Item No.

6.3

Classification: Open

Date: 7 May 2013

Meeting Name: Planning Committee

Report title:

Development Management planning application: Application 12/AP/3558 for: Full Planning Permission Address: 90-91 AND 92 BLACKFRIARS ROAD, LONDON SE1 8HW Proposal: Demolition of existing buildings and erection of a replacement building of five to eight storeys in height (max height of 27.5m), plus basement, comprising 53 residential units, 633 sqms of retail floorspace (Use Class A1) and 767 sqms of office floorspace (Use Class B1), disabled parking spaces and roof top landscaped amenity areas.

Ward(s) or groups affected:

Cathedrals

From: Head of Development Management

Application Start Date 21/11/2012 Application Expiry Date 20/02/2013

RECOMMENDATION

1 That permission is granted subject to conditions, and the applicant first entering into an appropriate legal agreement no later than 3 June 2013. In the event that the legal agreement is not entered into by 3 June 2013, the head of development management be authorised to refuse planning permission for the reasons set out in paragraph 70 of the report.

BACKGROUND INFORMATION Site location and description

2 The site, measuring 0.13 hectares, is located on the east side of Blackfriars Road,

between its junctions with Ufford Street and Boundary Row. It comprises two existing commercial buildings: a part three storey, part single storey building fronting Blackfriars Road and Ufford Street and a four storey building on the corner of Blackfriars Road and Boundary Row. There is an existing private parking area at the rear of the site with vehicular access onto Ufford Street. The site adjoins a four storey office building fronting onto Boundary Row.

3 The surrounding area comprises a mixture of residential and commercial properties of varying ages and architectural styles. A Georgian terrace is located to the north of the site fronting onto Blackfriars Road, the majority of which is Grade II Listed. A modern part two/part five storey brick extension to the terrace has been constructed siding onto Ufford Street. Single storey buildings forming part of Southwark College are located on the opposite site of Ufford Street facing the site at the rear. A modern five

storey office building is located on Blackfriars Road to the south adjacent to which is a newly constructed seven storey office building.

4 The four storey Sons of Temperance Friendly Society building is located on the opposite side of Blackfriars Road facing the application site adjacent to which is a twelve storey residential apartment building (Helen Gladstone House) which is set back from the road frontage behind a small garden area.

5 The site is located within the Central Activities Zone, the Borough, Bankside and London Bridge Opportunity Area and the Bankside and Borough District Town Centre.

Details of proposal

6 The application proposes the demolition of the existing buildings and the redevelopment of the site to provide for 53 residential units, 643 sqms of retail (A1) floor space and 724 sqms of business (B1) floor space. The retail unit is proposed at ground and basement levels at the front of the building with the business floor space proposed at basement, ground and mezzanine levels to the rear. The proposed density amounts to 1546 habitable rooms per hectare.

7 Excluding the basement area, the replacement building will range from a maximum of eight storeys (max height of 27.4m) fronting Blackfriars Road down to five storeys at the rear of the site.

8 Ten of the residential units are proposed as affordable accommodation comprising eight two/three-bedroom social rent units along with two one-bedroom shared ownership units, amounting to 21% of the total habitable rooms. Six of these will be wheelchair units. Three parking spaces for disabled residents are proposed at the rear of the scheme with access from Boundary Row. Cycle parking is provided within the building in the basement for the private residential units and at ground floor level for the affordable housing and commercial uses.

Planning history

9 There is no relevant planning history for this site. Planning history of adjoining sites

10 Planning permission was granted in March 2012 (11/AP/413) for extensions at second

to fourth floor level and other alterations to provide seven residential units, retail and office floor space at 88-89 Blackfriars Road (immediately to the north of the application site). This permission has not been implemented although it remains extant until March 2015.

11 Planning permission was granted in 2010 and has been recently implemented for a maximum seven storey building comprising retail use at ground floor level with offices above at 102-107 Blackfriars Road, approximately 50 metres to the south of the application site.

KEY ISSUES FOR CONSIDERATION

Summary of main issues

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

a) The loss of the existing business floor space and the acceptability in principle of the replacement floor space.

b) The design and appearance of the building including how it relates to existing

development in Blackfriars Road and the surrounding locality. c) Impact upon the setting of the adjacent conservation area and listed buildings. d) The acceptability of the proposed housing mix and quality of accommodation

provided within the development. e) The impact on the living conditions of neighbouring residential properties. f) The provision of affordable housing within the scheme. g) Transportation impacts. h) Energy and sustainability. i) Planning obligations.

Planning policy

13 Core Strategy 2011 Strategic Targets Policy 1 - Achieving growth Strategic Targets Policy 2 - Improving places Strategic Policy 1 - Sustainable development Strategic Policy 2 - Sustainable transport Strategic Policy 3 - Shopping, leisure and entertainment Strategic Policy 5 - Providing new homes Strategic Policy 6 - Homes for people on different incomes Strategic Policy 7 - Family homes Strategic Policy 10 - Jobs and business Strategic Policy 11 - Open spaces and wildlife Strategic Policy 12 - Design and conservation Strategic Policy 13 - High environmental standards

14 Southwark Plan 2007 (July) - saved policies

Policy 1.1 Access to Employment Opportunities Policy 1.4 Employment Sites outside the preferred office locations. Policy 1.7 Development within town and local centres Policy 2.5 Planning obligations Policy 3.1 Environmental effects Policy 3.2 Protection of amenity Policy 3.3 Sustainability assessment Policy 3.4 Energy efficiency Policy 3.6 Air quality Policy 3.7 Waste reduction Policy 3.9 Water Policy 3.11 Efficient use of land Policy 3.12 Quality in design Policy 3.13 Urban design Policy 3.14 Designing out crime

Policy 3.18 Setting of listed buildings, conservation areas and world heritage sites Policy 3.19 Archaeology Policy 3.22 Important local views Policy 3.28 Biodiversity Policy 4.2 Quality of residential accommodation Policy 4.3 Mix of dwellings Policy 4.4 Affordable housing Policy 4.5 Wheelchair affordable housing Policy 5.1 Locating developments Policy 5.2 Transport impacts Policy 5.3 Walking and cycling Policy 5.4 Public transport improvements Policy 5.6 Car parking Policy 5.7 Parking standards for disabled people and the mobility impaired

15 London Plan 2011

Policy 2.9 Inner London Policy 2.10 Central Activities Zone - Strategic Priorities Policy 2.11 Central Activities Zone - Strategic Functions Policy 2.12 Central Activities Zone - Predominantly Local Activities Policy 2.13 Opportunity Areas And Intensification Areas Policy 2.15 Town Centres Policy 3.3 Increasing Housing Supply Policy 3.4 Optimising Housing Potential Policy 3.5 Quality and Design of Housing Developments Policy 3.6 Children and Young People's Play and Informal Recreation Facilities Policy 3.7 Large Residential Developments Policy 3.8 Housing Choice Policy 3.9 Mixed And Balanced Communities Policy 3.11 Affordable Housing Targets Policy 3.12 Negotiating Affordable Housing On Individual Private Residential And Mixed Use Schemes Policy 4.7 Retail and Town Centre Development Policy 4.8 Supporting a Successful and Diverse Retail Sector Policy 4.9 Small Shops Policy 4.12 Improving Opportunities For All Policy 5.1 Climate Change Mitigation Policy 5.2 Minimising Carbon Dioxide Emissions Policy 5.3 Sustainable Design And Construction Policy 5.5 Decentralised Energy Networks Policy 5.6 Decentralised Energy In Development Proposals Policy 5.7 Renewable Energy Policy 5.8 Innovative Energy Technologies Policy 5.10 Urban Greening Policy 5.11 Green Roofs And Development Site Environs Policy 5.12 Flood Risk Management Policy 5.13 Sustainable Drainage Policy 5.14 Water Quality and Wastewater Infrastructure Policy 5.15 Water Use And Supplies Policy 6.3 Assessing Effects of Development on Transport Capacity Policy 6.9 Cycling Policy 6.10 Walking Policy 6.13 Parking Policy 7.1 Building London's Neighbourhoods And Communities

Policy 7.2 An Inclusive Environment Policy 7.3 Designing Out Crime Policy 7.4 Local Character Policy 7.5 Public Realm Policy 7.6 Architecture Policy 7.8 Heritage Assets and Archaeology Policy 7.13 Safety, Security And Resilience To Emergency Policy 7.14 Improving Air Quality Policy 7.15 Reducing Noise And Enhancing Soundscapes Policy 7.19 Biodiversity and Access to Nature Policy 7.21 Trees and Woodlands Policy 8.2 Planning obligations Policy 8.3 Community Infrastructure Levy

16 National Planning Policy Framework (NPPF)

The NPPF came into effect on 27 March 2012 and is a material planning consideration. In relation to this application the most relevant sections are: 1 Building a strong competitive economy 2 Ensuring the vitality of town centres 4 Promoting sustainable development 6 Delivering a wide choice of good quality homes 7 Requiring good design 8 Promoting healthy communities 11 Conserving and enhancing the natural environment 12 Conserving and enhancing the historic environment

Principle of development and land use considerations

17 The proposals seeks the redevelopment of the site to provide a high density mixed

use scheme comprising residential, commercial and retail floor space. The existing commercial buildings to be demolished are of no particular townscape merit and, provided that the proposal includes an acceptable provision of replacement employment floor space, the general principle of the redevelopment of the site is appropriate to its sustainable location within the Central Activities Zone and Town Centre, subject to the compliance on detailed matters with the relevant Development Plan policies.

18 The inclusion of a retail unit fronting Blackfriars Road is supported providing a local retail facility for residents in the vicinity of the site and creating an active frontage to this major road.

19 Provision of replacement employment floor space Saved policy 1.4 of the Southwark Plan seeks to prevent the loss of employment floor space. The policy allows an exception to be made where: • The site has been unsuccessfully marketed for Class B use, including

redevelopment, for 24 months, or • The site or building would be unsuitable for re-use or redevelopment involving

Class B use, or • Where the site is located with a town centre, suitable Class A or other town centre

uses are proposed in place of the Class B use.

Strategic Policy 10 of the Core Strategy reiterates the need to protect existing business space noting the need to help meet central London’s need for office space including that for small and medium sized enterprises.

20 The council’s Employment Land Review 2010 (ELR) advises that the projected need for office space over the period up to 2026 will amount to between 400,000 and 500,000 sqms of additional B1 office floor space in the SE1 property market. The ELR recommends the protection of existing business floor space and to facilitate the growth of space for existing and new businesses to accommodate forecast demand for B1 uses.

21 The existing buildings to be demolished contain 1,580 sqms of B1 office floor space (1202 sqms of which is within 90/91 Blackfriars Road and 377 sqms within 92 Blackfriars Road). The replacement building incorporates 1,400 sqms of commercial floor space comprising 633 sqms of retail (A1) and 767 sqms of office (B1) accommodation. Retail is an appropriate town centre use so is able to be counted as replacement employment floor space in the context of the tests in Saved Policy 1.4. The proposed retail floor space is set out over ground floor and basement and the office floor space is set out over basement, ground floor and mezzanine areas. In total, there is a net loss of 180 sqms of commercial floor space amounting to a reduction of 11% from the existing commercial floor space.

22 No.92 Blackfriars Road (on the left hand side when viewed from Blackfriars Road) has been vacant for approximately three years and has been marketed since December 2009 but with only limited interest from prospective occupiers, none of whom chose to lease the building as set out in the marketing information submitted with the application.

23 No.90/91 Blackfriars Road (on the right hand side) is still in use as an office building and no details have been submitted with the application of a marketing exercise for this building. The application states that the current occupier of the building is due to leave the premises later this year to move to a larger premises.

24 The application argues that the proposed office accommodation, unlike the current premises, will provide flexible useable space for small or medium businesses who wish to have their own ‘front door’ and presence on the street. The accommodation will provide flexible space which can be used for a range of B1 uses including light industrial or research and development. The new accommodation will provide space for up to 50 employees within the B1 space and between 20 and 30 employees within the retail premises.

25 It is noted that the proposed employment floor space for both retail and employment includes basements which are not as attractive for potential users although do offer space for ancillary accommodation and storage. However, the B1 units fronting Ufford Street do have large light wells which will make them more attractive to potential occupiers. It is also relevant to note that the existing office floor space within the existing buildings includes large circulation areas and do not provide the same efficiency and quality as the replacement floor space.

26 Whilst marketing information has not been provided for the main area of commercial floor space to be lost, it is recognised that the replacement office and retail floor space will offer better quality floor space than that it replaces and, on balance, it is concluded that the small loss of employment floor space of 180 sqms would not result in material harm to the economy or employment within the Borough. It would therefore not be reasonable to withhold planning permission on this basis if all other relevant matters

are considered acceptable.

27 Provision of residential accommodation The provision of residential accommodation is, in principle, appropriate in this highly accessible location and provides a range of unit types, including affordable housing. The proposed residential density stated in the application is 1154 habitable rooms per hectare (hrh) though including the commercial accommodation increases the density to 1546 hrh (this based on an assumption of a habitable room being equivalent to 27.5 sqms of floor space). This is above the recommended range in the Southwark Residential Design Guidance (SPD). The application therefore needs to demonstrate that the proposed development achieves an exemplary standard of design, exceeding the residential design standards set out in the SPD.

28 The proposed housing mix is set out in the table below: 1 Bed 2 Bed 3 Bed Total % Total Units

18

25

10

53

100%

Private Units

16

20

7

43

81%

Private Hab Rooms

32

60

28

120

79%

Affordable (Social Rent) Units

0

5

3

8

15%

Affordable (Social Rent) Hab Rooms

0

15

12

27

18%

Affordable (Shared Ownership Units)

2

0

0

2

4%

Affordable (Shared Ownership Hab Rooms)

4

0

0

4

3%

Total Affordable Units

2

5

3

10

19%

Total Affordable (Hab Rooms)

4

15

12

31

21%

29 The percentage of units with two or more bedrooms is 66%, in excess of the minimum

60% requirement in Strategic Policy 7 (Family Homes) of the Southwark Core Strategy. Whilst the proportion of three bed units at 19% is slightly less than the 20% requirement in Strategic Policy 7, this amounts to a shortfall of only half a unit which is not considered to be significant and would not justify the refusal of planning permission.

Environmental impact assessment

30 A screening opinion has not been issued, however it is not considered that the development constitutes EIA development as it does not fall within Schedule 1 or 2 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011. The likely environmental effects can be considered, addressed and mitigated as required through the planning application procedure.

31 Layout and quality of residential accommodation All the proposed residential units accord with, and in many cases, exceed the minimum dwelling size standards set out in the residential design guidance, particularly several of the two and three bedroom units. Of the 53 units 81% can be considered to be dual aspect, which considering the constrained shape of the site adjoining an existing building along one side, reflects the aspirations of the design guidance to include a pre-dominance of dual aspect units.

32 In terms of amenity space, all units have a private balcony and there are additional shared areas of amenity space for the private and affordable housing. Each of the three bedroom units has a private balcony of at least 10 sqms and several of the upper floor apartments will have private amenity spaces which are significantly larger. The design guidance requires that where 2 bedroom flats are unable to provide 10 sqms of floor space, the shortfall of space is added to the minimum shared amenity space requirement of 50 sqms. In this case, there is a total shortfall of private amenity space of 162 sqms, however this is compensated for by a total of 251 sqms of shared amenity space. Whilst the split of this shared amenity space is proportionately greater for the affordable units than for the private units and there is no scope within the development for a designated children’s play space, it is concluded that the proposal includes a satisfactory provision of amenity space for the future residents of the development. Details of appropriate screening between balconies will be required by condition.

33 Being a predominantly north facing development, with almost the whole of the south edge of the development abutting an existing development, the development has faced particular challenges in providing for an appropriate quality of residential accommodation. As outlined above, the development has achieved a predominance of dual aspect units, exceeds the minimum unit size in many cases and provides an acceptable level of private and shared amenity space. A daylight and sunlight assessment has been submitted with the application which demonstrates that the residential accommodation complies with the standards set out in the Building Research Establishment guidance ‘Site Layout Planning for Daylight and Sunlight (2011) in relation to the quality of light. This has been helped by the design of the development which, following pre-application discussions with officers, includes larger areas of glazing and generous inset areas along the northern side of the development providing for both increased amounts of light and larger amenity areas.

34 Conditions are recommended requiring suitable sound insulation for the new residential properties, both in terms of preventing significant noise disturbance from external environmental sources including traffic on Blackfriars Road, and to prevent any loss of amenity to the apartments from the commercial uses below.

35 Overall, it is concluded that a good quality of residential accommodation has been provided by the development which in some, but not all respects, exceeds the minimum standards in the residential design guidance. Whilst the standard of accommodation provided is not considered exemplary in all respects, given the

constraints of this predominantly north facing site, it has managed to achieve a high standard and it is not considered that there is justification to refuse the application on this basis.

36 Affordable Housing The application proposes that 21% of the residential accommodation will be affordable housing comprising 10 units (2 x 1 bed, 5 x 2 bed and 3 x 3 bed). Of these units, the 2 and 3 bedroom flats will provided at social (target) rents and the 1 bedroom flats as intermediate (shared ownership) units. Six of the social rented units will be designed as wheelchair accessible (11% of the total units in accordance with policy requirements) which will need to be fitted out in accordance with the South East London Wheelchair Guidelines. Strategic Policy 6 (Homes for people on different incomes) requires developments to provide as much affordable housing as is able to be provided taking into account viability, and sets a target of 35%. Saved Policy 4.5 of the Southwark Plan allows for the provision of each affordable wheelchair unit to amount to a reduction of 1 habitable room in the target for affordable housing. In this case, this would reduce the target to 46 rooms, or 31%.

37 The applicant has submitted a viability appraisal with the application which was assessed on behalf of the council by our in-house property valuation team. Following negotiations, the original affordable offer was improved by the inclusion of the two shared ownership units within one of the private cores. The valuer's report concludes that this is the maximum amount of affordable housing that the scheme is able to provide whilst remaining viable.

38 The scheme now provides a range of tenure options on site, which is a welcome aspect of the proposal. The inclusion of 8 family-sized social rented units in this area is a particular benefit of the development. In an area like Bankside, where market rents are high, affordable rented units would be particularly expensive, especially for families within larger sized units. The inclusion of social rented units does have an impact on the viability of a development, which is then reflected in the lower number of affordable units which can be provided. However, it does mean that the scheme can provide low cost family units which meet the particular housing needs within the Borough. The inclusion of 1 bedroom shared ownership units has the additional benefit of providing an option for people who aspire to purchase a home, but would not be able to afford market housing in this area.

39 In conclusion, the scheme offers the maximum viable level of affordable housing, with family sized units and wheelchair accessible housing at social rents, and smaller units available for shared ownership. This is considered to be the optimum type of provision for this area bearing in mind the impact on viability.

Design issues

40 Saved Policy 3.13 (Urban design) requires that the height, scale and massing of buildings should be appropriate to the local context and should not dominate the surroundings inappropriately. Paragraph 60 of the NPPF 2012 also notes that it is desirable to seek to promote or reinforce local distinctiveness. Blackfriars Road is an important route between north and south London, and the width of the road adds to the prominence and visibility of the developments on either side. Within the wider streetscape there is considerable variation in its urban grain and scale, especially on the eastern side. On the western side of Blackfriars Road in the vicinity of the site there is a greater consistency of scale with a general height level at 4/5-storey although a seven storey office building (maximum 26.9m in height) has recently been

permitted and constructed at 102-107 Blackfriars Road (known as One Valentine Place).

41 Whilst only carrying limited weight as a draft document, the draft Bankside, Borough and London Bridge Supplementary Planning Document (2010) recognises that this part of Blackfriars Road contains an eclectic mix of buildings and encourages the redevelopment of unattractive buildings to enhance the character and appearance of the area. It goes on to recommend that new development should respect the established building height of the area, recognising that the existing building heights of up to 8 storeys along Blackfriars Road. The existing buildings to be demolished are of little townscape merit and the availability of the site for development provides an opportunity for enhancements to be made to the streetscene and townscape.

42 During the course of the application, revised drawings have been submitted including alterations to the ground floor articulation of the building and a revised approach to the front elevation of the building to produce a more refined and coherent building form fronting onto Blackfriars Road.

43 Whilst the proposed building is higher than those immediately around to the site at a maximum of eight storeys (27.5m in height) it does not qualify as a ‘tall building’ as defined by saved Policy 3.20 (Tall Buildings) of the Southwark Plan. Along with the five storey building to which it will be attached, the development site has roads on each side separating it from other development and providing some scope for an increase in height. To break up its massing and reflect the vertical proportions of the Georgian terrace to the north, the design of the front elevation has been broken up into four elements, whilst retaining a coherent design approach that is sympathetic to existing forms of frontage development. The zinc clad roof additions at the eighth storey are set back from the front elevation and would not be visually prominent within the streetscene. A step down of two storeys adjacent to Ufford Street responds to the lower height of the Georgian terrace. Whilst higher than the prevailing form of buildings on this side of Blackfriars Road, the proposed building would not appear as out of context or visually intrusive in this location.

44 The scale of the proposal along the Ufford Street frontage (approximately 80m in length) steps down from seven storeys on Blackfriars Road to 3-4 storeys onto Boundary Row. While this represents a considerable bulk of building on such a long and narrow site, the massing is well modulated by step-ins and set-backs. The modulation of the massing with the two set-back courts provides rhythm and variety to the streetscape, above a strong commercial base. This variety of form is driven by this being a long north-facing site, and the need to prevent where possible single aspect units and create acceptable standard of amenity for the residents of the building. At the rear of site, the building reflects the height of the existing adjoining building and, whilst higher than other existing buildings surrounding this part of the site, it would not appear as being incongruous or excessive in this location.

45 The ground-level layout has been improved following amendments made to the scheme, with the commercial unit wrapping around the corner and having a full frontage onto Blackfriars Road and the two returns. This should provide an active frontage and a condition will be required to prevent the blocking up of the windows by future users. Four residential access points are created into the development with canopies to demarcate the doorways more prominently. The undercroft disabled-parking area at the rear does not create an active frontage and a condition is recommended to require further design details of this element of the building in order to create as attractive frontage as possible in this location.

46 The detailed design and composition of a building are important given the massing and prominence of the building. Saved Policy 3.12 Quality in design, requires that developments should achieve a high quality of both architectural and urban design to enhancing the quality of the built environment, as well as preserving or enhancing the historic environment. The overall composition of the development creates a strong base with the double-height commercial units, and lightens the perception of the top-levels with set-backs and non-masonry facing-materials. This creates a sense of proportion which helps to delineate and define the massing of the building into a balanced form. The windows of the development are grouped into vertical blocks of two or three-storey elements, which gives variety to the composition of the elevations which is further enhanced by the inset terraces and projecting balconies.

47 In terms of facing materials, the building will be predominantly finished with two contrasting bricks, in buff and brown; these will define the individual block elements while helping to break-down the perceived overall bulk into a linked collection of related elements. The buff brick will also be used for the horizontal banding between groups of windows. A glazed brick within a green tonal range is used to delineate the splays/set-backs within larger openings, as well as the walls to the two set-back courts. These bricks should give a high-quality and robust finish. Conditions are recommended requiring approval of materials and detailed design.

48 Saved Policy 3.14 Designing out crime, requires that development in both the private and public realm, should be designed to improve community safety and crime prevention. Whilst the rear car parking area does not help to create street surveillance at the rear, the building on the whole, creates active frontages, particularly along the Blackfriars Road and Ufford Street elevations. The doorway designs have been amended from the recessed entrances originally proposed.

49 There is little room for landscaping around the building but new tree planting is proposed in the inset areas along Ufford Street. The building design will also incorporate brown roofs and landscaped amenity areas. Further details of these will be required by condition.

50 The Conservation Area Advisory Group expressed concern over the scale of the building which it considered to be excessive within this part of Blackfriars Road streetscape, and in relation to the terrace of Georgian listed buildings to the north. It also considered the architectural composition to be inconsistent and lacking quality. The applicant has subsequently made amendments to the design of the scheme including the articulation of the front of the building and the detail at ground floor level which are considered to have now created an acceptably articulated building. The issues regarding the scale of the building are considered above with the conclusion that whilst height of greater massing than the prevailing form of development, the detailed design of the building and its physical separation from neighbouring developments will mean that it will be satisfactorily integrated with the surrounding townscape.

51 Impact on character and setting of a listed building and/or conservation area This site is now within the setting of the Valentines Place Conservation Area. Saved Policy 3.18 Setting of listed buildings and conservation areas, and Paragraph 137 of the NPPF 2012, requires that permission will not be granted for developments that would not preserve or enhance their immediate or wider setting. The scale, height and design of the building is not considered to be detrimental to the setting of this Conservation Area. Also, of particular significance to this site are the Grade II listed buildings in the terrace-block to the north. These are generally 4-storey plus basement

and date to the early C19. The proposal has sought to relate to the stepping-up at the southern end of the terrace and has broken down the elevations to reflect the historic plot widths of the terrace. The use of appropriate brickwork, to be secured by condition, will ensure that the proposed building will not be detrimental to the setting of the listed Georgian terrace.

52 Conclusion on External Design Although higher and of greater massing than the prevailing form of development surrounding the site, the design of the proposal has created a considered and articulated development. It replaces the existing poor quality buildings and will introduce active frontages to both Blackfriars Road and Ufford Street. The proposals respect the setting of listed buildings and the adjacent conservation area and will not appear as incongruous or out of keeping to either the Blackfriars Road frontage or the wider area. The materials and detail design will be controlled by condition in order to achieve the best possible final design quality.

Impact of proposed development on amenity of adjoining occupiers and

surrounding area

53 The nearest existing residential property to the site is at 30 Ufford Street, on the opposite side of the road to the rear boundary of the site. The side elevation of this property faces the application site and does not contain any principal windows to habitable rooms. The front and rear elevations face away from the proposed development and would not be detrimentally affected by the proposed development in terms of either sun/day lighting or visual intrusion. In terms of privacy, whilst there will be some indirect overlooking of the rear garden of No.30 Ufford Street from the residential windows in the rear elevation of the proposed development, the garden is already overlooked by existing properties and it is not considered that significant harm would result.

54 Given the separation distance to other residential properties, including those on the opposite side of Blackfriars Road such as Helen Gladstone House, no adverse implications would result from the proposed development.

55 Planning permission has been granted at Nos. 98-99 Blackfriars Road for rear extensions at second to fourth floor level and other alterations to provide seven residential units, retail and office floor space. Whilst the scheme has not been implemented, it remains extant until March 2015. This proposed scheme includes flats at first to fourth floor levels that would have principal windows facing the application site. Should both schemes be constructed, at their closest point the facing walls would be approximately 10 metres apart. Through the inset design of the proposed development at 90-92 Blackfriars Road, this would increase by an additional six metres for that part of the building which directly faces the proposed windows in the approved scheme opposite.

56 Whilst there would be some overlooking between the two schemes this would not be untypical for schemes fronting narrow streets. There would also be some impacts upon day and sun light received by some of the lower flats in either scheme although this has not been assessed as part of the applicant’s day and sun light assessment. However, there is no certainty that either or both schemes will be constructed and only limited weight should be given to the potential affects given that the impacts relate to a permitted scheme rather than an existing development. There is no impediment to both schemes being constructed and offering reasonable standards of living accommodation in a sustainable location. It is concluded on this issue that there are

not sufficient grounds for refusing this scheme based upon the potential impacts upon this other permitted scheme.

57 An objection has been received from the freeholder of 2-6 Boundary Row (a currently empty office building, the rear wall of which will adjoin the proposed development) on the grounds that the development will block daylight from entering the three lightwells within the rear wall, resulting in a significant reduction in the quality of the commercial floorspace. It is noted that the principal windows to this building are within the front and side elevations facing Boundary Row. Whilst inevitably the proposed building adjoining 2-6 Boundary Row will result in the loss of some daylight entering into this building via the lightwells, taking account of the principal windows which are unaffected by the proposed development, this is not considered to result in such a significant impact upon the amenity of the occupiers/workers of this building A condition is recommended requiring details of glazed bricks to be used in those parts of the wall of the proposed development which immediately adjoins the lightwells in order to maximise the amount of daylight entering the adjacent building.

Impact of adjoining and nearby uses on occupiers and users of proposed development

58 The buildings around the site house a mixture of commercial, educational and residential uses. Subject to the new residential properties being designed with appropriate noise insulation measures (which will be required by condition to particularly protect against road noise) the proposed uses will be compatible with those existing in the locality of the site.

Transportation issues

59 The site has the highest possible PTAL (Public Transport Accessibility Level) of 6b

and therefore enjoys excellent public transport accessibility including bus, underground and rail. No general car parking is proposed which is supported by policies seeking to minimise the use of private cars in areas with excellent access to public transport. The Traffic Order would be amended to prevent future residents of the scheme from applying for on-street parking permits. The s106 agreement will also include a commitment by the developer to pay for three years car club membership for residents of the development. There are existing on-street car club spaces in close proximity to the site.

60 Three off-street disabled parking spaces are proposed in an undercroft area accessed directly from Ufford Street amounting to a 50% provision for the six wheelchair units. Whilst ideally one space should be provided for each of the wheelchair units, saved Policy 5.7 (Parking Standards for Disabled People) of the Southwark Plan requires a minimum of one disabled space per development and the applicant has stated that due to the location of building cores there is not space for additional disabled parking spaces. Taking account of the site's close proximity to local services and public transport provision (including Southwark underground station which has wheelchair access) and the existing on-street parking bays on Ufford Street, it is concluded that the lack of further disabled parking provision would not justify the refusal of planning permission for the scheme.

61 A total of 62 secure cycle parking spaces are provided for the private and affordable residential apartments in accordance with the Council’s standards, all using Sheffield Stands. The private cycle parking will be in the basement accessed by lift and the affordable cycle parking will be provided within the building at ground floor level. In addition, eight secure parking spaces will be provided within the building for

employees of the commercial uses and sixteen external spaces for visitors are proposed within the site on the Ufford Street frontage. The cycle parking accords with the Council’s policies in respect of both numbers and type.

62 A Framework Travel Plan has been submitted with the application setting out the measures to enable residents, employees and visitors of the development to make more informed decisions about their travel and to encourage sustainable forms of travel. A requirement for a full travel plan to be submitted and monitored will be included in the s106 agreement.

63 Given the constraints of the site, there is no provision for loading and servicing to take place within the site. Instead, it is proposed that a servicing bay will be provided inset into a built out footway on Blackfriars Road which will delivered as part of Transport for London’s (TfL) wider public realm improvements scheme. Should the development be built in advance of the Blackfriars Road public realm scheme, TfL have agreed that an interim servicing bay can be provided in front of the site on Blackfriars Road. Provision for the servicing bay will be included within the s106 agreement.

64 In addition to the toolkit contributions towards Strategic Transport, Site Specific Transport and Public Realm the applicant has agreed with TfL to pay an additional £70,000 contribution towards the Blackfriars Road public realm scheme.

65 A Construction Management Plan and Delivery and Servicing Management Plan are recommended to be required by conditions.

66 On transport matters it is concluded that the proposals will promote sustainable travel and will not result in any adverse impacts upon local highway conditions in accordance with the relevant transportation policies including Strategic Policy 2 (Sustainable Transport) of the Southwark Core Strategy and saved Policy 5.2 (Transport Impacts) of the Southwark Plan.

Impact on trees

67 The application includes an arboricultural implications assessment report in relation to the impact of the development upon the two existing London Plane trees located directly in front of the site, one of which is a high quality Category A tree. The report concludes that, subject to the implementation of protection measures, there will be no adverse impact upon these trees from the proposed demolition and construction. The Council’s urban forester has agreed the submitted protection details which will be secured by condition.

Planning obligations (S.106 undertaking or agreement)

68 The table below sets out the agreed financial contributions that will be paid by the

developer: Planning Obligation

Toolkit Standard Charge

Proposed Contribution

Education £93,383 £93,383 Employment in the development

£20,641 £20,641

Employment during construction

£61,630 £61,630

Planning Obligation

Toolkit Standard Charge

Proposed Contribution

Employment during construction management fee

£4,830 £4,830

Public open space £29,549 £29,549 Children’s play equipment £6,911 £6,911 Sports development £72,108 £72,108 Transport Strategic £45,719 £45,719 Transport Site Specific £47,500 £47,500 Public Realm (General) £60,750 £60,750 Public Realm (Blackfriars Rd)

Not required by toolkit £70,000

Health £59,831 £59,831 Community Facilities £12,189 £12,189 Admin Charge £10,301 £11,701 Total £525,342 £596,742

69 Other obligations to be included in the s106 agreement are:

• Provision of 21% affordable housing on the site • Affordable housing viability review • Travel Plan including monitoring • Car club membership for three years • Future proof connection to district heating network • Provision of wheelchair units • Highway works and road safety audit

70 In the event that the section 106 agreement is not signed by 3 June 2013, it is recommended that the Head of Development Management be authorised to refuse the application for the following reason: In the absence of a signed Section 106 agreement , there is no mechanism in place to avoid or mitigate the impact of the proposed development on the public realm, public open space, health care provision, the transport network, and employment and the proposal is therefore contrary to Policy 2.5 of the Southwark Plan and Policy 8.2 of the London Plan.

Sustainable development implications

71 Core Strategy Strategic Policy 13 (High Environmental Standards) requires all proposed development to investigate the feasibility of using decentralised CHP or CCHP (Combined Cooling Heat and Power) systems and development of over 40 dwellings should be connected to existing or those being developed area-wide CHP or CCHP systems where they are within 200m of the site. The scheme proposes a Gas-fired CHP system. The energy strategy addresses the energy hierarchy of “Be Lean”, “Be Clean”, and “Be Green” stages to reduce the energy consumption of the development. The energy statement confirms that space allowance in the plant space will be provided for heat exchangers to connect to an offsite district heating and cooling network. This needs to be secured through the s106 agreement.

72 The energy statement submitted with the application states that utilising a large CHP plant to provide heat will provide an estimated CO2 emission saving of approximately 36%. When combined with the enhancements made from the Be Lean elements of the

scheme (7%), the proposals achieve 43% saving in CO2 which is over the 2010 building regulations required to achieve level 4 of Code for Sustainable Homes.

73 Policy 13 of the Core Strategy requires 20% reduction in carbon dioxide from on-site local low and zero carbon sources of energy. This is supported by the London Plan (2011) which states in policy 5.7 that major development proposals should provide a reduction in expected carbon dioxide emissions through the use of on-site renewable energy generation, where feasible. The London Plan (2011) also states that there is a presumption that all major development proposals will seek to reduce carbon dioxide emissions by at least 20 per cent through the use of on-site renewable energy generation wherever feasible.

74 The statement states that a number of renewable technologies have been appraised in terms of technical, physical and financial feasibility, as potential renewable systems for use on the project. Each technology was considered as an alternative option operating in conjunction with CHP. Solar photovoltaic panels (PV) are proposed onto the roofs of the building, achieving a 5.9% CO2 reduction.

75 The energy statement demonstrates how the proposal will achieve over 44% saving in carbon dioxide (CO2) emissions above the Building Regulations Part L 2010 from energy efficiency, efficient energy supply and renewable energy.

76 The commercial accommodation cannot meet 'Excellent' mainly as it will have a low heating demand. It is accepted that the operations within smaller units are likely to be less suitable for assessment against the BREEAM criteria because of reduced servicing requirements.

77 Whilst not meeting all the requirements of Strategic Policy 13, taking account of practical difficulties of providing a) higher levels of on site renewable energy and b) achieving BREAM excellent for the commercial premises for a development of this size, it is concluded that the scheme satisfactorily accords with the aims of this policy to achieve the highest possible environmental standard.

Other matters

78 Archaeology

The site is not located within an archaeological priority zone, however archaeological work within the immediate area and historic finds and records included on the Greater London Historic Environment Record, indicate that the Blackfriars Road area is a potential location for prehistoric activity. In the prehistoric and Roman periods, this area was dominated by a tributary of the Thames generally referred to as the 'Blackfriars Channel'. This channel, whilst following a meandering course, ran north, roughly on the line of modern Blackfriars Road. Other sites in the area of Blackfriars Road, most notably 240 Blackfriars Road, have revealed prehistoric settlement evidence on the channel margins within the site. The proposal includes expanding the basement across the whole of the site, thereby having a total impact upon potential buried archaeology. It is recommended that a programme of archaeological observation and recording is maintained during ground works on site to preserve the archaeological significance of the site by record. This will be secured by condition.

79 Flood Risk The site is located in Flood Zone 3 which is deemed to be high risk though it is within an area benefiting from the River Thames tidal flood defences. The application

includes a flood risk assessment (FRA) and the Environment Agency has confirmed it has no objections subject to a condition requiring that the development is carried out in accordance with the mitigation measures included in the FRA.

80 Ecology The site does not affect any site of ecological importance. As ecological assessment has been submitted with the application which recommends several ecological enhancements which can be secured through a condition of planning permission including the use of a brown roof.

81 Demolition and Construction Works Provided the works take place in accordance with best practice and relevant legislation it is not considered that the demolition and construction works associated with the development would result in significant impacts upon properties in the vicinity of the site, including the cumulative impacts along with other development that may be proceeding in the area at the same time. A condition is recommending requiring works to be carried out with an Environmental Management Plan which will need to be submitted to and approved in writing by the Council prior to the commencement of works. This should include consideration and the environmental impacts and the required remedial measures.

82 Mayoral Community Infrastructure Levy S143 of the Localism Act 2011 states that any financial sum that an authority has received, will or could receive in the payment of a CIL is a material ‘local financial consideration, in planning decisions. The requirement of the Mayoral CIL is a material consideration. However, the weight to be attached to a local finance consideration remains a matter for the decision maker. Mayoral CIL is to be used for strategic transport improvements in London, primarily Crossrail. In Southwark, the levy is applied to all developments at a rate of £35 per square metre. The CIL contribution is based on all the additional floor space created. This amounts to 4344 sqms resulting in an applicable CIL payment of £152,040.

Conclusion on planning issues

83 The application proposes a high density mixed use development in a sustainable location with excellent public transport links. The retail unit will provide a local shopping opportunity and the commercial floor space will provide flexible accommodation for small or medium businesses replacing the existing employment floors space existing on the site. The small loss of employment floor space from the existing building is not judged to result in significant harm to the local economy.

84 The scheme will replace the existing buildings of little townscape merit with a building of contemporary design leading to improvements in the street frontage along the front and side of the site. Whilst higher than the prevailing form of existing development on this side of Blackfriars Road, the design has been appropriately articulated and will not appear as visually intrusive or detrimental to the streetscape. Active frontages will be created to Blackfriars Road and Ufford Street. No harmful impacts would result upon existing residents living in the vicinity of the site. The residential accommodation will provide good quality residential living accommodation for future residents, 21% of which will be affordable housing. The level of affordable housing has been properly justified through the submission of a viability assessment, and has the benefit of including 8 social rented family units.

85 The proposal will not result in adverse transportation impacts and sustainable methods of travel will be promoted though the provision of cycle parking for all users and visitors.

86 All other matters have been considered none of which result in any material harm that would justify the refusal of the application. It is concluded that the proposal will result in a mixed use scheme that will contribute positively to Blackfriars Road and the surrounding area.

Community impact statement

87 In line with the Council's Community Impact Statement the impact of this application has been assessed as part of the application process with regard to local people in respect of their age, disability, faith/religion, gender, race and ethnicity and sexual orientation. Consultation with the community has been undertaken as part of the application process.

The impact on local people is set out above. Consultation

88 Details of consultation and any re-consultation undertaken in respect of this

application are set out in Appendix 1.

Consultation replies

89 Details of consultation responses received are set out in Appendix 2. Issues raised include: • Loss of small amount of employment space is, on balance, acceptable. • Sustainability proposals are acceptable. • No transportation/highway impacts subject to conditions and s106 provisions • Proposals acceptable in relation to Environmental Protection matters. • Concerns regarding height, massing and articulation of the scheme. • Impacts from construction works along with other developments. • Loss of light to neighbouring properties. • Impact upon listed buildings. • No open space within the development. • Question need for shops.

Human rights implications

90 This planning application engages certain human rights under the Human Rights Act

2008 (the HRA). The HRA prohibits unlawful interference by public bodies with conventions rights. The term ’engage’ simply means that human rights may be affected or relevant.

91 This application has the legitimate aim of providing a replacement building comprising residential accommodation and employment floor space. The rights potentially engaged by this application, including the right to a fair trial and the right to respect for private and family life are not considered to be unlawfully interfered with by this proposal.

BACKGROUND DOCUMENTS Background Papers Held At Contact Site history file: TP/1390-90 &

1390-92 Application file: 12/AP/3558 Southwark Local Development Framework and Development Plan Documents

Chief Executive's Department 160 Tooley Street London SE1 2QH

Planning enquiries telephone: 020 7525 5403 Planning enquiries email: planning.enquiries@southwark.gov .uk Case officer telephone: 020 7525 4351 Council website: www.southwark.gov.uk

APPENDICES No. Title Appendix 1 Consultation undertaken Appendix 2 Consultation responses received Appendix 3 Properties notified of application Appendix 4 Images Appendix 5 Recommendation AUDIT TRAIL Lead Officer Gary Rice, Head of Development Management

Report Author David Cliff, Team Leader, Major Applications Team

Version Final

Dated 19 April 2013

Key Decision No

CONSULTATION WITH OTHER OFFICERS / DIRECTORATES / CABINET MEMBER

Officer Title Comments Sought Comments Included

Strategic Director of Finance and Corporate Services

No No

Strategic Director of Environment and Leisure

No No

Strategic Director of Housing and Community Services

No No

Director of Regeneration No No

Date final report sent to Constitutional Team 25 April 2013

APPENDIX 1

Consultation Undertaken

Site notice date: 30 November 2012

Press notice date: 6 December 2012

Case officer site visit date: 30 November 2012 and 15 January 2013

Neighbour consultation letters sent: 30 November 2012, 8 January 2013 and 11 April 2013.

Internal services consulted:

Transportation Team, Environment and Housing, Planning Policy, Ecological Officer, Housing, Economic Development Officer, Public Realm, Housing Regeneration Initiatives.

Statutory and non-statutory organisations consulted:

Environment Agency, Thames Water, Transport of London, Health and Safety Executive,

Metropolitan Police, London Borough of Lambeth. Neighbours and local groups consulted:

Local residents as listed in Appendix 3

Re-consultation:

n/a

APPENDIX 2

Consultation Responses Received Internal services

Planning Policy

• The marketing information is not convincing to fully justify the loss of 180 sqms of

employment floor space, however on balance the proposed replacement commercial floor space will be more efficient and higher quality than the existing, and on this basis the small loss of commercial floor space is acceptable.

• Justification for the affordable housing provision of only 18% should be provided

through the viability assessment. • The proposed scheme delivers 64% of units over two bedrooms which exceeds the

policy requirement, however the proposed 19% family sized housing is non-compliant with policy requiring 20%.

• The scheme proposes a gas fired CHP system and plant space heat exchangers to

connect to off site district heating and cooling network should be secured by condition by condition.

• Code for Sustainable Homes level 4 will be achieved. The applicant has stated that

the area to accommodate the PV has been maximized (5.9% CO2 reduction) and no other technologies are feasible for the site. The commercial units cannot meet ‘Excellent’ because it will have a have a low heating demand. It is accepted that the operations within smaller units are likely to be less suitable for assessment against BREEAM criteria because of reduced servicing requirements.

Transportation Team

• Further details of cycle storage are required including secure storage for users of the

commercial units. • Car free development is supported. • £2750 should be secured towards amending the Traffic Order to prevent occupants

applying for on street parking permits. • Five wheelchair parking spaces should be provided. • Access to disabled parking bays needs to be addressed. • Given the low number of vehicle movements no objections to reversing into the

development and exiting in a forward gear. • Justification required as to why on site servicing cannot be provided. • Membership of car club should be provided for three years. • Travel Plan is required and monitoring fee of £3,000. • Delivery and Service Management Plans and Construction Management Plans are

required.

Ecological Officer Agree with findings of the ecological site survey. The report makes recommendations for ecological improvements, the most valuable of which is for a brown roof which should be the subject of a planning condition.

Environmental Protection Team No objections raised. Conditions recommended in relation to:

• Ventilation details • CHP emissions • Ambient noise levels • Noise insulation between residential and commercial premises • Contamination assessment • Environmental management plan

Urban Forester No objections subject to conditions requiring details of:

• Tree protection • Landscaping plan • Green/Brown roof/ living walls /vertical gardens and planters.

Statutory and non-statutory organisations

Environment Agency

Note that the site is located in Flood Zone 3 which is deemed to be ‘high risk’ and is within an area benefiting from the River Thames tidal flood defences. No objection raised subject to a condition being imposed to ensure that the development is carried out in accordance with the submitted flood risk assessment.

Transport for London The development site is located on the A201 Blackfriars Road which forms part of the Transport for London Road Network. Given the site has a Public Transport Accessibility Level of 6B, TfL welcomes the proposal to provide limited car parking. At least one space should be provided by Electric Vehicle Charging infrastructure. TfL welcomes the proposals to provide 86 cycle spaces. The TfL Blackfriars Road Urban Realm Improvement Scheme will benefit the development through improving the local pedestrian and cycling environment. TfL request a contribution of £140,000 from the developer to facilitate the implementation of the scheme and to deliver its associated benefits in the immediate vicinity of the scheme, to be secured through a s106 agreement (Note: TfL subsequently agreed to a contribution of £70,000). TfL note the proposals for the creation of loading bays along Blackfriars Road and it is understood it is the aspiration of the applicant to undertake these works as part of a two stage approach whereby Option 1 is implemented prior to the completion of the Blackfriars Road Improvement Scheme, with Option 2 implemented once the scheme is completed and where sufficient clearance on the footway allows the implementation of an inset loading bay. TfL request a Stage 1 Road Safety audit is prepared and submitted for both design

options, prior to a decision being made regarding future loading areas. Option 1: TfL consider the principle of a loading bay on Blackfriars Road between Boundary Row and Ufford Street acceptable, however TfL note a variation in design between the drawing submitted in the Transport Assessment and that illustrated in drawing T(20)P00. TfL consider the design submitted in drawing T(20)P00 unacceptable given the proximity to the junction with Boundary Row and potential conflicts with pedestrians and other vehicles. However, TfL are content that this issue can be resolved during the Section 278 detailed design process. Option 2: TfL considers this acceptable assuming the Blackfriars Road Improvement Scheme is implemented with the build out of the existing footway and provided any issues raised by the safety audit are resolved. A construction management plan and a delivery and servicing plan are required by condition. TfL does not object to the principle of development on the site, however, given local sensitivities, TfL wishes to have sight of proposed conditions prior to the determination of the application.

Conservation Area Advisory Group • Concerned and disappointed with this significant proposal for an important stretch of

the Blackfriars Road. • This eight storey scheme puts forward a perplexing sub Post-Modernist collage of

materials, brick, metal and glass grouped together in a wholly unconvincing way. • It must form an intelligent complement to the classical order and rhythm of the

important Georgian town houses to the north and the good quality Italianate Victorian commercial and public buildings nearby.

• The architecture must be of a higher order than the confused looking scheme which is proposed here.

• Brick is probably the right facing material but it needs to be handled with care and discipline.

• General consensus that the jump from five to eight storeys now proposed is harsh. However, the main failing of this scheme is its inept design for a prominent and historically significant site.

Thames Water No objections raised with regard to sewerage and water infrastructure.

Neighbours and local groups

Six letters received - five from local residents and one from the free holder of an adjacent building:

Occupier of Vaughan House, Nelson Square Gardens • Several building developments are planned and more on the horizon • All these developments offer nothing to the local communities • Cold and unimaginative designs, increasing density • Sheer scale will block natural light

Occupier of Helen Gladstone House • Builders making constant noise since 1995 • Oppose on the grounds of workmen making a constant noise • Old people in area affected by noise

Occupier of Ring Court, The Cut • Object to the proposed height, it should be no more than 4 storeys • There is no mention of any green aspect of the building, solar panels or even a

green sedum roof • If the building is preserved at four storeys it will preserve the integrity of 176

Blackfriars Road (Sons of Temperance Friendly Society) opposite • Do we need any more shops when those that exist are struggling?

Occupier of Helen Gladstone House • Eight storey building immediately adjacent to Blackfriars Road is too high and will

adversely affect the relatively open and low rise character of this part of Southwark • In conjunction with the proposed development opposite it will turn this part of

Blackfriars Road in a noisy urban canyon. • It will dominate and overshadow both the listed building opposite and the adjacent

garden next to Helen Gladstone House. • Urge the planning authority to stipulate a maximum of five storeys for this site

Occupier of Helen Gladstone House Object as it would directly affect quality of life. Officers Note - It appears that this objection relates to the proposed scheme on another site between Pocock Street and Surrey Row which has undergone pre-application consultation rather than these application proposals).

Freeholder of 2-6 Boundary Row (adjoining the application site) Support the principle of the proposal but consider that some design amendments are necessary to ensure the proposed building does not have an unacceptable impact on the amenity of the users of the adjoining building. Building at 2-6 Boundary Row has three lightwells that run down the proposed party wall, presume that these have not been considered in the proposed design, despite them being one of the closest and most affected windows of a neighbouring property. The application will significantly reduce the amount of daylight that currently enters 206 Boundary Row which will reduce the quality of commercial workspace. It will also decrease the sustainability credentials due to the necessity to increasingly use fluorescent lighting in these parts of the building. Contrary to Core Strategy Strategic Policy 13 (High Environmental Standards) requiring that developments avoid amenity and environmental problems that effect how we enjoy the environment in which we live and work. Request that the design is amended to mitigate its impact by mirroring the existing lightwells within the adjacent proposal or increase the amount of daylight that can travel down into the lightwells though the use of appropriately reflective materials on the abutting wall, in conjunction with avoiding increased solar glare (e.g. replacement frosted glass in lightwells).

APPENDIX 3

Properties Notified of Planning Application

Properties within approximately 100m of the site boundaries including those on/in: Blackfriars Road The Cut Boundary Row Webber Street Bridgehouse Court, Blackfriars Road Ring Court, The Cut Burrows Mews Pontypool Place Barons Place Peabody Square, Blackfriars Road Ufford Street Helen Gladstone House, Nelson Square Vaughan House, Nelson Square Quinton House, Chaplin Close Milton House, Short Street St Georges Mansions, Blackfriars Road St Andrews Vicarage, Short Street Manna House, Pocock Street Southwark College for Further Education Valentine Place Theatre View Apartments, Short Street St Andrews Church Hall, Short Street Friars House, Blackfriars Road Vaughan House, Nelson Square