have a negligible effect on the local wind environment and thatin some instances the wind environment would be improved. The applicant addsthat the results of the assessments also indicate that the wind environment of thesite with the proposed development in place, and with the Cannon Wharfdevelopment included would fall within the recommended criteria for pedestriansafety and comfort.

7.11.3 The Council’s consultant has advised that the proposed development massing issuch that conditions are generally expected to be suitable for pedestrian accessto, and passage through, the site and for pedestrian ingress and egress at buildingentrances, particularly if the indicated landscaping measures were implementedand the trees were of a species with substantial retained solidity in winter. The

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consultant also concluded that the proposed development was also unlikely tosignificantly impact on wind conditions within the surrounding area. They didhowever express concern about the recreational areas, particularly within thelinear park where the proposed landscaping would provide no direct shelter fromprevailing south-westerly and westerly winds. It is considered that this issue canbe addressed at conditions stage when details of the landscaping, including sitingand species of trees and any other structures, are approved.

7.11.4 In the light of these conclusions and the characteristics of the proposeddevelopment it is considered that the proposed development would not give rise tosignificant detrimental impacts in terms of wind.

7.12 Cumulative Effects

7.12.1 In chapter 15 of the ES the applicant considers the cumulative effects of thevarious effects set out in earlier chapters (“effect interactions”), and the cumulativeeffects of the proposed development and proposed developments at CannonWharf, Marine Wharf East, 19 Yeoman Street, Convoys Wharf, Oxestalls Road,Surrey Quays Leisure Site, Canada Water (sites A and B), Tavern QuayCommercial Centre, land at Downtown Road and Salter Road, and MulburyBusiness Park.

7.12.2 The applicant goes on to state in summary that the cumulative effects of theconsidered developments have the potential to be significant, but that during theconstruction phase will be short to medium term in nature, with both positive andnegative effects. The Council concurs with the assessment regarding constructionimpacts and that mitigation through construction management measures isappropriate. The Council considers that operational impacts i.e. on completion willalso include positive and negative impacts and it is considered that on balance theoverall impact is positive.

7.13 Residual Effects

7.13.1 Chapter 16 of the ES provides a summary table of the proposed development’seffects, including residual effects (i.e., the effects of the proposed developmentafter mitigation). Full details of mitigation measures proposed by the applicant areset out in each chapter of the ES (as amended).

7.13.2 Given that many of the development’s adverse effects would occur only during thesite preparation and construction period, and given that mitigation measures canbe secured through conditions and a Section 106 agreement attached to anyplanning permission for the proposed development, it is considered that overall theresidual effects of the proposed development are acceptable, and that planningpermission can be granted subject to the conditions and Section 106 agreementrecommended later in this report.

8. FINANCIAL VIABILITY AND DELIVERABILITY

8.1 Introduction

8.1.1 The application site forms part of the Plough Way Strategic Site, one of four that isidentified in the Draft Core Strategy as being a catalyst for regeneration of theDeptford and New Cross area through mixed use redevelopment. Development ofthe Marine Wharf West site has the potential to be a key component in theregeneration of the north of the borough, not simply because of the size of the site

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and its capacity for development but also because of its location in relation to otherdevelopment sites, the potential it offers for the repair of the disjointed landscapeand urban fabric around it, and the provision of connections of wider benefit to thenorth of the Borough and to LB Southwark.

8.1.2 Draft Core Strategy policy SSA1 sets out the requirements strategic sites includingthe need for a comprehensive masterplan and a delivery strategy setting out howthe development will be implemented and managed once occupied (includinghousing stock and publicly accessible space), any matters to be resolved such asland assembly and preparation, infrastructure requirements and delivery,development phasing and likely need for planning obligations (including financialcontributions) and/or conditions. It will also identify the likely need for public sectorintervention, by which agency and when.

8.1.3 A financial appraisal and delivery strategy for the Marine Wharf West site hasbeen submitted by the applicant in support of the application. The applicant is amajor house builder/developer (rather than land trader) who has developed andcontinues to develop other major sites in the wider area including the Venson sitein Lewisham and Ferrier Estate and the Woolwich Arsenal site in Greenwich.Whilst there can be no guarantee that they will commence or complete theproposed development as submitted they have stated they are committed todelivering the scheme despite its current poor financial state and that the currentfinancial strength of Berkeley’s parent company enables them to take such a view.They believe that by being the first developer to regenerate North Deptford, thequality of the Marine Wharf scheme will be key in creating a place where peoplewant to live. They go on to state that they have significant experience of creatingplaces where people want to live and invest in areas of regeneration acrossLondon, and this is a key strategy in the financial model to enable the delivery ofthe scheme.

8.2 Viability and Deliverability

8.2.1 The following considers viability and deliverability in the light of the informationprovided by the applicant and its assessment by the Council and its advisers

Financial Viability

8.2.2 The financial appraisal provides information on land purchase costs, build costs,sales values, and rents and yields for the commercial space as well ascomparables in terms of costs and values. This has been supplemented withadditional information in respect of the apportionment of abnormal site costsacross the phases.

8.2.3 The Council appointed external consultants to analyse the data includingbenchmarking costs against BCIS rates and consider the costs and salesvalues/rental levels that have been used. They conclude that whilst residentialbuild costs are higher than average they are within the BCIS range and based onthe evidence provided they are generally reasonable. Commercial rents and yieldsare comparable to those for similar space in the local area. The applicant hadinitially proposed discounted rents on the commercial space, however given thatthe full rents were comparable to those existing this has now been omitted.Accordingly the base information is generally considered acceptable.

8.2.4 Land purchase cost in the appraisal is set as a fixed amount based on theapplicant’s evidence. However this reflects values of a couple of years ago before

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the adjustments following the banking crisis and is considered to be above currentmarket levels. In the circumstances various scenarios have been run looking at theimpact on scheme viability of land values more in line with current prices. Whilstnot an Existing Use value (using the RICS Red Book definition), Valuation Officedata on land values in the area has been used as a proxy for this exercise and inthe absence of more detailed information this is considered a reasonable basis forthis assessment. The appraisal has also been reviewed in terms of the developer’sreturn which in current market conditions would be in the order of 15 to 20%.Scenarios have also been run using different levels of Section106 contribution.The scheme has been appraised on a cash flow basis to reflect the timing of costsand income from the scheme including financing (interest payments and credits).

8.2.5 Part of the cost of the scheme is involved in section 106 contributions to mitigatethe impact of the proposed development as well as the landscaping the route ofthe former Grand Surrey Canal as public open space. The canal works costs havebeen separately identified by the applicant and represent in-kind benefits of thescheme in delivering the Council’s wider objectives for the area as part of theNorth Lewisham Links initiative.

8.2.6 The findings of the Council’s viability consultants, and the appraisals provided bythe applicant will be forwarded to the GLA for their consideration when theapplication is referred back to them. The main findings of the review of theappraisal based on the proposed mix of uses are that,:

• Using the applicant’s costs and values the scheme shows a loss.• When a lower land purchase cost is used (based on an ‘existing use’ value

plus a 15% uplift) scheme viability improves however it is still not profitableat current build cost rates and sales values.

• Factoring in a growth in sales values over the course of the constructionperiod (approximately 5 years) the scheme could deliver a profit althoughthe level of return is below normally accepted levels and assumes asignificant level of growth.

8.2.7 It is relevant to note that as submitted the scheme does not provide affordablehousing or commercial space in line with London Plan and/or local policy in theadopted UDP and Core Strategy. A policy compliant scheme would show a moresignificant loss. It is also relevant to note that the applicant has made assumptionsabout grant funding for the Extra Care affordable housing in their appraisal,however this has not yet been applied for or secured. Accordingly a cascademechanism has been proposed based on reducing levels of grant whilstmaintaining the overall balance of costs and revenues. This is explained in moredetail in sub-section 6.4 of this report.

8.2.8 In addition the Section 106 package is below that indicated by the Council’sPlanning Obligations SPD and accordingly a review mechanism to secure fundingfor additional affordable housing should the scheme achieve specified salesvalues is proposed.

8.2.9 In the circumstances it is debateable whether a developer would undertake thescheme based on the appraisal figures, or that the current land owner would beable to recoup their land purchase costs if they sought to sell the site. Whilstfactoring in growth in residential sales values does indicate a positive return thedegree of market shift required to bring about a positive return would appear to besignificant. The applicant has stated however that they are committed to proceedon this basis.

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Land Ownership

8.2.10 Berkeley Homes own the freehold of the land defined by the planning applicationred-line boundary. The proposals (as amended) do however include twopedestrian links from the site onto adjacent land on the southern boundary; withCarteret Way and to the line of the former Grand Surrey Canal. Providing theseconnections was identified by the Council as important in both delivering the NorthLewisham Links Strategy as well as providing a route for residents to the southgaining access to Plough Way. The applicant has agreed to include these links inthe scheme.

8.2.11 In the case of the link to Carteret Way, this road is not adopted public highway andis controlled by Lewisham Homes who manage the housing stock and haveresponsibility for the public realm. Accordingly providing this link will be subject toa right of access being granted. Discussions have been held with LewishamHomes about gaining access between the site and Carteret Way and these areongoing. This link would be provided in phase 6 of the development, howevershould an access agreement not be signed by a set date then the link would beomitted. Details of the arrangements (including the need to remove two carparking spaces and associated re-landscaping on Carteret Way) will also need tobe approved. In the case of the link on the route of the former canal, the land tothe south is controlled by Lewisham Council and subject to a layout for this linkbeing agreed then continuous access from Oxestalls Road to Plough Way couldbe achieved (at present access is only possible as far as Rainsborough Avenue).

8.2.12 Subject to reaching agreement on these matters the Council is not aware of anythird party interests that would prevent or limit the implementation of the proposalsas submitted.

Phasing

8.2.13 Construction of the proposed development would be carried out in 7 phases, withthe first phase starting in Spring 2011 to be completed in April 2013 and the finalphase to be completed in January 2016 (see paragraph 3.11.1 above for furtherdetails). Given that essential elements of a mixed use and sustainable scheme(such as the affordable housing, a proportion of the non-residential uses, thelandscaping of the route of the former Grand Surrey Canal, the CHP facility andthe connection to Carteret Way) are to be provided or completed in later phases ofthe development, it is considered appropriate for the Council to seek somecertainty that the proposed development would be implemented as indicated in thephasing strategy and in full.

8.2.14 The applicant has included a Construction Programme as part of the ES whichindicates a continuous building programme over about 4 years to provide the 532units plus non-residential space and public realm works. The ConstructionProgramme identifies in some detail the sequencing of the development and thestages at which various non-residential uses will be provided, with projectedtimescales for each phase. This programme also reflected in the financial cashflow model for the scheme. Phase 1 includes 71 private residential units plus1,277 square metres of non-residential space including B1(c) and A1-A3 uses.Phases 2 and 3 (block C) will provide 111 private units, 78 Extra Care socialrented units, 2,775 square metres of non-residential floorspace and the site-wideenergy centre. Phases 4 to 7 would provide the remaining residential units,

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including the 25 shared ownership units in phases 5 and 6, and the last of theproposed business floorspace would be provided in phase 7 (block E).

8.2.15 The Programme has been supplemented by a phasing scheme for the provision ofthe open space on the route of the former Grand Surrey Canal which will beimplemented in parallel with the buildings on the western part of the site andcompleted at the same time. The first phase will ensure all the ground works andlaying out of the open space are undertaken at the beginning of the development.This will create a public route along the former canal towpath on completion ofPhase 1 of the development. This approach is welcomed and will mean that publicaccess to the route will be provided early in the development.

8.2.16 As already noted the applicant owns the freehold of the application site andsubject to receiving planning permission it is intended that they would commenceconstruction on this site in Spring 2011. In the circumstances it is considered thatthere is a reasonable prospect that the site will be developed comprehensively andin a timely manner.

8.2.17 The financial appraisal assumes an element of public sector funding to support theprovision of the Extra Care social rented units. It is understood that discussionshave been held with potential RSL operators of this space as well as with the HCAregarding funding. Until such time as a funding bid is submitted it is not possible tofirmly establish whether funding will be forthcoming. Accordingly officers havebeen in discussion with the applicant regarding a potential cascade mechanismwhereby social rented Extra Care units become ‘shared ownership’ units (forelderly people) in a form of equity release. Under this arrangement the 25 sharedownership units would be maintained as affordable housing. If no grant wereforthcoming when first submitted then the timing of the provision of the Extra Careunits would need to be reviewed in the first instance. The details of this arecurrently being negotiated as part of the detail of the Section106 agreement.

8.2.18 The provision of part of the non-residential space in Phase 1 and (subject tofunding) the social rented units in Phase 3 means that a mixed-use/mixed-tenuredevelopment is being developed on the site from an early stage. This approach iswelcomed and it is recommended that the Council requires that occupation of thefinal phase of residential space is linked to completion of the B1 space in thatphase. In the circumstances it is considered that there are various measures tosecure the delivery of a comprehensive scheme in accordance with the planningpermission.

Infrastructure

8.2.19 The proposed development will give rise to additional demands on existing socialinfrastructure (e.g. schools). Officers have been in discussion with the applicantregarding the key infrastructure requirements arising from the proposeddevelopment informed by the Council’s Infrastructure Delivery Plan and Scheduleand the Council’s Draft Planning Obligations Supplementary Planning Document.The applicant has agreed to make financial contributions towards infrastructure aswell as carrying out associated works (e.g. to the former Grand Surrey Canal) asan integral part of the proposed development. The scope and timing of thesefinancial contributions and works in kind are set out in Section 10 below.

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Housing Demand

8.2.20 The applicant has indicated a clear intention to commence development within arelatively short time after grant of planning permission and the provision of 454residential units (i.e. excluding Extra Care) will make a contribution to the housingtargets set out in the Draft Core Strategy. Whilst the Council cannot requirecommencement to start the applicant has indicated their intention to undertake thedevelopment.

8.2.21 The concept of Extra Care housing is a relatively new one in Lewisham and thereare currently 55 units elsewhere in the Borough. Provision of the 78 units in thisscheme will require formal agreements with relevant Council departments(including Strategic Housing and Adult Services) as well as an RSL over suchmatters as the nominations protocol and management of the space however theprinciple of Extra Care has been accepted by the Council as an appropriate formof provision in this part of the borough.

Non-Residential Uses

8.2.22 The applicant has submitted with their application an Employment Land Reportthat looks at the supply of and demand for business space in the locality. This issubmitted in part to seek to justify the level of B1 space being proposed for thesite. Relatively limited amounts of B1 space have been built in the local area inrecent years with few transactions and there are vacancies locally. There ishowever evidence of demand for well managed and appropriately priced space,albeit often in converted buildings rather than new build. Given the uncertaineconomic outlook the applicant is proposing that part of the B1 space is providedin Phase 1 with the balance in the last phase to a) avoid too much space comingonto the market and remaining unlet and b) to allow time for the new ‘hub’(comprising B1 and A1/A2/A3 retail space) to become established. This approachis considered acceptable subject to appropriate controls to ensure delivery of thesecond tranche of B1 space. It is understood that discussions with a potential foodstore operator to occupy the main A1 unit are underway. Occupiers of the B1space have not yet been identified however the rents included in the financialappraisal are considered reasonable for the location and type of space beingprovided and it has been concluded that the option of discounting rents for thisspace is not appropriate.

Management and Maintenance

8.2.23 A management and maintenance strategy for the site including roads, publiclyaccessible routes and open space and communal residential amenity and playspace is included in the heads of terms for a Section 106 agreement. Details of thestrategy will cover both how the relevant areas are to be managed and maintainedas well as the ongoing maintenance regime.

Other Legal Agreements and Consents

8.2.24 Part of the site (at the north western corner) is affected by a Thames Watereasement relating to the route of the Earl Pumping Station Storm Relief Sewerwhich runs roughly west-east from the Pumping Station on the corner of YeomanStreet/Chilton Street. This limits the scope for development above the sewer andthe application proposes that this area remains undeveloped with surface carparking only. This is considered an acceptable solution subject to landscaping ofthe perimeter as the car park will be visible along Plough Way. There is also an

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historical ‘right of way’ on the very north western edge of the site which may relateto the alignment of the towpath of the former Grand Surrey Canal however this ison private land and is understood not to be a public right of way. In thecircumstances it is considered that there are no other agreements relating to thirdparty land which would prevent implementation of the planning permission.

8.2.25 There is a need for some minor works on the public highway to provide a drop-off/servicing bay on Plough Way and the applicant has also agreed to provide newpedestrian crossing(s) on Plough Way (pedestrian refuges rather than signalcontrolled crossings) and therefore highways agreements under Sections 38 and278 of the Highways Act will be required.

Conclusion

8.2.26 Overall it is considered that there is a reasonable prospect of the schemeproceeding on this site and there are no other major impediments, for example interms of third party interests, to delivery of a comprehensive development for thesite. Whilst the scheme falls short on some policy matters it has beendemonstrated that the scheme could not afford to increase the amount ofcommercial space nor, at this time, the level of affordable housing.

8.2.27 Although the application is for only part of the Plough Way Strategic Site it hasbeen prepared in the context of a site-wide masterplan for the strategic site. Thisdemonstrates that the proposed development is compatible with the widermasterplan and would not prejudice the redevelopment of the entire strategic sitein a manner that would deliver the general and site specific objectives set out inthe Draft Core Strategy. In fact the application delivers site specific as well asstrategic objectives set out in the relevant Draft Core Strategy policy (SSA5) inproviding a key part of the North Lewisham Links strategy in this location as wellas initiating the process of regeneration and delivery of the strategic sites inDeptford. In this context and given the conclusions of the viability assessment,including the level of affordable housing and overall commercial space level aswell as the Section 106 provisions, it is considered the proposals are acceptableand will help deliver the objectives for the Plough Way Strategic Site set out in theDraft Core Strategy.

9. CONSIDERATION OF OBJECTIONS

9.1 Introduction

9.1.1 As noted at paragraph 4.31 above, written comments from were received from atotal of 14 addresses of local residents in response to the initial consultation andreconsultation. Responses are summarised at paragraph 4.32 above and in detailin Appendix 3. A summary of the key issues raised at the local meeting held on27/09/2010 is set out in Appendix 4.

9.1.2 The majority of matters raised are material planning considerations, and are

addressed in part 6 of this report.

9.1.3 One resident provided an assessment of the proposed development against theplanning policies of LB Southwark. The application can only be considered anddetermined with regard to the planning policies applicable to the site, and as theapplication site is entirely within LB Lewisham, the relevant policies are those ofthe Lewisham UDP, the London Plan, and national planning policies. Guidanceand emerging policies issued by LB Lewisham, the Mayor of London and the

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Government are also material considerations. The planning policies of LBSouthwark are not material considerations relevant to this application.

9.1.4 One resident made references to London Plan policies “3.12”, “3.13”, “3.20” and“3.22”, however as London Plan policy numbers are not formed in this way,officers are unable to identify what policies are being referred to.

9.1.5 One resident expressed concern that the submitted drawings would encouragepeople to walk through Transom Close as if it was a public right of way, howevertrespass onto private property is a civil matter and is not a reason for refusal ofpermission in this instance.

9.1.6 No written responses (to the Council’s initial consultation or reconsultation) werereceived from Lewisham PCT.

10. LEGAL AGREEMENTS

10.1 Introduction

10.1.1 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 basedon whether the application accords with the relevant development plan, unlessmaterial considerations indicate otherwise. Where applications do not meet theserequirements, they may be refused. However, in some instances, it may bepossible to make acceptable development proposals which might otherwise beunacceptable, through the use of planning conditions or, where this is not possible,through planning obligations. Accordingly, planning obligations can prescribe thenature of the development, compensate for or offset likely adverse impacts of thedevelopment, and mitigate the proposed development’s impact.

10.1.2 The Community Infrastructure Levy (CIL) Regulations 2010 puts the Government’spolicy tests on the use of planning obligations set out in Circular 05/2005 on astatutory basis for developments which are capable of being charged CIL. TheRegulations make it unlawful for a planning obligation to be taken into accountwhen determining a planning application for a development, that is capable ofbeing charged CIL (whether there is a local CIL in operation or not) if the obligationdoes 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

10.1.3 UDP policy IRM3 Community Benefit and Planning Loss and London Plan policies6A.4 (Priorities in planning obligations) and 6A.5 (Planning obligations) set out theCouncil’s approach to planning obligations. Whether a development makesappropriate provision for, or contribution towards, requirements that are madenecessary by, and are related to, the proposed development will be a materialconsideration relevant to the planning application being considered. Negotiationsshould seek a contribution towards the full cost of all such provision that is fairlyand reasonably related in scale and in kind to the proposed development and itsimpact on the wider area. Planning obligations should reflect strategic and localneeds.

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10.1.4 Given that the applicant proposes works to public highways, an agreement oragreements with LB Lewisham under Section 278 of the Highways Act 1980 withwould also be necessary, in addition to the Section 106 Agreement heads of termsset out below.

10.2 Planning Obligations (Section 106 Agreement)

10.2.1 In accordance with Circular 05/2005, the Council may only request and secure (inthe agreement) contributions that are needed to mitigate the development’simpacts and this, together with the Council’s Planning Obligations SPD hasinformed the Officers’ approach to negotiations. In the submitted PlanningStatement, the applicant offered their initial heads of terms, namely:

• Affordable Housing – obligation to secure on-site provision of 78 affordableextra care residential units;

• Employment – measures relating to affordability of commercial /employment accommodation;

• Transport / Accessibility – measures or financial contribution reasonablyrelated to providing new access to the Site and improvements to the localhighways network or access to public transport;

• Health Services – possible financial contribution reasonably related to thescale of the proposed development and the capacity of existing andemerging local facilities;

• Education – possible financial contribution reasonably related to the scaleand child yield of the proposed development and evidence as to thecapacity of local education facilities;

• Other Community Facilities – possible financial contribution towardimprovement of local community facilities;

• Open Space / Public Realm – on site provision of substantial open spaceareas, including public realm value of architectural and landscape design;

• Monitoring costs.

10.2.2 Officers considered that these heads of terms did not adequately address andmitigate all of the impacts of the proposed development nor provide sufficientcommitment to the proposed obligations and an extended list of heads of termswere therefore discussed with the applicant. The heads of terms set out underRecommendation A below (with appropriate timing to be agreed with the Council)take account of the proposed Planning Conditions set out below and the planningconsiderations in section 6-8 of this report, and are considered appropriate tosecure policy objectives, prescribe the nature of the development, compensate foror offset likely adverse impacts of the development, and mitigate the proposeddevelopment’s impact. These take account of comments raised by the GLA in theMayor of London’s Stage 1 comments. The main topics are:

1. Affordable Housing• 78 Extra Care social-rented units (29 x 1 bed, 49 x 2 bed) including

associated ancillary facilities• 25 shared ownership units (11 x 1 bed, 8 x 2 bed, 6 x 3 bed)• affordable housing supported by grant to be built to HCA space

standards, with no discernible difference in quality of externalappearance to private dwellings

• affordable housing to be provided as per submitted plans andconstruction phasing strategy

• provision of a cascade mechanism if grant is reduced

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• provision of a review mechanism to secure funding for affordablehousing if financial viable

2. Public Realm• implementation of landscaping works to the route of the former Grand

Surrey Canal (in general accordance with submitted plans, phasingstrategy and submitted costings)

• implementation of landscaping works to link the application site to theroute of the former Grand Surrey Canal to the south

• implementation of permanent pedestrian link to Carteret Way (subject tolong stop date for provision of a right of way)

• areas of public realm to remain available for use by the public• £70,000 contribution towards open space improvements (minor projects

within the vicinity of the site)• maintenance and management of the public realm in accordance with a

management plan agreed with the Council

3. Transport:• £350,000 towards transport-related measures including contributions

towards: public transport service improvements; public transportinfrastructure enhancements including bus stops within the vicinity of thesite; the Council’s monitoring of the Travel Plan; the cost of consultationon a CPZ in the local area (and occupiers of new dwellings not to beable to apply for parking permit for on-street parking bays should a CPZbe implemented)

• site-wide Travel Plans for residential and non-residential uses to besubmitted to and approved by Council

• provision of 5 car club spaces within site and free membership for 1 yearfor all occupiers of the site

• (g) submission, approval and implementation of a parking managementplan

• (h) implementation of works (under Section 278 agreement) to the publichighway

4. Social Infrastructure (Education and Health):• financial contribution of £1,080,000 to education (primary and

secondary)• financial contribution of £400,000 to improve existing health facilities in

the locality• financial contribution of £250,000 to support community facilities in the

locality

5. Local Labour and Employment:• implementation of a local labour scheme on site to be agreed with the

Council and provision of work experience for local people during theconstruction process

• £100,000 contribution to construction employment training

6. Residential Amenity:• communal private residential amenity areas to be maintained and

managed in accordance with a plan submitted to and approved by theCouncil.

7. Costs:

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• meeting the cost of external consultants appointed by the Council toassess and advise on proposed development

• meeting the Council’s legal, professional and monitoring costsassociated with the drafting, finalising and monitoring of the Agreement.

10.2.3 Officers consider that the obligations and financial contributions referred to aboveare appropriate in order to mitigate the impacts of the proposed development, andare in accordance with CIL regulations, Circular 05/2005 and Council policy. Thetotal financial package secured is below that using the amounts and calculationsset out in the Council’s Planning Obligations Draft SPD. However this needs to beseen in the context of advice from the government regarding the need for apragmatic approach to Section 106 negotiations, the financial viability of thescheme and the ‘in-kind’ benefits of the development including implementation ofpart of the North Lewisham Links project. Confidential viability information, whichhas been independently reviewed, has accompanied the application and this hasdemonstrated that the level of affordable housing proposed and the other financialcontributions that officers have negotiated is commensurate with the overallviability of the scheme.

11. CONCLUSIONS AND RECOMMENDATIONS

11.1 Introduction

11.1.1 The proposed development of the Marine Wharf West site raises issues relatingboth 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 proposeddevelopment and its impact on the local environment. This report has consideredboth matters in the light of development plan policies and other materialconsiderations including the information set out in the ES.

11.1.2 Although still emerging policy, Draft Core Strategy Policy SSA1 sets out anapproach regarding the process by which proposals for strategic sites shouldcome forward, that is in the context of a comprehensive masterplan for the entiresite. In this case the applicant has prepared a masterplan for the majority of thePlough Way site and this has been submitted as part of the Design and AccessStatement. The masterplan provides a framework and development principles forthe strategic site in terms of site layout and linkages across the area, on thelocation of commercial uses and on scale and massing of development across thesite. It is within this context that proposals for the Marine Wharf West site havebeen developed.

11.1.3 Officers consider that the masterplan analysis of the strategic site and its contextis based on an appropriate understanding of the problems, constraints andopportunities of this part of the borough and that the masterplan provides acoherent basis within which the strategic site can come forward. Officers considerthat development of the Marine Wharf West site as submitted would not prejudicethe redevelopment of the entire strategic site and would in fact deliver a number ofobjectives set out in the Draft Core Strategy. Although this approach is not fullyconsistent with the detailed requirements set out in the Draft Core Strategy, onbalance the Council is satisfied that the masterplanning material submittedprovides sufficient context within which to consider the current planning applicationand how its fits into the wider Plough Way Strategic Site, and the Council'saspirations and emerging policy for it. Therefore whilst the policies envisage asingle comprehensive redevelopment based on a single masterplan, for thereasons set out above, it is considered that the submitted masterplan

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demonstrates that policy SSA5 can be delivered by separate proposals for theindividual sites that make up the Plough Way Strategic Site. In the circumstancesit is concluded that the determination of a separate application for this part of thePlough Way Strategic Site is acceptable.

11.1.4 In terms of site specific issues these include: the change of the use of the site fromindustrial to mixed use incorporating a significant residential element; the height,massing and design of buildings and the impact that the development would haveon protected views and townscape; the ability of local transport and socialinfrastructure to cope with the level of change proposed; the accessibility of thescheme; the impact the development would have on the occupiers of surroundingproperties and the wider local environment; and the ability to deliver anenvironmentally sustainable development.

11.1.5 The proposed development does not comply with policy in a number of respects inparticular the level of affordable housing and employment floorspace, the provisionof living roofs and the lack of a connection to a district heating system andSELCHP. The proposed development would however provide much neededhousing and an element of affordable accommodation, and would improve theappearance of a large site. It has been demonstrated that the scale of thedevelopment is acceptable, that the buildings have been designed to respond tothe site’s context, constraints and potential and that the development will provide asatisfactory standard of accommodation. The proposed development would alsodeliver a key element of the Council’s strategy for the wider area in terms ofopening up pedestrian and cycle routes to connect the existing communities withinthis part of the borough.

11.1.6 For a development of this size, the proposals have attracted relatively fewobjections from the occupants of neighbouring properties. Those materialconcerns expressed by residents have been addressed in the conclusions made insection 6 of this report, and in provisions set out in the recommended conditionsand Section 106 agreement.

11.1.7 Officers consider that, with the recommended mitigation, planning conditions andobligations in place the scheme is broadly consistent with local and nationalpolicies (including the extant development plan) and is therefore recommended forapproval.

RECOMMENDATIONS

11.1.8 The recommendations to the Committee are set out below.

11.1.9 As the proposed development involves the creation of more than 5,000 squaremetres of floorspace at an out-of-centre site, and is not in accordance with one ofthe provisions of the relevant development plan, there is a requirement to refer theapplication to the Secretary of State at the appropriate regional government office(the Government Office for London) under the Town and Country Planning(Consultation) (England) Direction 2009 (paragraph 5). As noted at Section 4above, there is also a requirement to refer the application to the Mayor of London.

RECOMMENDATION (A)

11.1.10 To agree the proposals and refer the application, this report and any otherrequired documents to the Mayor for London (Greater London Authority) under

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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)

11.1.11 Subject to no direction being received from the Mayor of London, to refer theapplication to the Secretary of State at the appropriate regional government office(the Government Office for London) under the Town and Country Planning(Consultation) (England) Direction 2009 (paragraph 5), as a departure from thedevelopment plan involving the creation of more than 5,000 square metres offloorspace at an out-of-centre site.

RECOMMENDATION (C)

11.1.12 Subject to no direction being received from the Secretary of State, authoriseofficers to negotiate and complete a legal agreement under Section 106 of the1990 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 amendmentsas considered appropriate to ensure the acceptable implementation of thedevelopment:

1. Affordable Housing2. Accessible Housing3. Public Realm4. Transport:5. Social Infrastructure6. Local Labour and Employment7. Residential Amenity8. Meeting the Council’s legal, professional and monitoring costs

RECOMMENDATION (D)

11.1.13 Subject to completion of a satisfactory legal agreement, authorise the Head ofPlanning to GRANT PERMISSION for the reasons set out in paragraph 9.2 belowand subject to conditions including those set out in paragraph 9.3 below and suchamendments as considered appropriate to ensure the acceptable implementationof the development.

11.2 Summary of Reasons for Grant of Planning Permission

11.2.1 The decision to grant planning permission has been taken, having regard to thepolicies and proposals in the London Plan (Consolidated with Alterations since2004) (February 2008) and the adopted Unitary Development Plan (July 2004) asset out below, and all relevant material considerations, including commentsreceived in response to third party consultation.

11.2.2 The application was granted for the following reasons:

The Local Planning Authority has considered the particular circumstances of theapplication against relevant planning policy set out in The London Plan(Consolidated with Alterations since 2004) and saved policies in the Council’sadopted Unitary Development Plan (2004). The Local Planning Authority hasfurther had regard to the Mayor of London’s Supplementary Planning Guidanceand Best Practice Guidance, as well as the Local Planning Authority’s ResidentialStandards Supplementary Planning Document (August 2006), Government

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Planning Policy Guidance and Statements, and all other material considerationsincluding policies in the Draft Core Strategy, and the obligations that are to beentered into in the planning agreement in connection with the development and theconditions to be imposed on the permission. The Local Planning Authority has alsotaken account of the information set out in the Environmental Statement, theidentified impacts and proposed mitigation. The Local Planning Authorityconsiders that:

(1) The mixed use development of the site for A1, A2, A3, B1, B1c and C3 use isin accordance with London Plan policy 3B.4, which notes the potential forsurplus industrial land to help meet strategic and local requirements for a mixof other uses such as housing and social infrastructure, Lewisham UDP policyEMP 3 which allows for non-employment uses where nine criteria are met,and Lewisham UDP policy HSG 2 which promotes the development ofhousing on previously developed land. The objectives for the Plough WayStrategic Site set out in Draft Core Strategy policy SSA5 in respect of mixeduse development have been satisfactorily addressed within the context offinancial viability.

(2) The site is an appropriate location for a development of the density proposedin accordance with London Plan policy 3A.3, which seeks to ensure thatdevelopment proposals achieve the highest possible intensity of usecompatible with local context, identified design principles and public transportcapacity.

(3) The provision of residential accommodation at the density proposed at thissite is in accordance with London Plan policy 3A.3 which seeks to maximisethe potential of sites, and with Lewisham UDP policy HSG 2 which promotesthe development of housing on previously developed land and Draft CoreStrategy policy SSA5 which identifies the site as suitable for higher densitydevelopment.

(4) The layout of the site, the design of the development, and the provision ofhousing is in accordance with London Plan policy 3A.5 which seeks toachieve a range of housing choice, and with Lewisham UDP policy HSG 5,which requires that all new residential development is attractive, neighbourlyand meets the functional requirements of its future inhabitants.

(5) The proposed dwelling mix and provision of affordable housing, which iscontrolled by planning obligations agreed as part of the permission, isconsidered to be the maximum reasonable that can be achieved on this sitetaking account of targets and scheme viability and the need to encouragerather than restrain residential development in accordance with London Planpolicy 3A.10 regarding the provision of affordable housing, with LewishamUDP policy HSG 14 which seeks the provision of affordable housing includingon mixed use sites and HSG 15 which seeks the affordable housingcontribution to be provided in a way which assists in securing a morebalanced social mix, having regard to the financial viability of thedevelopment, as well as Draft Core Strategy policy 1 regarding housingprovision, mix and affordability. The proposal is also in accordance withLewisham UDP policy HSG 6 which seeks a mix of dwelling sizes determinedby reference to the housing needs of the area, the nature of the developmentand its proposed relationship to the surrounding area,.

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(6) The provision of new public realm and publicly accessible open space, andmitigation secured through planning obligations, is appropriate and complieswith London Plan policy 4B.3 which seeks high quality and accessible publicrealm, with London Plan policy 3D.13 and Lewisham policy LCE 4 whichseeks to provide attractive, safe and accessible places for children to play,and with Lewisham UDP policy URB 12 which requires the inclusion oflandscape proposals for all areas not occupied by buildings. The inclusion ofthe open space along the route of the former Grand Surrey Canal specificallyaddresses one of the key urban design principles for the masterplan for thePlough Way site in Draft Core Strategy policy SSA5.

(7) The energy demand of the proposed development has been assessed inaccordance with London Plan policies 4A.1, 4A.4 and 4A.6 and Draft CoreStrategy policy 8 regarding energy and carbon dioxide savings through alean, clean and green strategy.

(8) The proposed highway works including provisions for pedestrians, cyclistsand other road users and the overall traffic impact of the development havebeen assessed in accordance with Lewisham UDP policy TRN 2, and theidentified highway impacts and proposed mitigation measures secured byplanning conditions and obligations, are considered acceptable in accordancewith Lewisham UDP policies TRN 4, TRN 5, TRN 14, TRN 15, and TRN 16which require major schemes to provide access that take account of therequirements of public transport providers as well improvements to publictransport and facilities for cyclists and pedestrians.

(9) The proposed level of cycle parking and associated measures to reduce caruse are in accordance with Lewisham UDP policies TRN 5, TRN 14 and TRN23 (and the related Table TRN 2), as well as Draft Core Strategy policy 14regarding sustainable movement and transport. Measures to reduce car use,provide off-street parking, provide ‘car club’ spaces and membership and tosubmit Travel Plans are proposed to be secured by planning obligationsagreed as part of the permission and by conditions.

(10) The regeneration benefits inherent in the scheme and the financialcontributions towards achieving other planning policy objectives are inaccordance with Lewisham UDP policy IRM 3 which seeks the inclusion ofcommunity benefits as part of development proposals, with London Planpolicies 6A.4 and 6A.5, and Draft Core Strategy policy 21 regarding planningobligations.

11.2.3 Consideration has also been given to the objections made to the proposeddevelopment, at set out in Sections 6 and 7 above. It is considered that none ofthe material objections outweigh the reasons for granting planning permission.

11.3 Conditions

11.3.1 The Planning Conditions referred to in Recommendation D are as follows:

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General

1. Approved drawings and documents

Unless minor variations are otherwise approved in writing by the local planningauthority, the Development shall be carried out strictly in accordance with thefollowing application documents, plans or drawings hereby approved:

(PL)001 rev A, (PL)002 rev A, (PL)003 rev A, (PL)004 rev A, (PL)100 rev A,(PL)101 rev A, (PL)102 rev A, (PL)103 rev A, (PL)104 rev A, (PL)110 rev A,(PL)111 rev A, (PL)112 rev A, (PL)113 rev A, (PL)114 rev A, (PL)115 rev A,(PL)116 rev A, (PL)117 rev A, (PL)120 rev A, (PL)121 rev A, (PL)122 rev A,(PL)123 rev A, (PL)124 rev A, (PL)125 rev A, (PL)126 rev A, (PL)130 rev A,(PL)131 rev A, (PL)132 rev A, (PL)133 rev A, (PL)134 rev A, (PL)135 rev A,(PL)136 rev A, (PL)137 rev A, (PL)200 rev A, (PL)201 rev A, (PL)202 rev A,(PL)202 rev A, (PL)203 rev A, (PL)204 rev A, (PL)205 rev A, (PL)206 rev A,(PL)207 rev A, (PL)208 rev A, D1788.L.200 rev E, D1788.L.201 rev D,D1788.L.400 rev C, Planning Statement (Indigo Planning, January 2010) asamended/supplemented by Indigo Planning letter dated 19/08/2010 andAccommodation Schedule received 20/08/2010; Design and Access Statement(Hamiltons, January 2010) as amended/supplemented by Addendum Design andAccess Statement (Grid Architects, August 2010); Environmental Statement NonTechnical Summary (WSP, January 2010); Environmental Statement Volume 1:Main Text and Figures (WSP, January 2010) as amended/supplemented byEnvironmental Statement Addendum (WSP, August 2010); EnvironmentalStatement Volume 2: Technical Appendices (WSP, undated, received February2010) as amended/supplemented by Environmental Statement Addendum (WSP,August 2010); Transport Assessment (Savell Bird and Axon, January 2010) asamended/supplemented by Transport Assessment Addendum (Savell Bird andAxon, August 2010); Transport Assessment Appendices (Savell Bird and Axon,January 2010); Employment Land Report (Colliers CRE, January 2010);Landscaping Design Statement (Fabrik, January 2010) as amended/supplementedby Addendum Landscaping Design Statement (Fabrik, August 2010); Daylight andSunlight Report (Drivers Jonas, January 2010) as amended/supplemented byDaylight and Sunlight Addendum (Drivers Jonas, August 2010); Energy StatementReport (Meinhardt, October 2010); Revised Drainage Strategy Report (Meinhardt,August 2010); Tree Survey Report and Arboricultural Impact Assessment (TreeFabrik, January 2010); Clarification to Townscape and Visual Impact AssessmentPlans and Photographs (Fabrik, July 2010); Visually Verified Montages (VVMs)Methodology Statement (Glass Canvas, undated); and confidential viabilityinformation received 15/07/2010.

Reason

To ensure that the development is carried out in accordance with the approveddocuments, plans and drawings submitted with the application (or otherdocuments, plans and drawings subsequently approved in writing by the localplanning authority) and to ensure that the development is acceptable to the localplanning authority.

2. Time limit

The development must be begun not later than three years from the date of thegrant of this permission.

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Reason

To comply with Section 91 of the Town and Country Planning Act 1990.

3. Restriction of A1 floorspace

No individual retail unit within Class A1 shall exceed 350 square metres (grossinternal area).

Reason

To ensure that the amount of A1 floorspace provided at the site does not adverselyaffect the viability and vitality of existing town and district centres, and to complywith Policies STC 2 Location of New Stores (Sequential Test) in the adoptedUnitary Development Plan (July 2004) and 3D.1 Supporting Town Centres in theadopted London Plan (February 2008).

Details

4. Detail for all phases

No phase of the development shall be commenced until details of the followingmatters in respect of that phase have been submitted to and approved in writing bythe local planning authority:

i) detailed elevational drawings and sections to a scale of 1:50 and 1:100ii) details of 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 proposeddevelopment.

5. External materials (buildings)

No development shall commence on any phase until details of all facing materials(including their colour and texture) to be used on the building(s) in that phase havebeen submitted to and approved in writing by the local planning authority. Thedevelopment shall be carried out in accordance with the approved details, unlessthe local planning authority agrees in writing to any variation.

Reason

To ensure that the Development is of a satisfactorily high design standard toensure that it makes a positive contribution to the appearance of the locality and tocomply 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 detailsof directional hoods and measures to prevent light spillage, shall be submitted to

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and approved in writing by the local planning authority not later than six monthsfollowing the commencement of that phase.

(ii) All such external lighting shall be installed in accordance with the approveddetails before any dwelling in the relevant phase is occupied and thereafter anyexternal lighting (including any directional hoods) shall be retained in accordancewith the approved details.

(iii) Details submitted for approval pursuant to paragraph (i) of this condition, shallbe accompanied by a supporting statement which demonstrates that the proposedlighting is the minimum needed for security and working purposes and that theproposals minimise pollution from glare and spillage.

Reason

To ensure that the lighting is installed and maintained in a manner which willminimise possible light pollution to neighbouring properties and to comply withPolicies ENV.PRO 12 Light Generating Development and HSG 4 ResidentialAmenity in the adopted Unitary Development Plan (July 2004).

7. Shopfronts

(i) Details of the ground floor level and double-height shopfronts to the non-residential accommodation hereby approved shall be submitted to and approved inwriting 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 providesadequate access for everyone, particularly people with disabilities and to complywith Policy URB 8 Shopfronts in the adopted Unitary Development Plan (July2004).

8. Lifetime Homes and wheelchair accessible/adaptable units

No phase of the development shall commence on site until drawings for eachdwelling type in that phase demonstrating compliance with Lifetime Homesstandards has been submitted to and approved in writing by the local planningauthority.

The development shall be constructed in accordance with the approved drawingsand on completion of the development not less than 95 of the dwellings shall bewheelchair accessible or shall be easily adaptable for wheelchair users (designedto SELHP August 2009 standards) in accordance with drawings submitted to andapproved in writing by the local planning authority.

Reason

In order to comply with the requirements of Section 76 of the Town and CountryPlanning Act 1990 which relates to the provision of satisfactory access to buildingsfor people with disabilities and to comply with Policy HSG 5 Layout and Design ofNew Residential Development in the adopted Unitary Development Plan (July2004).

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Sustainability

9. Code for Sustainable Homes

No dwelling hereby approved shall be occupied until a Code for SustainableHomes Level 3 post-construction certificate and verified Code for SustainableHomes report for that dwelling has been submitted to and approved in writing bythe local planning authority.

Reason

To ensure the use of sustainably-sourced and recycled materials and aggregatesand the sustainable use of water, and to meet the requirements of Policies 4A.3Sustainable Design and Construction and 4A.16 Water Supplies and Resources inthe adopted London Plan (February 2008).

10. BREEAM

The non-residential floorspace hereby approved shall not be occupied until aBREEAM 2008 Excellent design and procurement certificate and report has beensubmitted to and approved in writing by the local planning authority. A postconstruction certificate to demonstrate compliance with the design andprocurement assessment shall be submitted to the local planning authority within 3months of the occupation of the non-residential floorspace.

Reason

To meet the requirements of Policies 4A.3 Sustainable Design and Constructionand 4A.16 Water Supplies and Resources in the adopted London Plan (February2008).

11. Future connection to a district CCHP or CHP scheme

No development shall commence on site until written information, drawings andsections showing a scheme for the provision of conduits and/or piping for futureconnection to a district CCHP or CHP scheme and network have been submittedto and approved in writing by the local planning authority. No residential units inblock S shall be occupied until the scheme has been carried out in accordancewith the approved details.

Reason

To enable the future connection of the development to a district CCHP or CHPscheme and network, and to comply with Policy 4A.6 (Decentralised Energy:Heating, Cooling and Power) in the London Plan (February 2008) Consolidatedwith Alterations Since 2004.

12. Living Roofs

Development on a particular 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

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of management) for that phase have been submitted to and approved in writing bythe local planning authority.

No part of the relevant phase shall be occupied until the living roofs forming part ofthe approved scheme have been implemented in full, and the living roofs shall beplanted or seeded with the approved mix of species within the first planting seasonfollowing the practical completion of building works. The living roofs shall not beused for play or recreation and shall only be used in the case of essentialmaintenance or repair, or escape in case of emergency. The living roofs shall bemaintained as such thereafter and no change therefrom shall take place withoutthe prior written consent of the local planning authority.

Reason

To ensure the development provides the maximum possible provision of livingroofs to enable the creation of habitats and areas for biodiversity and to reduce therate and volume at which rainwater reaches watercourses in times of heavy orprolonged rainfall, in accordance with Policies OS 13 Nature Conservation andENV.PRO 15 Sustainable Surface Water Drainage in New Development in theadopted Unitary Development Plan (July 2004), Policies 3D.14 Biodiversity andNature Conservation, 4A.3 Sustainable Design and Construction, 4A.9 Adaptationto Climate Change, 4A.11 Living Roofs and Walls and 4A.14 Sustainable Drainagein 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 beprovided and reserved for Car Club use shall be submitted to and approved inwriting by the local planning authority before the commencement of the phase(s) inwhich they are located.

(ii) The said spaces shall be provided and made available for use before any partof the relevant phase is occupied. Thereafter the spaces shall be retained andused only for parking cars associated with the Car Club.

Reason

To limit car ownership/use and encourage sustainable modes of transport inaccordance with Policies 3C.3 (Sustainable transport in London) and 3C.23(Parking Strategy) in the approved London Plan (Consolidated with Alterationssince 2004 (February 2008).

14. Electric Vehicle Charging Points

(i) Details of electric vehicle charging points to be provided in each phase and aprogramme for their installation and maintenance shall be submitted to andapproved in writing by the local planning authority prior to commencement of thephase within which they are to be located.

(ii) The electric vehicle charging points as approved shall be installed prior to firstoccupation of the relevant phase and maintained in accordance with the detailsapproved under (i).

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Reason

To reduce pollution emissions in an Area Quality Management Area in accordancewith 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 ofcomposting facilities) for each phase shall be submitted to and approved in writingby the local planning authority no later than three months following thecommencement of that phase.

(ii) The development of each phase shall be carried out and operated inaccordance with the approved WMP relating to that phase unless minor variationsare otherwise approved in writing by the local planning authority.

Reason

To ensure that waste is minimised as far as practicable and managed in anenvironmentally sustainable way and to comply with Policy 4A.21 (Waste strategicpolicy and targets) in the London Plan.

Residential Amenity

16. Noise Insulation

Details for each phase, including relevant drawings and specifications of:-

(a) The construction of the ceilings and walls separating the residential andnon-residential uses hereby permitted and

(b) The proposed works of soundproofing against airborne and impact soundand vibration

shall be submitted to and approved in writing by the local planning authority prior tocommencement of the relevant phase.

The uses hereby permitted shall not commence in that phase until thesoundproofing works have been implemented in accordance with the approveddetails. The soundproofing shall be retained permanently in accordance with theapproved details.

Reason

To ensure a satisfactory environment for the residential occupiers of thedevelopment and so as to comply with Policy ENV.PRO11 (Noise GeneratingDevelopment) in the adopted Unitary Development Plan (July 2004).

17. Noise and vibration from fixed plant and machinery

(i) The rating level of the noise emitted from fixed plant and machinery on thedevelopment including the CHP plant shall be 5dB below the existing backgroundlevel at any time, as measured at the façade of any noise sensitive receptor. Themeasurements and assessments shall be made according to BS4142:1997.

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(ii) For any particular phase, the design, operation and maintenance details of ascheme for compliance with paragraph (i) of this Condition shall be submitted toand approved in writing by the local planning authority within three months ofcommencement of that phase.

(iii) No phase shall be occupied until the approved scheme has been implementedin its entirety in relation to that phase.

(iv) Thereafter, the approved scheme shall be retained and maintained inaccordance with the approved details.

Reason

To ensure a satisfactory environment for the occupiers of the development and soas to comply with Policy ENV.PRO11 (Noise Generating Development) in theadopted Unitary Development Plan (July 2004).

18. A3 hours of use

Any A3 use within the site shall not be open to the public other than between thehours of 8.00am and 11.00pm on any day of the week.

Reason

To ensure that the development does not prejudice the enjoyment by neighbouringoccupiers of their properties and to comply with Policies ENV.PRO 11 (NoiseGenerating Development) and HSG 4 (Residential Amenity) in the adopted UnitaryDevelopment Plan (July 2004).

19. A3 ventilation

No A3 use shall be fitted out or commence on site until detailed plans and aspecification of the equipment comprising a ventilation system which shall includemeasure to alleviate noise, vibration, fumes and odours (and incorporating activecarbon filters, silencer(s) and anti-vibration mountings where necessary), havebeen submitted to and approved in writing by the local planning authority. Theventilation system shall be installed in accordance with the approved plans andspecification before the A3 use commences and shall thereafter be permanentlymaintained in accordance with the approved specification.

Reason

To ensure that the proposed development does not prejudice the enjoyment byneighbouring occupiers of their properties and to comply with Policies ENV.PRO11 Noise Generating Development, HSG 4 Residential Amenity and STC 9Restaurants, A3 Uses and Take Away Hot Food Shops in the adopted UnitaryDevelopment Plan (July 2004).

20. A1, A2 and A3 delivery hours

No deliveries shall be made to any A1, A2 or A3 use within the site other thanbetween the hours of 7.00am and 11.00pm Monday to Friday, 7.00am to 7.00pmon Saturdays and 7.00am to 5.00pm on Sundays and Bank Holidays.

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Reason

To ensure that the development does not prejudice the enjoyment by neighbouringoccupiers of their properties and to comply with Policies ENV.PRO 11 (NoiseGenerating Development) and HSG 4 (Residential Amenity) in the adopted UnitaryDevelopment Plan (July 2004).

21. Air quality

No development on phase 2 shall commence on site until an updated air qualityassessment, including details and specifications of the CHP facility, have beensubmitted to and approved in writing by the Council. The CHP facility shall beconstructed in accordance with the approved details and specifications, unlessminor variations are approved in writing by the local planning authority.

Reason

To reduce pollution emissions in an Area Quality Management Area in accordancewith London Plan Policy 4A.19 (Improving air quality).

Landscaping

22. Landscaping details

No development of any phase shall commence on site until drawings showing hardand soft landscaping of any part of the site not occupied by buildings, including anyretained features, and the treatment thereof (including planting, tree species andlocation, paving, walls and fences, temporary and permanent site boundarytreatments), details of the permeability of hard surfaces, and details of themanagement and maintenance of the landscaping for that phase, have beensubmitted to and approved in writing by the local planning authority.

All works which form part of the landscaping scheme shall be completed in the firstplanting season following the completion of that phase, unless the local planningauthority has given written consent to any variation. Any trees or plants whichwithin a period of 5 years from the completion of the development die, are removedor become seriously damaged or diseased, shall be replaced in the next plantingseason with others of similar size and species, unless the local planning authorityhas given written approval to any variation.

Reason

In order that the local planning authority may be satisfied as to the details of theproposal and to comply with Policies URB 3 Urban Design, URB 12 Landscapeand Development and URB 13 Trees in the adopted Unitary Development Plan(July 2004).

23. Ecological enhancement

Development shall not commence until a site-wide strategy for ecologicalenhancement and mitigation including a habitat management plan setting outdetails of monitoring arrangements has been submitted to and approved in writingby the local planning authority. The habitat management plan will be implementedin full as approved.

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Reason

In order that the local planning authority may be satisfied as to the details of theproposal and to comply with Policies URB 3 Urban Design, URB 12 Landscapeand Development and OS 13 Nature Conservation in New Development in theadopted Unitary Development Plan (July 2004), and Policy 3D.14 (Biodiversity andnature conservation) in the London Plan.

24. Trees – protection during construction

No development of any phase shall commence on site until adequate steps havebeen taken in accordance with Section 8 of BS 5837:2005 Trees to safeguard alltrees to be retained within or adjacent to that phase against damage, prior to orduring building works, including the erection of fencing. These fences shall beerected to the extent of the crown spread of the trees, or where circumstancesprevent this, to a minimum radius of 2 metres from the trunk of the tree and suchprotection shall be retained until the development has been completed. Noexcavations, site works, trenches or channels shall be cut, or pipes or services laidin 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 thevisual amenities of the area generally and to comply with Policies URB 3 UrbanDesign, URB 12 Landscape and Development and URB 13 Trees in the adoptedUnitary Development Plan (July 2004).

Archaeology and Heritage

25. Archaeology

No development shall take place on the site until the applicant, or any successorsin title, has secured the implementation of a programme of archaeological work inaccordance with a written scheme of investigation, observation and recordingwhich has been submitted to and approved in writing by the local planningauthority.

Reason

To ensure adequate access for archaeological investigations and to comply withPolicy URB 21 Archaeology in the adopted Unitary Development Plan (July 2004).

26. On-site heritage assets

All stones, bricks and paving materials that formed part of the original GrandSurrey Canal towpath and canal edge and that are intact and remain on site shallbe retained and reused in the landscaping of the linear park, unless the localplanning authority agrees in writing to any variation.

Reason

To ensure that heritage assets remaining on site are retained and reused in thedevelopment.

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Construction Management

27. Construction Management Plan

(i) No works (including demolition and construction) shall commence in each phaseuntil a Construction Management Plan, including details of hours of works, wheelwashing, dust minimisation, noise mitigation relating to on-site crushing, anddeliveries, details of compliance with the relevant Code of Construction Practice,and incorporating a Construction Traffic Management Plan, Construction LogisticsPlan and Construction Environmental Management Plan, in respect of that phasehas been submitted to and approved in writing by the local planning authority.

(ii) No works (including demolition and construction) in the relevant phase shall becarried out other than in accordance with the approved Construction ManagementPlan.

Reason

To ensure that the demolition and construction processes are carried out in amanner which will minimise noise, vibration, dust and mud pollution and minimisedisturbance from road traffic and safeguards road safety and the amenities ofadjacent occupants in accordance with Policies ENV.PRO 9 Potentially PollutingUses, ENV.PRO 11 (Noise Generating Development) and HSG 4 (ResidentialAmenity) in the adopted Unitary Development Plan (July 2004) and that allreasonable measures have been taken to improve construction freight efficiency byreducing CO2 emissions, congestion and collisions in accordance with PolicyTRN20 (Improving Road Safety) in the adopted Unitary Development Plan (July2004) and Policy 3C.25 (Freight Strategy) in the approved London Plan(Consolidated with Alterations since 2004 (February 2008).

Flood Risk

28. Flood risk

The development shall be carried out in accordance with the Flood RiskAssessment dated January 2010 appended to the ES as amended by the FloodRisk Assessment Addendum dated August 2010 and appended to the ESAddendum.

Reason

To ensure the development minimises risk associated with flooding in accordancewith Policy ENV.PRO 15 (Sustainable Surface Water Drainage in NewDevelopment) in the adopted Unitary Development Plan (July 2004) and Policy4A.13 (Flood risk management) in the approved London Plan (Consolidated withAlterations since 2004 (February 2008).

29. Surface water

(i) No phase shall commence until a scheme of surface water management,including specifications of the surface treatments and sustainable urban drainagesolutions, has been submitted to and approved in writing by the local planningauthority, in consultation with the Environment Agency and Thames Water.

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(iii) Each phase shall be carried out in accordance with the approved scheme forthat phase and thereafter the approved scheme is to be retained in accordancewith the details approved therein.

Reason

To prevent the increased risk of flooding and to improve water quality inaccordance with Policy ENV.PRO 15 (Sustainable Surface Water Drainage in NewDevelopment) in the adopted Unitary Development Plan (July 2004) and Policy4A.12 (Flooding) in the approved London Plan (Consolidated with Alterations since2004 (February 2008).

Contamination

30. 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 extentof potential contamination and its effect (whether on or off site);

(ii) a report comprising the results of that site investigation andrecommendations for treatment of any contamination (whether by remedialworks or not) has been submitted to and approved in writing by the Council;and

(iii) all measures or treatments identified in that report as being necessary ordesirable 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 thiscondition [“paragraph a„] or implementation of this planning permission generally)contamination is encountered which has not previously been identified (“the newcontamination„), then paragraph (a) shall apply to the new contamination and nofurther development shall take place until the requirements of paragraph (a) havebeen complied with in relation to the new contamination.

(c) The development shall not be occupied until a closure report has beensubmitted to and approved in writing by the Council. The closure report shallinclude details both of the remediation (including waste materials removed from thesite, an audit trail demonstrating that all imported or reused soil material conformsto current soil quality requirements as approved by the Council) and any post-remediation sampling that has been carried out.

Reason

To ensure that the local planning authority may be satisfied that potential sitecontamination 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.PRO10 Contaminated Land in the adopted Unitary Development Plan (July 2004).

31. Piling operations

(i) Piling or any other foundation designs using penetrative methods shall not bepermitted, other than with the prior written consent of the local planning authority.

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Any such application for consent shall be accompanied by details of the relevantpenetrative methods.

(ii) The said piling shall be carried out only in accordance with the written consentof the local planning authority.

Reason

To prevent pollution of controlled waters and to comply with Policies ENV.PRO 10Contaminated Land and ENV.PRO 17 Management of the Water Supply in theadopted Unitary Development (July 2004).

Parking

32. Use of car parking

i) All car parking spaces within the development shall be reserved for and used byvehicles of the occupiers or users of the development only.

ii) No phase shall be occupied until details of the allocation of the car parkingspaces to the uses within that phase have been submitted to and approved inwriting by the local planning authority.

Reason

To ensure the permanent retention of the space(s) for parking purposes, to ensureuses within each phase are not over-provided with car parking spaces, to ensurethat the development does not increase on-street parking in the vicinity and tocomply with Policy TRN 26 Car Parking Standards in the adopted UnitaryDevelopment Plan (July 2004).

33. Cycle parking

(i) A minimum of 558 cycle parking spaces shall be provided within thedevelopment, as follows:-

a. Within block N – 34 spacesb. Within block E – 91 spacesc. Within block C – 184 spacesd. Within block S – 213 spacese. Within block P – 27 spacesf. Within houses – 9 spaces

(ii) A minimum of 20 visitors’ cycle parking spaces shall be provided.

(ii) No phase shall be occupied until the cycle parking spaces to be provided withinthat phase have been provided and made available for use. Thereafter, suchspaces shall be retained and used only as cycle parking for use as provided for inparagraphs (i) and (ii) of this Condition.

Reason

In order to ensure adequate provision for cycle parking and to comply with PoliciesTRN 14 (Cycle Parking) and TRN 15 (Provision for Cyclists and Walkers) in theadopted Unitary Development Plan (July 2004).

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34. Motorcycle parking

(i) A minimum of 11 motorcycle parking spaces shall be provided within thedevelopment.

(ii) No phase shall be occupied until the motorcycle parking spaces to be providedwithin that phase have been provided and made available for use. Thereafter suchspaces shall be retained and used only as motorcycle parking for use as providedfor in paragraph (i) of this condition.

Reason

In order to ensure adequate provision for motorcycle parking and to comply withPolicy TRN 28 (Motorcycle Parking) in the adopted Unitary Development Plan (July2004).

Informatives

1 Applicants should be aware of their responsibilities under Part IIA of theEnvironmental Protection Act 1990 to ensure that human health, controlledwaters and ecological systems are protected from significant harm arisingfrom contaminated land. Guidance therefore relating to their activities onsite should be obtained primarily by reference to DEFRA and EApublications.

2 Assessment of the scheme required by Condition 17 (Noise from fixed plantand machinery) must be carried out by a suitably qualified acousticconsultant.

3 With regard to Condition 27, the Construction Management Plan will berequired to confirm that no deliveries to the site in connection withdemolition or construction works shall take place outside the hours of 8 amand 6 pm on Mondays to Fridays and 8 am and 1 pm on Saturdays and thatno such deliveries shall take place at all on Sundays or public holidays.

4 With regard to Condition 27, the relevant Code of Construction Practice canbe viewed online at:http://www.lewisham.gov.uk/Environment/Pollution/PollutionNoiseDocument.htm

5 Your attention is drawn to comments provided by Thames Water on09/09/2010 regarding drainage and infrastructure capacity.