planning report PDU/2676/01
6 April 2011
in the London Borough of Greenwich
planning application no.11/0271/F
Strategic planning application stage 1 referral (new powers)
Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and
2007; Town & Country Planning (Mayor of London) Order 2008
A detailed application for a mixed-use redevelopment of the site to provide 181 residential and
358 student residential units; education/office floor space, health club/leisure floor space and
11 start-up/incubator units; an extension to the rear of Greenwich West Community Centre,
a nursery, a retail foodstore and a cafe/bike store; together with a three-star 104-bed hotel, a
30-room boutique hotel, associated restaurant, including external works to the North Pole
Public House, an on-site energy centre, improvements to the existing public realm and the
provision of public art; landscaping and associated car, car club and cycle parking spaces.
The applicant is Cathedral (Movement Greenwich) LLP and the architects are HLM
Architects and Studio Egret West.
The proposal is for a comprehensive mix of uses in a town-centre location with good public
transport accessibility. The key issues are the design/architectural quality of the scheme,
its impact on strategic views, its contribution to tourism/leisure, higher education and
London’s world city role; affordable and open market housing, local employment, inclusive
access, climate change (including energy) and other environmental considerations.
That Greenwich Council be advised that while the application is generally acceptable in
strategic planning terms, it does not fully comply with the London Plan for the reasons set
out in paragraph 157 of this report; but that the potential remedies set out in paragraph 159 of
the report could address those deficiencies.
1 On 2 March 2011, the Mayor of London received documents from Greenwich Council
notifying him of a planning application of potential strategic importance to develop the above
site for the above uses. Under the provisions of The Town & Country Planning (Mayor of
London) Order 2008 the Mayor has until 12 April 2011 to provide the Council with a
statement setting out whether he considers that the application complies with the London Plan
and his reasons for taking that view. The Mayor may also provide other comments. This report
sets out information for the Mayor’s use in deciding what decision to make.
2 The application is referable under Categories 1A, 1B and 1C of the Schedule to the
1A: “Development which comprises or includes the provision of more than 150 houses, flats, or houses and
1B: “Development (other than development which only comprises the provision of houses, flats, or houses
and flats) which comprises or includes the erection of a building or buildings—(c) outside Central
London and with a total floorspace of more than 15,000 square metres”
1C:”Development which comprises or includes the erection of a building of the following description—(c)
the building is more than 30 metres high and is outside the City of London”.
3 Once Greenwich Council has resolved to determine the application, it is required to
refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his
own determination; or allow the Council to determine it itself.
4 The environmental information for the purposes of the Town and Country Planning
(Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken
into account in the consideration of this case.
5 The Mayor of London’s statement on this case will be made available on the GLA
6 The site is approximately 1.06 hectares in size, situated within the Greenwich town
centre boundary, directly south of the Isle of Dogs, on the opposite side of the River Thames. It
is bounded on the north by the central London to Dartford and DLR railway line, on the south
by the A206 Greenwich High Road, on the west by the B208 Norman Road, and on the east by
Waller Way. Greenwich Station is situated in the north–east corner of the site, some 400
metres south-west of the core town centre and World Heritage site. As such, Greenwich
Council has identified the site as a ‘gateway’ to the town centre and heritage site.
7 The site is owned by Greenwich Council and is characterised by some low-grade,
single-storey industrial/commercial buildings that have been vacant for about three years. It
also encompasses the area of land immediately behind a public house at the junction of
Greenwich High Road and Norman Road, known as ‘The North Pole’ and 159 Greenwich High
Road. Despite its prime location, the site is grossly under-utilised from a strategic planning
8 The surrounding area is typified by a mix of uses, including industrial estates,
residential housing and community uses that include the Greenwich West Community and
Arts Centre- an attractive two-storey brick building fronting Greenwich High Road, to the
immediate east of the application site. Greenwich Centre Business Park is situated to the north,
beyond the National Rail and DLR stations; to the west lies Greenwich Pumping Station,
beyond which is Deptford Creek; and to the south is the predominantly residential
Ashburnham Triangle conservation area.
9 The A200 Creek Road, located approximately 400m north from the site forms part of
the Strategic Road Network (SRN), whilst the A2 Blackheath Hill, approximately 450m to
the south of the site is the nearest section of the Transport for London Road Network
(TLRN). The site is also located within an acceptable distance of the Greenwich
DLR/National Rail station which offers frequent services into central London. Six bus
routes also serve the site with bus stops located on both the A206 and the B208. As a result,
the site records a good public transport accessibility level (PTAL) of 4, out of a range of 1 to
6 where 6 is considered as excellent.
Map 1: Site location plan (Source: Drawing submitted by HLM Architects)
Details of the proposal
10 The proposal is for a mixed-use redevelopment to provide:
181 residential units,
358 student residential units,
1,332 sq.m. of education/office space,
1,382 sq.m of health club/leisure space,
11 start-up/incubator units totalling 635 sq.m.
A 104-bed three-star hotel (possibly Travelodge).
A 30-room boutique hotel and associated restaurant
(including external works to the North Pole Public House).
A 480 sq.m. retail food store.
A 200 sq.m. rear extension to Greenwich West Community Centre.
A 360 sq.m. nursery.
A 37 sq.m. cafe/bike store.
An on-site energy centre.
57 car parking spaces, 2 car club spaces and 439 cycle parking spaces to encourage
sustainable modes of transport within the town centre.
Improvements to the existing public realm, public art, landscaping and associated car, car
club and cycle parking spaces.
11 A key feature of the scheme would be a new, east to west, landscaped street through the
development, linking a pedestrian route from the DLR station to Norman Road and the
western part of the borough. The internal street would be a lively and animated space, with the
residential and non-residential uses having pedestrian entrances off the street, including a new,
inclusively accessible entrance to the Greenwich West Community and Arts Centre.
12 On 21 October 2010, a pre-application meeting was held between the present applicants
and GLA officers to discuss a proposal for a mixed-use development of the site to provide:
178 residential units.
371 student residential units and a 1,500 sq.m. student village.
A 95-room hotel.
1,000 sq.m. of office space.
A 247sq.m. community centre extension.
2,200 sq.m. of leisure (class D1) space.
350 sq.m. for art and craft units.
An on-site energy centre.
13 In summary, the GLA advised that the principle of a mixed-use redevelopment was
acceptable in strategic planning terms and broadly in line with the Council’s development plan
aspirations for the site. The commercial, cultural and community elements of the scheme were
consistent with the town centre location of the site; whilst the proposed hotel, significant
element of residential and student accommodation would ensure the levels of continued activity
and surveillance required for an evening economy.
Strategic planning issues and relevant policies and guidance
14 The relevant issues and corresponding policies are as follows:
Land use policy/principle London Plan
Mix of uses London Plan
Regeneration London Plan; the Mayor’s Economic Development Strategy
World city role London Plan
Tourism/leisure London Plan; Good Practice Guide on Planning for Tourism
Education London Plan; Ministerial statement July 2010
Retail/town centre uses London Plan; PPG13, PPS4
Housing London Plan; PPS3; Housing SPG; Providing for Children and
Young People’s Play and Informal Recreation SPG, Housing
Strategy; Interim Housing SPG; Housing SPG EiP draft
Affordable housing London Plan; PPS3; Housing SPG, Housing Strategy; Interim
Housing SPG; Housing SPG EiP draft
Density London Plan; PPS3; Housing SPG; Interim Housing SPG;
Housing SPG EiP draft
Urban design London Plan; PPS1
Tall buildings/views London Plan; RPG3A, Revised View Management Framework
Access London Plan; PPS1; Accessible London: achieving an inclusive
environment SPG; Planning and Access for Disabled People: a good
practice guide (ODPM)
Transport/parking London Plan; the Mayor’s Transport Strategy; PPG13;
Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22;
draft PPS Planning for a Low Carbon Future in a Changing
Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change
Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy;
Sustainable Design and Construction SPG
River Thames/flooding London Plan; Mayor’s draft Water Strategy; PPS25, RPG3B
Air quality London Plan; the Mayor’s Air Quality Strategy; draft replacement
air quality strategy; PPS23
15 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004,
the development plan in force for the area is the Greenwich Unitary Development Plan 2006
and the London Plan (Consolidated with Alterations since 2004).
16 The following are also relevant material considerations:
The draft replacement London Plan, published in October 2009 for consultation.
The draft Core Strategy with Development Management Policies (Nov.2010 - Feb.2011
Land use policies and the principle of development
17 The site falls within the Greenwich District Town Centre boundary and the 189-
hectare Deptford Creek/Greenwich Riverside Opportunity Area, wherein the London Plan
identifies the potential for a cultural quarter, smaller scale leisure and tourism-related
provision, business workspace, an indicative capacity for 4,000 new jobs and 5,000 additional
18 Greenwich Council retains its UDP designation of the site (MU33) for mixed-use
development, with enhancement of the adjoining transport interchange. It goes on to seek a
significant proportion of class B1 office/business space, active uses, including retail at street
level and a residential component as part of the mix.
19 The Council’s draft Core Strategy document is at pre-submission stage, but aims to
enhance the role and historic character of the town centre as a visitor destination and a centre
for education, by continuing to protect and promote the Maritime Greenwich as a World
Heritage Site and promoting development that would enhance the offer for tertiary education,
most notably at the University of Greenwich and Trinity College of Music.
20 The submitted proposal is for a residential-led mixed-use development with hotel
accommodation, leisure space, a student village, commercial and community uses, which are
acceptable in strategic land use terms, but provide a small rather than ‘significant’ proportion
of office/business space as envisaged by the Council in its UDP designation of the site.
21 The proposed uses are, nonetheless, acceptable in principle from a strategic and local
land use policy perspective.
Town centre regeneration and the mix of uses proposed
22 Greenwich is the most significant of the borough's district town centres, with
complementary town centre uses that include international tourist attractions like the Cutty
Sark, the Royal Observatory, the National Maritime Museum and the Old Royal Naval
College; not to mention a variety of bars, cafes and restaurants.
23 This redundant and unattractive application site is one of the last remaining
opportunities for regeneration within the town-centre. Although it is in a highly accessible and
strategic location, its present state makes little or no contribution to its potential as the
‘gateway’ to Greenwich from the adjacent public transport hub, Greenwich High Road and the
World Heritage Site; or to local aspirations of promoting a multi-functional role of Greenwich
as a District Centre, a tourist destination and a centre for tertiary education. It has remained
vacant despite several attempts at regeneration over the past ten years, none of which have
resulted in a successful planning application.
24 The application proposals aim to revitalise the site by removing the existing dated
industrial and other inefficient uses of the land from within the town centre, and replacing
them with a truly mixed-use scheme including housing, student housing, education use,
nursery, community centre extension, a health club, a 3-star hotel, boutique hotel,
commercial/incubator start-up business units, a new food store for the town centre, a cafe and
25 Assessed against London Plan policies, the scheme would deliver the following strategic
26 Despite its global tourist attractions, Greenwich Council concedes in its draft Core
Strategy Document that the borough has had only limited success in attracting overnight
visitors. The strategy therefore identifies a need to improve the range of both accommodation
and the evening hospitality and leisure offer, in order to create more diverse forms of tourism,
enhance the experience of Greenwich and benefit the borough economy through increased
27 As such, the creation of two new hotels (totaling 134 rooms), including a 3 star hotel
that would be completed in time for the London Olympic Games in 2012, would help encourage
tourists stay longer in Greenwich. It would be sited in the south-eastern corner of the site, on
the High Road frontage adjoining Waller Way and would make a modest contribution to
London’s ‘world city’ role; and the fulfillment of London Plan policy 3D.7 and policy 4.5 of the
draft replacement London Plan, which seek to achieve the provision of 40,000 net additional
hotel bedrooms by 2031, of which at least 10% should be wheelchair accessible.
28 The new proposals represent a net loss of traditional industrial/commercial business
space relative to the existing, albeit, outdated and currently vacant provision. Its
replacement by the creation of 11 start-up/incubator units (635 sq.m. in total), some 1,332
sq.m. of potential office space and the employment opportunities likely to be generated by
new retail (480 sq.m.), hotel, leisure and educational accommodation would, however,
support a greater number and variety of jobs than the existing facilities provide and would
complement similar provision in a recently completed mixed-use scheme to the west of the
29 In particular, the start-up/incubator units would be provided for renting to local
businesses (typically small retail, creative or internet enterprises) at the behest of the local
Greenwich Enterprise Board, who would ultimately manage the facilities. In total, the
applicant has estimated that the development has the potential to support 200 full time jobs.
30 The revitalisation of use of the site for employment purposes is consistent with
London Plan policies 2A.8, 3B.1 and 3B.11, which aim to sustain and enhance the vitality and
viability of town centres by accommodating economic and housing growth through
intensification and selective expansion; seek a range of workspaces of different types sizes
and costs to meet the needs of different sectors of the economy and firms of different types
and size; and improve employment opportunities for Londoners by removing the barriers to
employment and tackling low participation in the labour market.
31 These objectives are reinforced by policies 2.15, 4.1 and 4.12 of the draft replacement
London Plan. The latter specifically endeavours to promote outer London as an attractive
location for businesses, give access to relatively affordable workspace and ensure that
strategic development proposals support local employment, skills development and training
32 The number of start-up units is, however, relatively modest and the applicant should
explore the possibility of providing additional units within the scheme in order to fulfil
London Plan Policy.
33 The application proposes the provision of some much needed high-quality new
housing, including a mix of unit sizes (including family units) and types, and a proportion of
affordable homes. The full details and relevant policies for this are outlined in a subsequent
section of this report.
34 London Plan policy 3A.25 and 3.19 of the draft replacement London Plan relate to
education facilities. The policies affirm the Mayor’s commitment to meeting the needs of the
education sector, supporting the provision of student accommodation and maintaining
London’s international reputation as a centre of excellence in higher education.
35 The Council’s draft Core Strategy Document highlights the status of the borough as
a centre for tertiary education, noting in particular that the University of Greenwich and
Trinity College of Music perform an important role in Greenwich town centre and add to its
diversity. The emerging policy looks to ensure that this role continues to be enhanced. It
further states that the provision of student accommodation in the town Centre is an
important aspect of the tertiary education offer and will enhance Greenwich's role as a centre
36 The creation of a high-quality student village with generous areas of new public
realm that would benefit future occupants of the student and residential accommodation, as
well as the existing local community, including opening up the site and creating new
pedestrian and cycle links are, therefore, especially welcome.
37 A more detailed policy analysis of the student accommodation is provided further on
in this report.
38 Provision is also made for extended and improved community facilities at the
Greenwich West Community and Arts Centre, a proposed health club, cafe and on-site
nursery, all of which would be accessible to and assist in delivering additional services to the
local community. The extension to the community centre would increase capacity for
approximately 250 additional people to enjoy its services.
39 London Plan policy 3A.26 and policy 3.17 of the draft replacement London Plan
support the provision of additional social infrastructure that is accessible to all sections of
the community, in locations and are within easy reach by walking, cycling and public
transport. Proposals that result in a net loss of social infrastructure should be resisted and
the multiple use of premises should be encouraged wherever possible.
40 In strategic terms, the proposals offer a vibrant and sustainable mix of high-quality
employment, much needed new homes, community facilities, student accommodation and
public realm improvements that would significantly enhance the local environment and make
optimize the use of a centrally located ‘brownfield’ site.
41 London Plan policies 3A.1, 3A.2 and 3A.3 affirm the Mayor’s commitment to increase
London’s housing supply through the monitoring of annual targets that borough Councils are
encouraged to exceed by identifying new sources of supply and maximizing the development
potential of sites to an extent that is compatible with local context, public transport capacity
and strategic design principles. Those objectives are reiterated in policies 3.3 and 3.4 of the
draft replacement London Plan, which provides up-to-date housing targets for London (33,380
units per annum) and each of the boroughs, for the ten-year period between 2011/12 and
42 The borough target for Greenwich is 25,950 new homes for the period 2011/12 to
2020/2021, with an annual monitoring target of 2,595 homes. The proposed development
would contribute a modest but welcome 7% of that annual target as part of a mixed-use
development within a town centre.
43 The national planning policy PPS3 (Housing) requires the London Plan to set out
strategic density policy for the region. Accordingly, the London Plan confirms that DPDs and
individual residential proposals referred to the Mayor will be assessed against policy 3A.3, the
density matrix provided in table 3A.2 and other appropriate objectives, in order to achieve
appropriate housing outputs.
44 In terms of density and overall quantum of residential provision, London Plan policy
3A.3 seeks to ensure that development proposals achieve the maximum intensity of use
compatible with local context, the design principles in policy 4B.1 and local transport capacity.
Policy 3.4 (Optimising housing potential) of the draft replacement London Plan reiterates this
objective, aiming to optimise housing output for different types of location within the relevant
density range provided in table 3.2 of that document. Most significantly, the policies state that
the development proposals that compromise this policy should be resisted.
45 The net residential area of the site is approximately 0.5 ha and the development would
be built to a net residential density of 362 units or 1,126 habitable rooms, per hectare. These
figures significantly exceed the upper limits (260 units or 700 habitable rooms per hectare) of
the range provided in the London Plan density matrix for a site in an urban setting with a
public transport accessibility level of four.
46 Given the good accessibility of the site, that density might be acceptable, provided the
development fulfils the Mayor’s residential quality indicators and does not exhibit the typical
symptoms of a cramped overdevelopment of the site. The design considerations of this scheme
are set out in a subsequent section of this report.
47 In this instance, however, some 52% of the development space proposed is allocated to
non-residential uses, making the plot ratio of development more significant. The latter is
calculated at almost 4:1, thereby exceeding the threshold (3:1) indicated in the Mayor’s
Housing SPG for sites with good public transport accessibility; nonetheless, this is just one
consideration and as mentioned, the design aspects of the scheme also need to be taken into
48 London Plan policy 3A.5 and 3.8 of the draft replacement London Plan require borough
councils to promote policies to ensure that new developments offer a mix of dwelling sizes and
types to meet the full range of housing needs within their area. The policy is elaborated in the
Mayor’s Housing Supplementary Planning Guidance, which seeks a balanced mix of unit sizes
in new developments, with a London-wide target of 32% one-bed, 38% two & three-bed and
30% four-bed or larger units, and a market housing target of 25% one-bed and 75% two and
three-bed units. This may be subject to justified local variation to reflect identified housing
49 The schedule of residential accommodation for the proposed scheme is as follows:
unit total number percentage habitable percentage
size of units by unit rooms hab. rooms
1-bedroom (2P) 34 19 68 12
2-bedroom (4P) 93 51 279 50
3-bedroom (5P) 54 30 216 38
total 181 100 563 100
50 Relative to strategic targets, the table indicates a lower proportion of one bedroom units
and a significantly higher proportion (80%) of two and three-bed units. As a high-density,
flatted component of a variety of uses in a town centre location, the scheme is unlikely to
include a proportion of four and five-bedroom family units to meet strategic aspirations,
without radical revision. In any event, the aspiration for 30% of new housing to contain four or
more bedrooms is a London-wide rather than a site-specific target and the relatively high
proportion of three–bed units in the scheme is welcomed.
51 The draft replacement London Plan, interim London Housing Design Guide and draft
SPG (EiP version) provide minimum space standards for new housing developments. The
applicant’s schedule of accommodation confirms that all units would be designed to meet the
minimum internal space standards provided in the draft replacement London Plan.
52 Whilst it is acknowledged in paragraphs 77-79 that the design of the flats appears to be
of good quality, it would be helpful if the applicant could set out the precise number of flats that
would be served by each core within the residential development; the location and proportion
of residential units with single aspect, and whether any of those would be north-facing in
orientation. These details are required to assess conformity with the draft replacement London
Plan, interim London Housing Design Guide and draft SPG (EiP version). The applicant is,
therefore, requested to provide these details prior to any subsequent referral of this application
back to the Mayor.
53 London Plan Policy 3A.10 requires borough councils to seek the maximum reasonable
amount of affordable housing when negotiating on individual private residential and mix-use
schemes. In doing so, each council should have regard to its own overall target for the amount
of affordable housing provision. Policy 3A.9 states that such targets should be based on an
assessment of regional and local housing need and a realistic assessment of supply, and should
take account of the London Plan strategic target that 35% of housing should be social and 15%
intermediate provision, and of the promotion of mixed and balanced communities. In addition,
Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain
residential development, and to the individual circumstances of the site. Targets should be
applied flexibly, taking account of individual site costs, the availability of public subsidy and
other scheme requirements.
54 Policy 3A.10 is supported by paragraph 3.52, which urges borough councils to take
account of economic viability when estimating the appropriate amount of affordable provision.
The ‘Three Dragons’ development control toolkit is recommended for this purpose. The
results of a toolkit appraisal might need to be independently verified
55 Greenwich Council has not adopted new overall targets as required by Policy 3A.9, but
has had regard to the emerging London Plan targets in its draft Core Strategy document. The
draft Core Strategy sets a target for the plan period (2012-2027) of 32,235. This consists of
2,595 dwellings per year, in line the draft replacement London Plan for the period 2012/13-
2020/21, plus an additional 8,880 dwellings from 2020/21-2026/27. The supporting text for
those targets refers the Strategic Housing Land Availability Assessment) and Housing
56 This development would provide 63 affordable housing units (approximately 35% of the
total) and 118 units for sale on the open market. This is illustrated in the table below:
unit affordable affordable hab. market market hab.
size units (%) rooms units (%) rooms
1-bedroom (2P) 0 0 0 34 29 68
2-bedroom (4P) 37 59 111 56 47 168
3-bedroom (5P) 26 41 104 28 24 112
total 63 100 215 118 100 348
total % 35 - 38 65 - 62
57 The applicant’s planning statement indicates that the level of affordable housing was
derived with regard to the viability of the scheme and reflected the maximum provision that the
development could support.
58 The statement did not, however, contain any information on the tenure of the affordable
housing proposed, confirm whether a grant subsidy would be available from the Homes &
Communities Agency, or include any evidence that the level of provision was indeed the
maximum that could be sustained within the scheme.
59 GLA officers therefore require confirmation of the tenure split of the affordable housing
and a toolkit appraisal of the financial viability of the scheme, to enable a proper assessment of
the proposals against the London Plan policies that seek an affordable housing ratio of 60:40
social rented to intermediate accommodation, and the maximum reasonable amount of
affordable housing that the development could sustain.
Children’s play space
60 Policy 3D.13 of the London Plan sets out that “the Mayor will and the boroughs should
ensure developments that include housing make provision for play and informal recreation,
based on the expected child population generated by the scheme and an assessment of future
needs.” Using the methodology within the Mayor’s supplementary planning guidance
‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that
there will be approximately 112 children within the development. The guidance sets a
benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child
playspace provided on-site. As such the development should make provision for 1120 sq.m. of
playspace for children of all age groups.
61 The development would include balcony space for each of the apartments and 620 sq.m.
of designated play space for children under five, situated directly over a proposed nursery. For
small children, that provision is considered adequate for a town centre flatted development
with 30% three-bedroom units (38% by habitable rooms) and no large four or five-bedroom
family units. The applicant should set out how access to that space would be served for the
occupiers of the development and how it is intended to manage the space.
62 A variety of other amenity spaces, including a 550 sq.m. communal residential courtyard
and 775 sq.m. of communal roof terraces, would be available for older children, however, they
are unsuitable for the type of outdoor games or informal sports that appeal to children in the
11-16 age group. The applicant is, therefore, requested to consider any local public open space,
within a reasonable walking distance of the site, where opportunities for off-site alternatives
may exist and to make a financial contribution towards such provision.
63 The London Plan recognises in paragraph 3.39 that the provision of purpose-built
student housing adds to the overall supply of housing and may reduce pressure on the existing
supply of market and affordable housing, and in paragraph 3.53 states that where a proposal for
development relates solely to student housing, it will not normally be appropriate to apply a
planning obligation for an element of social rent or intermediate housing. Paragraph 3.69 of the
Plan states that shared accommodation or houses in multiple occupation often provide housing
for people unable to gain access to social rented housing or to afford market home ownership or
rents, and where such accommodation is of a reasonable standard, its provision helps contribute
to meeting housing demand and should be encouraged.
64 London Plan policy 3A.25 (Higher and further education) states that the Mayor will and
boroughs should work with the London Development Agency and the higher and further
education sectors to ensure that the needs of the education sectors are addressed in
Development Plan Documents, and that this will include supporting the provision of student
65 Draft Replacement London Plan policy 3.8G states that strategic and local
requirements for student housing meeting a demonstrable need are to be addressed by working
closely with higher and further education agencies and without compromising capacity for
66 At a strategic level there has been a notable increase in applications for student
accommodation in recent times. This raises concern that the impact of an increased amount of
student accommodation being built in London is not being considered in a holistic way. The
draft revised London Plan changes the emphasis of strategic policy on student accommodation
to an approach that more carefully considers both supply and demand, together with a more
dispersed distribution and different forms of provision. Whilst it is acknowledged that there is
capacity for upwards of 17,000 student places, addressing these demands should not
compromise capacity to meet the need for conventional dwellings, especially affordable family
homes, or undermine policy to secure mixed and balanced communities. There is a
requirement that unless student accommodation is secured through a planning agreement for
occupation by members of specified educational institutions for the predominant part of the
year, it will normally be subject to the requirements of affordable housing policy.
67 The applicant has suggested that the proposed student accommodation would benefit
local tertiary institutions such as Greenwich University and Trinity College of Music, but has
not received any firm commitment to take up the accommodation from those institutions.
Details of such commitment should be provided in the Heads of Terms or draft of a legal
agreement, as part of any subsequent referral of this application back to the Mayor.
Urban design and architectural quality
68 Good design is central to all objectives of the London Plan and is specifically promoted
by the policies contained within Chapter 4B, which address both general design principles and
specific design issues. London Plan Policy 4B.1 sets out a series of overarching design
principles for development in London. Other design polices in this chapter and elsewhere in the
London Plan include specific design requirements relating to specific issues. London Plan
policies 4B.9 and 4B.10, which set out specific design requirements relating to maximising the
potential of sites, the quality of new housing provision, tall and large-scale buildings, built
heritage, views, and the Blue Ribbon network.
69 The draft replacement London Plan reinforces these principles, with new development
required to have regard to its context, and reinforce or enhance the character, legibility and
permeability of the neighbourhood (Policy 7.1).
70 The Mayor has published his London Housing Design Guide (Interim Edition).
Although this is not a supplementary planning guidance, the principles within it should help
the scheme to demonstrate consistency with London Plan strategic design principles. This
should be used to inform all design aspects of the planning application.
71 An assessment of the local area in the immediate vicinity of the site notes that there is a
character change between the lower scale residential character of the areas to the south of
Greenwich High Road (Ashburnham Triangle Conservation Area) and the emerging
development pattern of taller and mixed use buildings to the north of Greenwich High Road on
either side of the railway line.
Fig.1: North-facing elevation onto the railway line. (Source: Applicant’s Design and Access
Scale, massing and architectural quality
72 The scheme proposes a new landscaped pedestrian connection from the west to
Greenwich town centre through the site. This is welcomed, as it would enhance the legibility of
and connectivity to the area.
73 The rationale of including a new education/commercial space is supported, as this
could provide an opportunity to create access and activity to the north edge of the site.
74 The layout of the internal street, which is positioned at the southern edge of the site, is
of a good quality and would be overlooked by the community centre extension and the
incubator spaces (although, as noted earlier, provision should be considered for additional
75 The residential development would be located above the western zone of the podium
development, and the siting of the residential blocks is considered appropriate to the context.
76 The main entrance would be located within the street at lower ground level, accessed
through a double-sided glazed entrance.
77 The western residential block would be 11 storeys, stepping down to 7 storeys towards
the south overlooking the street, with the south core serving up to 8 storeys. The eastern
residential block would be 12 storeys, stepping down to 7 storeys towards the south
overlooking the street, with the south core serving 8 storeys. The affordable housing core in
the north core of the western residential block would be accessed directly from Norman Road,
taking residents up to the 6 storeys of flats to the north of the residential block. The height and
massing of the residential blocks are appropriate to the context.
78 The layout of the proposed residential units is encouraging: both private flats and
affordable units are ‘fanned’ and stepped to bring light into the flats, and the fanned out
external walls would form a kinetic response to the movement of the sun.
79 The design of the residential blocks is of good quality: the facades have been articulated
to include many recesses, projecting bays and overhangs so as to create interest and break up
the facade. The building steps down from north to south in a series of landscaped habitable
terraces creating a cantilevering form that engages with the streetscape. The proposed ‘fin’
facades would help achieve a maximisation of dual aspect, with private balcony or terrace
spaces provided for each flat. A series of projecting and recessed elements have also been
included to help break the scale of the facades to Norman Road to reduce massing impact from
80 In terms of materials, the fins to the main facades to both residential blocks would be
clad in Corten steel, with white render to other facades to provide contrast with the natural
‘rust’ finish of the panels. White glazed brick has been proposed to the lower residential
elements, the link blocks to the north and south would be rendered in white. The north
elevation would incorporate a variety of projecting and recessed balconies, which will be
glazed. The roof terraces will also have glazed balustrade.
81 The student housing blocks would be located above the eastern zone of the podium
development. Access would be provided via the lower ground level and ground level entrance
space provides a new main entrance to the student accommodation. The double height entrance
space would provide access to the two main student housing blocks with cafe facilities and
study spaces at upper level.
82 The two main student housing blocks would sit above the podium accommodation and
the third bock would be located overlooking the DLR Plaza. The podium lower ground level of
the student accommodation would be the entrance level, whilst the upper ground level would
house the main circulation routes with amenity space, entrances to flat clusters at podium level
and entrances into the four cores accessing blocks SA1 and SA2.
83 Block SA1, the western block, would be 11 storeys above the 2-storey podium level, and
would have 200 rooms in clusters.
84 Block SA2, the middle Block, would be 9 storeys above the 2-storey podium level, and
would have 118 rooms in clusters.
85 Block SA3, the eastern block overlooking the DLR Plaza, would have 5 storeys of
accommodation and 30 rooms in clusters. The student accommodation in this block commences
from 2 storeys above ground, the lower storeys would accommodate a cafe to the south and an
open Plaza to the north. The building would project a ‘box’ element overhanging the street to
the south and at the north elevation.
Fig.2: South elevation to the internal street, including students’ village. (Source: Applicant’s Design and
86 The rationale of providing a student accessible courtyard (approximately 245 sq.m. in
size) is welcomed. This communal amenity space will be located at first floor level within the
student residential building, and will accommodate communal seating areas and planting. In
addition, a sports court will be provided within this courtyard to provide the opportunity for
ball games within a fenced enclosure. The applicant should provide details of how this would be
accessed by occupiers and managed as an amenity resource within the development.
87 The architect states that the key design concept is for a design solution where both the
main organisational elements and individual rooms of this simple building slip over each other.
However, the height transition of the vertical elements within the block is uncomfortable.
There is also concern over the proposed elevational treatment as its current design is
substandard: the elements proposed to the elevations are scattered and lack cohesion, and has
failed to form an appropriate architectural response to the adjacent residential blocks.
88 The architect is therefore asked to reconsider the elevational treatment of the student
housing blocks in order to foster more harmonious relationship with the residential blocks and
89 The budget hotel would comprise six storeys of accommodation, stepping back from
Greenwich High Road with a two-storey set-back to the top floors. It would provide 104 rooms
(located on the ground to fourth floors), a cafe bar and social spaces at ground floor. The hotel
plant room would be located at basement level. The main entrance to the hotel would be
accessed from Greenwich High Road. The height and massing and the budget hotel building is
considered appropriate to its context.
Fig.3: Impression of new hotel on Greenwich High Road shown at the left end of the buildings. (Source:
Applicant’s Design and Access Statement).
90 The design of the hotel building is of an acceptable standard: it refers to the Georgian
buildings in the vicinity, resulting in a simple and contemporary built form. The eastern
elevation to Waller Way would have an elevated four-storey brickwork facade with a mix of
horizontal and vertical orientation punched and framed windows, in order to tie in with
Eastern Student building leading up to the DLR station. The top floor would be set back from
Greenwich High Road to respect the Conservation Area grouping, with render surrounds to
full height windows. The four-storey wing would be rendered in white, with hotel room
fenestration to give a punctuated rhythm to the oblique views along the street at upper levels.
91 In terms of materials, white rendered facing brickwork, with curtain wall glazing are
proposed on the hotel building.
92 The proposed boutique hotel would form an extension to the existing uses of the North
Pole Pub. The three upper floors have been arranged to provide 30 hotel rooms. The top floor
is aligned with the flat roof of the pub to form a south facing garden terrace for users of the
93 The boutique hotel will have a dining area and reception at ground level that would
continue the active frontage along Norman Road, and help invite pedestrians to the entrance of
the new street.
Fig. 4: West–facing elevation onto Norman Road. (Source: Applicant’s Design and Access Statement).
94 In terms of scale and massing, the boutique hotel relates well to the North Pole public
house and to the buildings along Greenwich High Road and manages the transition between
the retained pub and the incubator units appears in a simple and contrasting manner.
95 The start-up/incubator business space would comprise 11 units, which have been scaled
as low-rise three- level structures to avoid overshadowing the new street. These units would
provide rentable space for local small start-up businesses (typically creative or internet
enterprises). The units vary in size from 17 to 104 sq. m. The layout has been arranged to
provide 5 units at ground level (which can be adapted to be small retail facilities) with a further
6 units on the upper level reached by an open deck corridor. The units with vertical circulation
would have access to a rooftop terrace with a balustrade overlooking the street.
Fig.5: Impression of incubator units onto new street, to the right of illustration. (Source: Applicant’s
Design and Access Statement).
96 The height has been restricted to a maximum of three levels to ensure that the street is
not overly shaded by the structure. The scale and massing of these units are considered
appropriate to the context.
97 The elevation has been broken up to give a sense of identity to the different units and
this is welcomed. The design of these incubator units is of a good standard.
Extension to community centre
98 The proposed development would provide the opportunity to improve and expand the
facilities of the existing community centre while offering a new public entrance to the rear of
99 Due to the topography of the site, the upper floor of the extension links into the
Ground floor of the existing community centre, thus providing an internal link to the street
through the existing building.
100 Level access would be provided to the incubator units, allowing the internal uses to
interact with external space. This also allows for circulation to the stair at either end, providing
access to the upper workshops levels.
101 At ground level, the new extension would house a relocated cafe and kitchen with the
possibility of external seating, and an exhibition space which can be converted into a lecture
space. Between these two spaces and at the centre of the composition, there will be a new
double height entrance space dominated by a staircase that connects the floors. On the level the
extension would house a training room and a meeting room.
102 The community centre extension would form an extension to the incubator units, and it
will be of a similar height (a two-storey structure due to the tall ceiling heights of each storey
which need to relate to the internal section of the community centre). The scale and massing of
the extension is considered appropriate to the context.
Fig.6: Proposed extension to the rear of existing community centre. (Source: Applicant’s
Design and access Statement).
103 The new stair mirrors the grand stair of the existing building and makes the vertical
connection between the levels of the building clearly visible through an enclosure of glass. This
glazing would create a kinetic visual response to the occupation and energy of the street and
the new/existing community centre which is welcomed.
104 The proposed materials are of a good quality: the main elevation would be clad with
bronze patinated copper panels, a more noble material to timber reflecting its association with a
traditional and public building.
105 The residential development would include a landscaped communal courtyard, which
will be located at level 1 between the two residential blocks and will serve as the access to these
buildings. This courtyard will take the form of an intensive green roof acting as a transition
space between the public realm of the street and private residential properties, as well as
providing useable amenity space for residents.
106 The courtyard will comprise of hard surfacing, fixed seating with canopies for shade
and some raised planters to green the building edge and provide privacy to apartments at level
107 Hard landscaped terraces will be also provided at various levels on the residential
building accessed from private apartments. These roof terraces will comprise of hard paving or
decking, and balustrading, providing private outdoor space for residents
108 The scheme proposes a series of children’s play spaces, including 400 sq.m. on the roof
of the nursery, 60 sq.m. on level two of the link between the residential buildings, and 300
sq.m. within balcony spaces of family units. These spaces will be designed to promote play and
learning, with a variety of colours and textures as well as play equipment aimed at the under
fives.Details of how the roof play space would be accessed and managed should be supplied.
Impact on the conservation area
109 The site context in respect of heritage requires careful consideration especially given its
relationship with the Ashburnham Triangle Conservation Area and a number of Listed
Buildings (both statutory and locally). It is relevant to note however that the majority of
Greenwich High Road itself is not in the Conservation Area and the buildings on its northern
side serve to partially screen the proposed development site. It should also be noted that a
development of up to 11 storeys has been approved immediately on the other side of the main
group of Listed Buildings (pumping station/coal sheds).
Fig 7: South-facing view onto Greenwich High Road. (Source: Applicant’s Design and Access
110 Whilst some basic views have been included in the design and access statement, these
are not considered to be sufficient to demonstrate the full impact the proposals will have on the
setting of the Conservation Area. The architect is asked to provide further information,
including photorealistic images of the development proposals from views to and from the
Ashburnham Triangle Conservation Area and the site’s wider area including the World
Heritage site in order to allow officers to assess the impact of the proposed development on the
setting and character of the nearby conservation area and its context.
111 The applicant proposes building heights of 12 storeys for the residential blocks, 13
storeys for the student accommodation blocks and 6 storeys for the budget hotel block. It
cannot, however, be confirmed if the height of the proposed scheme is acceptable under the
policies set out in the revised London View Management Framework (adopted July 2010).
Under the London View Management Framework, the primary tool for the protection and
enhancement of key views of London is by visual assessment and analysis of impact.
112 Given that the site falls within the foreground of the Blackheath Point Panorama
(Viewing Location 6A), the architect is requested to produce a views analysis to demonstrate
how the proposed scheme would comply with policy 4B.17 of the London Plan relating to
strategic views, and to enable proper determination of the classification type that should be
applied to subsequent Accurate Visual Representations (AVR). The architect should also
submit the height of the proposals in terms of AOD (Above Ordnance Datum).
113 The landscape design proposal is of a good quality. It demonstrates how planting and
surface treatment would help enhance the overall quality of the scheme. It also includes
information covering the maintenance, and likely survival of the amenity spaces and this is
114 The design will create a visual landmark at a gateway location to Greenwich Town
Centre along Greenwich High Road, and the range of mixed-uses which will positively
contribute to the local economy, as well as stimulating creative and entrepreneurial activities
within the community. The proposals will also improve the permeability and connectivity of
the site with its surroundings. The current design proposals are positive in many regards, but
particular attention should be paid to elevational treatment of the student housing blocks and
the boutique hotel in order that the proposal complies with the London Plan.
115 Policy 4B.5 of the London Plan expects all future development to meet the highest
standards of accessibility and inclusion (not just the minimum), and ensure that from the outset
the design process has considered how everyone, including disabled and deaf people, older
people, children and young people, would be able to use the places and spaces proposed. This,
together with the Supplementary Planning Guidance ‘Accessible London: achieving an
inclusive environment’, underpins the principles of inclusive design and aims to achieve an
accessible and inclusive environment across London. These policies are respectively supported
by policies 7.2 and 3.8 of the draft replacement London Plan.
116 The applicant has submitted a detailed design and access statement that addresses the
accessibility provisions to be made for each of the many uses proposed. Each of them are
addressed under the following sub-headings: parking, serving and refuse disposal, entrance
details, horizontal access and vertical access, room/unit sizes and means of escape. These
details are illustrated in the design statement, which confirms compliance with Part M of the
Building Regulations and the relevant British Standard.
117 The applicant has confirmed that all the residential units would be designed to the
Lifetime Homes standard and that 10% of the total 181 flats would be wheelchair accessible.
118 The student accommodation would be provided in two blocks with the 358 residential
beds arranged between 4 and 8 individual rooms per cluster. Communal living/kitchen space
would be provided to suit the number of occupants of each cluster, with 5% of the units
designed to be wheelchair accessible.
119 Similarly, it is proposed that 5% of the hotel rooms would be wheelchair accessible. The
London Plan requirement is for 10% of new hotel accommodation to be wheelchair accessible.
It is pertinent to note that the proposals are for three-star budget hotel accommodation, for
which there may well be a particular demand from visitors with impaired mobility.
Transport for London’s comments
120 TfL notes that the developer has undertaken a bus capacity assessment as part of the
transport assessment. While this is helpful, it is not sufficiently robust as it considers only a
small section of the bus routes to be used by the development, rather than the entire route.
Nevertheless, given the scale and location of the proposals, TfL is satisfied that the
development is unlikely to have a significant impact on the capacity of the local bus network.
121 The transport assessment forecasts that 78 DLR trips are likely to be generated in the
morning peak hour. TfL is satisfied that this is unlikely to impact negatively on the capacity of
local DLR services, it should be noted, however, that Greenwich Station currently suffers from
overcrowding on its eastbound platform, which affects train boarding, especially during the
morning peak period. Canopy extensions will be required to assist in providing increased
waiting areas for passengers. TfL therefore requires the applicant to make a financial
contribution towards canopy extensions and public realm improvements towards the entrance
of the station at Waller Way, estimated to cost in the region of £650,000. After initial
assessment of sites around Greenwich station that have potential to come forward for
development in the future, TfL requests that a contribution of £150,000 is secured through
Section 106 agreement, in line with London Plan policy 3C.13 ‘Improved Underground and DLR
services’ and draft London Plan policy 6.2 ‘Providing public transport capacity and safeguarding
land for transport’, towards a pool to carry out these necessary works; further discussion on this
is welcomed. TfL also recommends a sum of £40,000 should be set aside through the S106
agreement for the provision of Docklands Arrival Information System (DAISY) boards, or an
agreed alternative, in communal areas of the development. Given that the red line boundary of
the development covers the access route to the station along Waller Way, DLR would require
the developer to provide an undertaking that access along this route will be maintained at all
times throughout the construction period. This should be secured by condition or planning
122 A total of 57 car parking spaces are proposed on site, 49 of which are allocated for the
residential element of the scheme at a ratio of 0.27 spaces per dwelling, which is acceptable and
in line with London Plan standards. The remaining spaces are allocated for disabled parking,
servicing, and drop off/pick up uses, with a car-free arrangement for the student
accommodation. However, no information has been provided regarding the car parking
arrangements for periods where occupants are moving in or out of accommodation, particularly
at the beginning/end of university terms; this should therefore be provided. TfL therefore
requests the submission of a car parking management plan, secured by condition, in order to
clarify student loading and unloading arrangements.
123 In line with London Plan policy 3C.23 ‘Parking strategy’ and draft London Plan policy
6.13 ‘Parking’, TfL requires 20 per cent of all residential parking spaces to be fitted with
electric vehicle charging points, with a further 20 per cent of spaces having passive provision.
It is noted that the site is located within the Greenwich Town Centre controlled parking zone
(CPZ), and TfL therefore requests that future occupiers of the development should be
prevented from applying for parking permits within the CPZ under the terms of the S106
124 The proposed number of cycle parking spaces is in line with TfL’s minimum cycle
parking standards and is, therefore, considered acceptable. The applicant’s decision to provide a
variety of cycle parking facilities that recognise the differing needs of cyclists across the
development is welcomed; however TfL requests that the cycle parking spaces provided on
ground floor should be covered by CCTV and that on-site changing facilities should be
provided for the 11 incubator business units, in line with London Plan policy 3C.22 ‘Improving
conditions for cycling’ and draft London Plan policy 6.9 ‘Cycling’. TfL is of the opinion that the
distance from the Norman Road coach parking bay could be unsuitable for passengers with
luggage travelling to the proposed hotel. The applicant should therefore identify within their
submitted documents, if there are any roads nearer to the hotel that would allow coaches to
pick up and set down passengers without necessarily having to wait.
125 Whilst TfL welcomes the inclusion of a pedestrian audit, the use of the developer’s own
audit tool, rather than the Pedestrian Environment Review System (PERS), means it is less
comprehensive and neither comparable nor consistent with other audits conducted elsewhere.
The applicant has identified obstacles to pedestrian movement along Tarves Way and Egerton
Drive, however, TfL requests the applicant to propose suitable corrective measures to address
those deficiencies. TfL welcomes the commitment of the developer to improve the pedestrian
environment, particularly the shared surface proposals for Waller Way; further suggestions for
improving deficiencies in the nearby walking environment are also encouraged.
126 Given the site’s location in the town centre, TfL recognises the potential for installing
Legible London (LL) signs within the development and locations in close proximity to the site,
including the National Rail and DLR station entrances/exits, in line with London Plan policy
3C.21 ‘Improving conditions for walking’ and draft London Plan policy 6.10 ‘Walking’. Though
further discussions would be required between TfL, Greenwich Council and the developer
about this, the scheme could be funded though the legal agreement, which would require a
contribution of circa £50,000. This contribution wouldl fund the design, manufacture,
installation and project management of 5 LL signs.
127 Service vehicles gaining access to the development from Norman Road follow a route
through the development in a one-way direction. Given that large articulated vehicles, which
are often attracted by retail units, are not able to access the development from Norman Road,
TfL welcomes the decision by the developer to enter into an agreement restricting the size of
vehicles accessing the site, under the terms of lease of the premises; and recommends that this
be secured by planning condition. The commitment to submit a delivery and servicing plan is
welcomed. The plan should seek to rationalise servicing trips with the aim of reducing the total
number of trips made and to avoid critical times on the road network; this should be secured by
128 Whilst the draft construction logistics plan submitted by the applicant is welcomed in
principle, given the proximity of the site to safeguarded wharves, TfL requests further
improvements, including consideration as to how the river could be used for the transportation
of construction materials, in line with London Plan policy 3C.25 ‘Freight strategy’ and draft
London Plan policy 6.14 ‘Freight’. The site is in close proximity to Greenwich Park, a venue
for the 2012 Olympic Games and it is noted that site traffic will be routed via the A2
Blackheath Road. The A2, which forms part of the Olympic Route Network and Paralympics
Route Network, will operate during the Olympic and Paralympics Games period between June
and September 2012. During this period, there will be an impact on construction works, utility
works and highway licensed activities (for example, skips and building materials) if they affect
the roads designated as a part of the ORN/PRN and some of the surrounding streets. Other
routes might also be affected and will also be required to be clear of any obstruction. These are
not yet finalised, but will be advised as further information becomes available. Given this,
highway works and licences could be affected on occasions during the Games period. Requests
to utility providers to provide any additional water, gas, electricity or telecommunications
connections should also be made sufficiently well in advance of this period.
129 The travel plan has passed it ATTrBuTE assessment tool and is generally of good
quality. The main potential improvement is to include information on how the Travel Plan will
be secured and funded. The travel plan should be secured by Section 106 agreement.
130 In conclusion, subject to the above matters being satisfactorily addressed, TfL is
satisfied that the proposed development would accord with the transport policies of the London
Climate change mitigation
131 The London Plan climate change policies as set out in chapter 4A collectively require
developments to make the fullest contribution to tackling climate change by minimising carbon
dioxide emissions, adopting sustainable design and construction measures, prioritising
decentralised energy supply, and incorporating renewable energy technologies with a target of
20% carbon reductions from on-site renewable energy. The policies set out ways in which
developers must address mitigation of and adaptation to the effects of climate change. Chapter
5 of the draft replacement plan sets out the approach to climate change and requires
developments to make the fullest contribution to minimizing carbon dioxide emissions.
132 Policies 4A.1 to 4A.8 of the London Plan focus on how to mitigate climate change, and
the carbon dioxide reduction targets that are necessary across London to achieve it.
Energy efficiency standards
133 A range of passive design features and demand reduction measures are proposed to
reduce the carbon emissions of the proposed development. Both air permeability and heat loss
parameters will be improved beyond the minimum backstop values required by building
regulations. Other features include energy efficient lighting, enhanced controls and inverter
134 Based on the information provided, it is not clear whether the proposed development
will achieve any carbon savings from energy efficiency alone compared to a 2010 Building
Regulations compliant development. The applicant should confirm that the development would
achieve 2010 Building Regulations compliance through energy efficiency alone.
135 The applicant has investigated the potential to connect into heat networks in the
vicinity of the planned development. A potential opportunity to connect the development with a
network planned for the University of Greenwich has been identified and preliminary
discussions have taken place, although this is some distance from the site. The applicant should
confirm that provision will be made within the design of the development to allow future
connection to an external district heating network.
136 A site heat network is proposed with heat supplied from an energy centre located
centrally in the basement of the main residential building. The applicant should confirm that all
dwellings and non-domestic building uses, including hotel bedrooms, would be connected to
the site heat network. The floor area of the energy centre should also be confirmed.
Combined heat and power
137 A 238kWe gas fired CHP unit is proposed as the lead heat source for the development’s
heat network. This will be sized to supply the base heat load of the main elements of the
development. A reduction in CO2 emissions of 144 tonnes per annum (25%) will be achieved
through this second part of the energy hierarchy.
138 A range of passive design measures, including shading features and high performance
glazing, are proposed to minimise the requirement for active cooling. Further information on
how the residual active cooling demand will be met should be provided.
Renewable energy technologies
139 The energy strategy proposes that biomass boilers are installed as supplementary heat
sources to the CHP unit. The biomass boilers will contribute towards space heating demand.
Space has been allocated within the energy centre for the boilers and biomass fuel storage.
Further information on the proposed fuel supply and delivery arrangements should be
140 A reduction in CO2 emissions of 207 tonnes per annum is envisaged through this third
element of the energy hierarchy.
141 The applicant has broadly followed the energy hierarchy. Sufficient information has
been provided to understand the proposals as a whole. The proposals are broadly acceptable;
however, further information is required before the carbon savings can be verified.
142 The estimated regulated carbon emissions of the development are 223 tonnes of CO2
per year after the cumulative effect of energy efficiency measures, CHP and renewable energy
has been taken into account.
143 The applicant should confirm the overall carbon dioxide emission reductions, expressed
in tonnes of CO2 per annum and percentages, relative to a 2010 Building Regulations compliant
Climate change adaptation
144 Developments are required to be adaptable to the climate they will face over their
lifetime and address the five principles set out in policy 4A.9 of the London Plan. These are: to
minimise overheating and contribution to heat island effects; minimise solar gain in summer;
contribute to flood risk reductions, including the application of sustainable drainage principles;
minimise water use; and protect and enhance green infrastructure. Specific policies cover
overheating, living roofs and walls, and water conservation. Chapter 5 of the draft replacement
London Plan considers climate change adaptation, specifically policies 5.9 through to policy
Overheating/heat island effects1
145 The applicant’s sustainability assessment confirms that cooling is proposed in those
areas with expected high heat gains, to ensure a comfortable environment.
Flood risk reduction
146 The entire site is within Zone 3 on the Environment Agency’s flood zone map and is,
therefore, at risk from fluvial and residual tidal flooding from the Deptford Creek and the River
Thames respectively. More specifically, there is an up to 1 in 100 (1%) probability of flooding
from a fluvial event and a 1 in 200 (0.5%) probability of flooding from a tidal event, in any
given year. A flood risk assessment has therefore been submitted in accordance with the
requirements of national policy (PPS25).
147 With respect to the fluvial flood risk, the site does not actually fall within the current 1
in 100 flood extent for the River Ravensbourne. The Environment Agency modelling does,
however, indicate that it falls within the 1 in 100 area that would flood if climate change were
taken into account. To mitigate the risk, the applicant proposes a design solution that would
ensure finished floor levels were constructed above the 1 in 100 year plus climate change level
for the most vulnerable uses; a safe escape for all units at a level above the 1 in 100 year plus
climate change level; and an increase in flood storage capacity within the site boundary.
148 For the tidal flood risk, the site enjoys protection from the Thames Barrier and Thames
Tidal Defences, which offer defences against flooding for a 1 in 1000 year event. Based on a
breach location at the Cutty Sark, as advised by the Environment Agency, breach modelling
undertaken in support of the Greenwich Strategic Flood Risk Assessment in 2008 indicates
that the site would not suffer flooding.
Sustainable drainage principles
149 The proposed drainage strategy accounts for the surface water drainage requirements.
At present, the site is hard-surfaced in its entirety so the development would not increase
surface run–off. To fulfil the London Plan (policy 4A.14) and draft replacement London Plan
(policy 5.13) requirements, the applicant proposes to submit a surface water run-off attenuation
strategy to reduce run-off to 50% of the current rate. This would the use of green roofs and
other appropriate sustainable urban drainage techniques to provide the required level of
150 The applicant’s commitment should be secured by an appropriate planning condition if
Greenwich Council resolves to grant planning permission for this development.
151 To fulfil the requirements of London Plan policy 4A.16 (and policy 5.15 of the draft
replacement London Plan) the applicant proposes to install water meters to help monitor and
potentially reduce operational consumption. This would be augmented by the installation of
water efficient fittings, including dual flush toilets, spray taps, low-flow showers and the use of
infra-red sensor controls for urinals and basins where appropriate.
152 The applicant’s sustainability statement indicates that the development would meet the
target levels required by the Code for Sustainable Homes and BREEAM.
153 Some 1600 sq.m. of green living roofs would be provide at roof terrace level as part of
the development. This would reduce heat loss and provide attenuation of surface water runoff,
enhance biodiversity by providing a habitat for local species and provide an attractive view
from residential properties.
Local planning authority’s position
154 Officer level discussions indicate broad support for the principle of a mixed-use scheme
along the lines proposed, subject to satisfactory details. The application is likely to be reported
to Greenwich Council’s Planning Board on 14 April 2011, with a positive recommendation
155 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor
of London) Order 2008 the Mayor is required to provide the local planning authority with a
statement setting out whether he considers that the application complies with the London Plan,
and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must
consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft
decision on the application, in order that the Mayor may decide whether to allow the draft
decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the
application, or issue a direction under Article 7 of the Order that he is to act as the local
planning authority for the purpose of determining the application and any connected
application. There is no obligation at this present stage for the Mayor to indicate his
intentions regarding a possible direction, and no such decision should be inferred from the
Mayor’s statement and comments.
156 There are no financial considerations at this stage.
157 London Plan policies on town centres, mixed-use development, hotel/tourist
accommodation, education/student accommodation, London’s ‘world city’ role, employment,
retail development; health/leisure and community facilities; housing, affordable housing, urban
design (including strategic views), inclusive access, transport and climate change (including
energy) are relevant to this application. The application complies with some of these policies
but not with others, for the following reasons:
Affordable housing: Details have not been provided of the tenure split between social
rented and intermediate affordable housing to meet the strategic aspirations provided in
policy 3A.9 of the London Plan or policy 3.12 of the draft replacement London Plan.
Furthermore, no evidence has been provided to demonstrate that the affordable housing
contribution is the maximum reasonable amount that can be supported within the
scheme, as required by London Plan policy.
Residential quality: Inadequate details are provided to allow proper assessment of the
number of flats to be served by each core within development; or to identify the location
and proportion of residential units that are single aspect, and whether any of those
would be north-facing in orientation.
Children’s play space: The play space provision is unlikely to meet the requirements of
older children (the 11-16 age group) as required by London Plan policy and associated
supplementary planning guidance on children and young people’s play and informal
Student accommodation: There is presently no evidence to confirm that the proposed
student accommodation would be occupied exclusively by members of any particular
educational institution, as required by London Plan policy in order to obtain exemption
from an affordable housing contribution.
Urban design: Inadequate information is required to enable full analysis of the impact,
if any, on strategic views; whilst the treatment of some elevations of the scheme falls
short of the design objectives of the London Plan.
Transport: As TfL has indicated in paragraphs 119 to 129 of this report, additional
works, information and undertakings are required to fulfil the transport policies of the
Energy: Inadequate information has been provided to ensure full compliance with the
requirements of the London Plan energy policies.
158 Whilst the application is broadly acceptable in strategic planning terms, on balance, it
does not comply with the London Plan.
159 The following changes might, however, remedy the above-mentioned deficiencies, and
could possibly lead to the application becoming compliant with the London Plan:
Affordable housing: The applicant should confirm the tenure split of the proposed
affordable housing with due regard to the Mayor’s strategic aspiration for a 60:40 ratio
of social rented to intermediate housing provision. A full and detailed appraisal of the
financial viability of the scheme should be submitted for assessment to the GLA and
Greenwich Council, to demonstrate that the affordable housing provision is the
maximum reasonable amount that can be sustained within the development.
Residential quality: The applicant is requested to provide further details of the number
of flats that would be served by each core within the residential development, identify
the location and proportion of flats that would be single aspect and confirm whether any
of those would be north–facing in orientation; prior to any subsequent referral of this
application back to the Mayor.
Children’s play space: The applicant is requested to consider public open spaces,
within reasonable walking distance of the site, where alternative opportunities for
outdoor games and informal sports might exist and to make a financial contribution
towards off-site play provision for the older children likely to reside within the
Student accommodation: Prior to any further referral of this application back to the
Mayor, Greenwich Council should submit the Heads of Terms or draft copy of a legal
agreement committing the occupation of the proposed student accommodation to a
specified (i.e. named) educational institution or institutions for the predominant part of
the year, to ensure compliance with the terms of occupation for student accommodation.
Urban design: The applicant should reconsider the height transition of vertical
elements within the student blocks and the treatment of their elevations, in order to
achieve greater cohesion with the adjacent residential blocks. Reconsideration is also
required of the treatment and materials of the facades of the boutique hotel, to achieve a
more elegant design that responds to the character of the North Pole public house. The
applicant is further required to produce a views analysis to demonstrate compliance
with the London Plan policy on strategic views, as it relates to Blackheath Point
Panorama (Viewing Location 6A). The height of the buildings in reference to the
Ordnance Datum should also be provided.
Transport: The applicant should provide a fully detailed response to address TfL’s
requirements for financial contributions towards the essential works specified; and
provide the necessary undertakings and information required to ensure the sustainable
and effective management of pedestrian and vehicular traffic generated by the
development, as detailed in paragraphs 119 to 129 above.
Energy: The applicant should confirm in writing whether the proposed development
would achieve carbon savings compliance with the 2010 Building Regulations from
energy efficiency alone; how the demand for residual active cooling would be met; and
detailed information on the intended supply and delivery arrangements for biomass fuel.
for further information, contact Planning Decisions Unit:
Colin Wilson, Senior Manager - Planning Decisions
020 7983 4783 email firstname.lastname@example.org
Justin Carr, Strategic Planning Manager (Development Decisions)
020 7983 4895 email email@example.com
David Blankson-Hemans, Senior Strategic Planner, (Case Officer)
020 7983 4268 email firstname.lastname@example.org