planning report PDU/2742/01
1 June 2011
Abell House & Cleland House, Pimlico
in the City of Westminster
planning application no.11/03034/FULL
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.
Redevelopment to provide two new buildings for 285 residential units. The proposal includes
basement excavation, gym with swimming pool, hard and soft landscaping and highway
works including 245 vehicle and 377 cycle parking spaces.
The applicant is Berkeley Homes and the architect is DSDHA.
The application raises strategic planning matters regarding the functions of the central
activities zone, housing and affordable housing, urban design and access, climate
change and transport.
That Westminster City Council be advised that the application does not comply with the
London Plan, for the reasons set out in paragraph 86 of this report; but that the possible
remedies set out in paragraph 88 of this report could address these deficiencies.
1 On 27 April 2011, the Mayor of London received documents from Westminster City
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 7 June 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 Category 1A1 of the Schedule to the Order 2008:
“Development which comprises or includes the provision of more than 150 houses, flats, or
houses and flats.”
3 Once Westminster City 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 comprises two separate office buildings on either side of the junction of Page
Street with John Islip Street. Abell House is located to the west and comprises ground plus
eight commercial storeys and is currently a vacant office building. Cleland House, located to
the east, is also ground plus eight commercial storeys and is currently vacant. Originally
conceived and constructed by TP Bennet around 1930, both buildings were over-clad in 1985
using matching dark brown marbleised granite cladding, giving a highly polished appearance.
7 The area is a mix of Government, commercial, cultural and residential buildings. The
most notable being Thames House (Security Services) to the east, Tate Britain and Millbank
Tower to the south and south east, Millbank Estate to the west and St John’s, Smith Square,
Westminster Abbey and the Houses of Parliament to the north. The scale of development in
the surrounding area is predominantly between 8 to 10 storeys with the exception of the
Millbank Tower (29 storeys).
8 The nearest Transport for London Road Network (TLRN) is Millbank (A3212), 150
metres to the east. The nearest Strategic Road Network (SRN) is a different section of the
A3212, 150 metres away to the north east. The nearest London Underground station is
Pimlico which is located approximately 750 metres away, equivalent to a 9 minute walk, and is
served by the Victoria line. Westminster London Underground station is located
approximately 850 metres to the north of the site and is served by the Jubilee, District and
Circle lines. Bus routes 88 and C10 serve Marsham Street directly to the north-west of the
sites while route 87 serves Millbank directly to the east of the sites. Hence, the public transport
accessibility level in the middle of John Islip Street between the two sites is 4, where 1 is low
and 6 is high. This equates to a good level of accessibility. The site lies within the area covered
by the London Cycle Hire Scheme, docking stations are located at Millbank Tower, Horseferry
Road and Smith square, all within 200m of the site.
Details of the proposal
9 The proposal comprises two new residential blocks on the respective plots. Both will be
groundfloor plus twelve storeys at their tallest point. The quantum of affordable housing and
the tenure split is still subject to negotiation. The applicant’s intention is for Cleland House to
accommodate a mix of tenures and Abell House to be stand alone market accommodation. The
current bedroom size mix by tenure is show as follows:
Table 1 bedroom size mix
1-bed 2-bed 3-bed 4-bed Total Habitable rooms
26 74 41 4 145 458
Social rent 13 20 12 5 50 159
Intermediate 20 11 0 0 31 73
Market 9 20 30 0 59 198
Overall total 68 125 83 9 285 888
10 GLA officers provided pre-application advice published on 3 March 2011. The key
strategic issues raised at that time related to the principle of development, specifically the loss
of office in the Central Activities Zone (CAZ); housing and affordable housing; design, access
and heritage matters, and climate change.
Strategic planning issues and relevant policies and guidance
11 The relevant issues and corresponding policies are as follows:
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
Mix of uses London Plan
Regeneration London Plan; the Mayor’s Economic Development Strategy
Transport London Plan; the Mayor’s Transport Strategy; PPG13
Parking London Plan; the Mayor’s Transport Strategy; PPG13
Access London Plan; PPS1; Accessible London: achieving an inclusive
environment SPG; Planning and Access for Disabled People: a good
practice guide (ODPM)
Equal opportunities London Plan; Planning for Equality and Diversity in Meeting the
spatial needs of London’s diverse communities SPG; Diversity and
Equality in Planning: A good practice guide (ODPM)
Tall buildings/views London Plan; RPG3A, Revised View Management Framework
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
Historic Environment London Plan; PPS5
12 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 2007 Westminster Unitary Development Plan,
the 2011 Westminster Core Strategy (adopted 26 January 2011), and the London Plan
(consolidated with alterations since 2004). The Mayor’s draft replacement London Plan
(October 2009) which underwent Examination in Public in 2010 and upon which the Panel has
now reported is a relevant material consideration of significant weight.
Principle of development
13 The application sites fall within the Central Activities Zone (CAZ), as identified in the
London Plan. London Plan Policy 3B.2 states that boroughs should “promote the provision of
additional space and the rejuvenation of existing office space in CAZ”. London Plan Policy 5G.3
recognises CAZ as “…the country’s most important strategic office location” and within CAZ seeks
to “…ensure adequate capacity to meet future demand”. The London Plan encourages the
renovation and renewal of existing office stock to increase and enhance the quality and
flexibility of London’s office market offer and promotes the provision of additional space in the
14 The Mayor’s emerging plan further underlines this approach at policy 4.2 Offices c) and
d) which encourages the “renewal and modernisation of existing office stock in viable locations to
improve its quality and flexibility”, and “seek increases in current stock where there is authoritative,
strategic and local evidence of sustained demand for office based activities in the context of policies 2.7,
2.9, 2.13, 2.15-2.17”. Policy 2.10 Central Activities Zone – strategic priorities also seeks, “in
appropriate parts of the CAZ… ensure that development of office provision is not strategically
constrained and that provision is made for a range of occupiers especially the strategically important
financial and business services”. Policy 2.11 Strategic functions also seeks to ensure that
development complements and supports the cluster of other strategically important specialised
CAZ uses. Map 2.3 indicates that the site falls within the ‘mixed uses with a strong state
character’ zone of the CAZ. Policy 2.12 Central Activities Zone – predominantly local
activities also underlines the need to “protect and enhance predominantly residential neighbourhoods
within the CAZ and develop sensitive mixed use policies to ensure housing does not compromise CAZ
strategic functions elsewhere in the zone”.
15 The site comprises two existing office buildings. As set out above, CAZ is prioritised
for this type of land use. Transfer to other land uses must be carefully considered. As above
there is a strong State character to this area but it is focussed largely to the north and east of
the application site. To the west the area is also defined by a strong residential character.
16 The policy test in this instance is the extent to which the loss of office undermines this
particular function of the CAZ both locally and in terms of the implications to wider CAZ
functions through the defined clusters, in this case the ‘State character’.
17 The loss of office in this instance has been considered in part by the applicant. The
applicant provides a local land use map, which supports the notion that the area has a stronger
residential character but retains its State character to the north and east.
Figure 1 Local land use map: source planning statement
18 It is however important that the strategic priorities for office accommodation in the
CAZ are considered as part of the overall approach to redevelopment and that the State
function is not undermined. As set out in the emerging plan (paragraph 2.41 – 2.42) “In
practical terms the Mayor intends to deliver this commitment… (to protect & enhance 2.41).. by
continuing to support the unique functions the CAZ fulfils for London, the UK and internationally and
the development needed to sustain them”. The plan continues that “policies favouring mixed use
development should be applied flexibly on a local basis so as not to compromise the CAZ's strategic
functions, while sustaining the predominantly residential neighbourhoods in the area”. Whilst it is
clearly a strong residential neighbourhood the applicant needs to evidence the market
conditions regarding office release locally and marketing evidence undertaken regarding
demand for office provision in this location. Fundamentally the strategic function in this
instance is the opportunity to maintain the strong state functions through office
accommodation. Whilst there is a recognised residential character the office market in the west
part of the CAZ is particular constrained and therefore an evidence based approach is need to
ensure the defined function and character is not undermined.
19 London Plan policy 3A.1 seeks to increase London’s supply of housing and sets a
London-wide target of 30,500 additional homes per year between 2007/8 and 2016/17. Table
3A.1 sets borough housing targets, of which Westminster’s is 680 additional homes per year
between 2007/8 and 2016/17. The draft replacement London Plan sets a target of 770
additional homes between 2011 and 2021. Policy 3A.3 of the London Plan (and policy 3.2 of the
draft replacement London Plan) seek to ensure that development proposals achieve the
maximum intensity of use taking into account local context, the design principles of the
London Plan and public transport capacity. A distinction in the Mayor’s emerging approach to
the issue of density is the move from maximise to optimise site capacity.
20 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.
21 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. Policy 3.13 of the draft
replacement London Plan establishes the same broad principles.
22 At local level UDP policy H4 seeks affordable housing contributions on sites over 0.3
hectares or on sites with 10 or more dwellings. Policy CS16 of the adopted Core Strategy also
sets out that within the CAZ a maximum of 30% affordable housing will be sought.
23 The current housing offer is set out in table 1. The quantum, tenure split and bedroom
size mix remains the subject of further discussions. The applicant has provided a viability
appraisal to substantiate the proposed approach. At present this material has not been
scrutinised, however the GLA wish to jointly commission an independent assessment of the
viability case with the City Council. GLA officers would welcome further discussion regarding
the brief for an agreed valuer. It is important this process is undertaken prior to the Mayor’s
final determination of the case.
24 It is also important that the implications of the new affordable housing model, as
outlined in the HCAs affordable housing programme framework, as well as changes to funding
and definitions of affordable housing, are recognised in testing the approach. It may be
appropriate to consider the use of a review mechanism within the section 106 agreement to
ensure the policy regarding the maximum reasonable amount is deliverable.
25 As above, the availability of HCA funding and changes to the definitions of affordable
housing will be a determining factor regarding the type of affordable housing products that will
be secured. The planning policy position is, however, currently unchanged. London Plan
Policy 3A.9 states that affordable housing 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 within the affordable element 70% of housing should be
social and 30% intermediate provision, and of the promotion of mixed and balanced
communities. Policy 3.12 of the draft replacement London Plan states that within the 13,200
affordable homes per year target, the Mayor will, and boroughs and other partners should, seek
to ensure that 60% is social housing and 40% is intermediate. The current offer set out in table
1 provides a tenure spite set at 68/32 (social/intermediate). Further discussion will be
necessary in line with the independent assessment of the viability.
Mix of units
26 London Plan Policy 3A.5 encourages a full range of housing choice. This is supported
by the London Plan Housing Supplementary Planning Guidance, which seeks to secure family
accommodation within residential schemes, particularly within the social rented sector, and
sets strategic guidance for councils in assessing their local needs. Policy 3.12 of the draft
replacement London Plan states that within affordable housing provision, priority should be
accorded to family housing. Recent guidance is also set out in the draft revised interim Housing
Supplementary Housing Guidance (October 2009) and draft replacement London Plan policy
3.8, which seeks to widen housing choice.
27 A mix is provided (as set out in the above table 1) but may be subject to change. The
proposal will, however, be expected to accord with the strategic and local requirement for a
significant proportion of family accommodation. Given the nature of the location it is
important that the units will be affordable and are consistent with the GLA’s affordability
criteria. This will need to be discussed further with the GLA along with the tenure and
quantum discussion in general.
28 London Plan Policy 3A.3 outlines the need for development proposals to achieve the
highest possible intensity of use compatible with the local context, the design principles within
Policy 4B.1 and public transport capacity. Table 3A.2 of the London Plan provides guidelines
on density in support of policies 3A.3 and 4B.1. As mentioned above, Policy 3.4 of the draft
replacement plan moves away from maximising site capacity to optimising development
potential with a stronger focus on local context in particular (Table 3.2).
29 Based on the character and location of the site the London Plan suggests a density of
between 650-1,100 habitable rooms per hectare. At local level the UDP seeks that the density
is reflected by the range of zones shown on the proposals map. This sets a density guidance
range of between 400-850 habitable rooms per hectare. The planning statement suggests the
target density as 1,346 habitable rooms per hectare.
30 This target is above the guidance in the London Plan and the UDP. The applicant
seeks to justify this on the basis of design quality. Design quality is one of many factors that
are relevant in the consideration of this aspect of the scheme. Given the quantum and bedroom
size mix of affordable housing is still subject to negotiation the density will also be subject to
change. It is important that this is considered in light of the guidance in the emerging London
Plan which seeks to optimise rather that maximise site potential. Other factors in addition to
design quality are relevant including the local context, contribution to family housing, open
space and sustainability. Design matters are considered in further detail below.
31 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 maximising the potential of
sites, the quality of new housing provision, tall and large-scale buildings, built heritage, views,
and the Blue Ribbon Network. 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).
32 At the meeting the design team raised the issue of design constraints being imposed by
the Security Services located in Thames House, adjacent to Cleland House. These have not
been articulated in the application and it remains important that GLA officers are clear on how
these have influenced the design of the blocks. In particular the use of balcony access, front
doors onto the street, fenestration, materials and facade detail. The applicant should provide
details of the agreed approach with the Security Services.
Circulation and layouts
33 The ground floor arrangement to Abell house has been amended since pre-application
discussions. It is unclear which layout is being adopted. Page 55 of the design and access
statement shows a different entrance to the layout shown later in the drawings (drawing
number 195_P20.013). The approach requires a level change to provide safe refuge in the
event of flooding. In both drawings the approach does not provide a truly inclusive solution.
Whilst the layout shown on page 55 creates generous streetscape it also provides two separate
entrances. The main entrance via steps and the secondary route to a double sided lift. This
approach is disappointing and segregates anyone wishing to access the building using the lift to
deal with the level change. This layout should be revisited and clarified by the design team. As
raised at pre-application the design team may wish to consider direct access from street into
the duplex units on John Islip Street to provide further active frontage.
34 The ground floor arrangement to Cleland House has similar level change problems.
The market entrance is located on the west side of the building and is grand with views into
the courtyard garden. It is, however, split to deal with what appears to be an unnecessary level
change of 300mm. As set out in page 56 of the design and access statement, there is no ground
floor residential accommodation at the market side of the building and therefore no need for
flooding refuge area. The 300mm step level change is therefore unnecessary and results in two
entrance doors, creating further segregation.
35 The affordable block entrance is located on the east side, which is acceptable in principle
but the level change to the affordable block needs a more inclusive approach. As discussed at
pre-app the current platform lift is a poor solution to managing the level change. At pre-
application stage, GLA officers suggested relocating the southern lift core with the stair core
and introduce a double-sided lift opening east and north to address the level change without
the need for a platform lift. This has not been considered and it remains unclear what other
options have been tested, including ramping up along the street elevation.
36 As raised at pre-application, the introduction of front doors to Thorney Street for the
duplex units would also help provide active uses along what is a very controlled and defensive
environment at present. The double height entrance to the affordable block is, however, a
positive introduction into the street.
37 The Mayor has published his draft Housing Design Guide and aspects of this, notably
the minimum space standards for dwellings, are also reflected in the draft replacement London
Plan. Policy 3.5 of the draft replacement London Plan introduces a new policy on the quality
and design of housing developments. Part A of the draft policy states that housing
developments should be of the highest quality internally, externally and in relation to the wider
environment. Part C of the draft policy states that new dwellings should meet the dwelling
space standards set out in Table 3.3, have adequately sized rooms and convenient and efficient
room layouts. Part E of the draft policy states that the Mayor will provide guidance on
implementation of this policy including on housing design for all tenures. The reasoned
justification provides further guidance and explanation. In particular paragraph 3.31 states
that other aspects of housing design are also important to improving the attractiveness of new
homes as well as being central to the Mayor’s wider objectives to improve the quality of life of
38 Whilst at present the Mayor’s interim London Housing Design Guide applies to grant
funded housing and London Development Agency development, its guidelines are considered
by the Mayor to be best practice in residential design. Additionally, the principles of the guide
have been written into the newly released draft Housing SPG (EiP consultation version), in
support of policy 3.5, and which will gain increasing weight through to its expected adoption at
the end of 2011. This will apply to all development, including market housing.
39 A breakdown of the space standards for each unit is provided in the schedule supporting
the drawing set (7.1). These are however shown in gross external area and should be updated
to allow comparison to the Mayor’s standards, gross internal area. As raised above, the
constraints arising from the Security Services need to be understood, in particular given the
lack of balcony space being provided for the affordable block. As suggested at pre-application,
other design options for provision of outdoor space, such as winter gardens may be an
40 The proportion of single aspect units has been minimised in the affordable block to one
per floor, the design team should however consider wrapping this unit around to the eastern
elevation to provide some easterly aspect. Another solution may be to set the units either side
of the single aspect unit back into the facade to allow a break forward creating some east or
41 Abell House includes a fairly significant proportion of single aspect north facing units
(between two and three per floor). The size of these units should be clarified and access to
balcony space should be considered. Currently whilst Abell House contains only private units,
these units are poor in terms of the aspect and access to outdoor private residential amenity
42 Whilst there are positive elements to the layout, including the number of units accessed
off a single core, (which is within the maximum of eight per core) the design and access
statement has not clearly assessed how the scheme embodies the principles of residential
quality. At pre-application a table comparing the unit types against the various standards,
including individual room sizes and storage space, was requested. It is important that this is
submitted to allow officers and the Mayor to make a judgement regarding residential quality.
43 London Plan policy 4B.1 and 4B.2 underpin the Mayor’s aspiration to create world class
architecture that inspires, excites and delights. The proposal will be high quality in terms of
the appearance and materiality. The massing, bay study, materials and design concept is
strong and the fabric of the building will fit in the established pattern of the surrounding
environment. Full renders have been provided which demonstrate the scale and form fit
comfortably into the existing context of 10-12 storey buildings. The architecture is seamless in
its appearance in the context of the existing surrounding stone buildings. The architectural
approach is therefore broadly supported.
Figure 2 view towards Abell House (source: Design and Access Statement)
Figure 3 view towards Cleland House (source: Design and Access Statement)
Strategic views and built heritage
44 London Plan policies 4B.11 to 4B.15 set out the strategic approach to the protection and
enhancement of London’s rich built heritage. The broad architectural approach is supported,
the impact of the proposal on the setting of nearby listed buildings, including St John’s, Smith
Square, has been assessed as part of the visual impact assessment. The site is not in the
conservation area, but is adjacent to the Millbank and Smith Square Conservation Areas
Figure 4 adjacent Conservation Areas (source: Design and Access Statement)
45 The analysis suggests that the proposal fits comfortably into the existing townscape
and would not harm the setting or character and appearance of surrounding heritage assets.
46 London Plan policies 4B.16 to 4B.18 set out the strategic approach to the management
of strategically important views. The visual impact assessment demonstrates the impact of the
proposals is acceptable given in most instances the building does not appear in any of the key
Children’s play space
48 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 et out in the Mayor’s supplementary planning guidance
‘Providing for Children and Young People’s Play and Informal Recreation’ the total child
population anticipated will be 111 children. The applicant has used Westminster City Council
methodology for the over-5 age group and the Mayor’s supplementary planning guidance
methodology to calculate expected under-5’s population (given the WCC methodology is based
on school placement which excludes under-5’s). The applicant’s anticipated child population
comes to approximately 102 children within the development. The table below sets out the age
breakdown on the basis of the applicants calculations:
Figure 5 expected child population (source: play space report)
49 The SPG promotes use of local data to calculate expected population where this is
available therefore the approach is broadly acceptable. The GLA 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 1,020sq.m. of playspace.
50 The development identifies a total 1,985 sq.m. of open space across both sites. 770 sq.m.
of this is specifically intended as playable space for under-5’s. This is split as 520 sq.m. at
Cleland House and 250 sq.m. at Abell House. Whilst it would appear adequate in terms of the
guidance in the SPG, the applicant does not disaggregate the two sites in terms of expected
demand. GLA estimate that 22 under 5’s will occupy the Cleland House and 19 Abell House.
In both cases the provision is adequate. The applicant also provides detailed breakdown of
nearby facilities for older children. These include Victoria Tower Gardens North, Grosvenor
Estate, Vinvent St Playground and MUGA and Causton Street Playground which fall within
400 metres of the sites. Beyond that, but within 800 metres is Trinity Mews Playground and
MUGA, Tachbrook MUGA and, on the other side of the river in Lambeth, Archbishop’s park
51 The assessment is robust and demonstrates sufficient consideration and provision will
be included as part of the development for play on-site and through existing facilities within a
Access and inclusive design
52 London Plan policy 4B.5 and the corresponding draft replacement London Plan policy
7.2 seek to ensure that proposals achieve the highest standards of accessibility and inclusion
(not just the minimum), and this and all developments should seek to better minimum access
requirements. Design and access statements should explain the design thinking behind the
application and demonstrate how the principles of inclusive design, including the specific access
needs of disabled and older people, have been integrated into the proposed development and
how inclusion will be maintained and managed. The development should aim to meet the
highest standards of accessibility and inclusion.
53 Policy 3A.5 of the London Plan and policy 3.8 of the draft replacement London Plan
require that 100% of new homes meet the Lifetime home standards and that 10% of new
housing is designed to be wheelchair accessible or easily adaptable for residents who are
54 The applicant confirms a commitment to Lifetime Home Standards and 10% wheelchair
units. Flat layouts are provided to determine the standards will be met. This should be
conditioned by the City Council.
55 There needs to be flexibility for allocation of parking spaces as residential units are
adapted in the future and for Blue Badge users who may reside in the Lifetime Home
apartments. The arrangements for the future review of demand and supply of bays for disabled
people should be reflected in the parking management and travel plans. This can also be
conditioned by Westminster City Council.
56 The issue of access into the affordable block is considered above; it appears that there
would be step-free access to the other common areas, with lift access to all public areas and
57 Extending the Lifetime Home concept to the neighbourhood level can help to ensure
that the public realm, amenity spaces, the parking areas, the routes to and from the site and
links to adjacent public transport and local services and facilities are all designed to be
accessible, safe and convenient for everyone, particularly disabled and older people. This
concept can also help to meet the specific needs of older people. The pedestrian links to the
adjacent roads are level or gently ramped. The lighting design is particularly important to
create safe, well and evenly light routes through and into the site. This should be conditioned
by the City Council.
58 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. The
corresponding policies within the draft replacement London Plan are set out in chapter 5.
Climate change mitigation
59 Policies 4A.2 to 4A.8 of the London Plan focus specifically on how to mitigate climate
change, and the carbon dioxide emissions reduction targets that are necessary across London
to achieve this. Developments are required to make the fullest contribution to tackling climate
change by minimising carbon dioxide emissions (be lean), adopting sustainable design and
construction measures and prioritising decentralised energy (be clean), including renewables
60 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
parameter will be improved beyond the minimum values required by building regulations.
Other features include low energy lighting and mechanical ventilation with heat recovery.
61 Based on the information provided, it is not possible to verify whether the proposed
development would achieve 2010 Building Regulations compliance with energy efficiency
measures alone. The applicant should model the proposed measures using 2010 Building
Regulations approved software. This is necessary in order to demonstrate compliance with
2010 Part L of the Building Regulations with the use of energy efficiency alone.
62 The applicant has stated that it is impractical to connect to the nearby Pimlico Heat
Network. Given the proximity of the proposed development to the Pimlico Heat Network the
applicant should provide evidence of correspondence with the Pimlico heat network operators
before this option can be rejected.
63 The applicant has committed to the installation of a site wide heat network served from
a single energy centre located at the basement of the Cleland House building. This heat
network would link the two buildings of the proposed development either via an underground
tunnel or buried pipe work.
64 The applicant is proposing to install a gas fired combined heat and power unit of
140kW electrical capacity as the lead heat source for the development. Given the small scale of
the proposed residential development and the complexity involved in managing the use of
combined heat and power at that scale, in particular with regards to the electricity sales,
further information should be proved in relation to the strategy for the selling of the electricity.
65 Following up the comments above, the applicant should use 2010 building regulations
modelling to recalculate the carbon saving that this option would achieve should it be
66 Passive design measures proposed include the use of adequate thermal mass and facade
shading features to limit the need for cooling. Under the current proposals active cooling will
however be available to all private apartments. The applicant should clarify how this would be
67 The overall strategy would achieve a reduction of carbon emissions of approximately
25% beyond 2010 Building Regulations. As a consequence no renewable energy on-site is
being proposed. The applicant should recalculate the carbon savings achieved using 2010
Building Regulations approved modelling before the GLA can consider if the approach is
acceptable in terms of the strategy overall.
68 The applicant should provide an estimation of the regulated carbon emissions of the
development after the cumulative effect of energy efficiency measures and CHP has been taken
into account. The overall carbon savings should be calculated using 2010 building regulations
Climate change adaptation
69 The London Plan promotes five principles in Policy 4A.9 to promote and support the
most effective adaptation to climate change. These are to minimise overheating and contribute
to heat island effects; minimise solar gain in summer; contribute to flood risk reduction,
including applying sustainable drainage; minimising water use; and protect and enhance green
infrastructure (the corresponding draft replacement London Plan policy is policy 5.3). There
are specific policies covering overheating, living roofs and water. Further guidance on these
policies is given in the Mayor’s SPG Sustainable Design and Construction.
70 Policy 4A.11 and draft London Plan policy 5.11 seek major developments to incorporate
living roofs and walls where feasible. Policy 4A.14 of the London Plan and Policy 5.13 of the
draft replacement plan seek to ensure that surface water run-off is managed as close to its
source as possible and sets out a hierarchy of preferred measures to achieve this. Policy 4A.16
of the London Plan and policy 5.15 of the draft replacement plan seek to ensure that new
development has proper regard to the impacts on water demand and existing capacity by
minimising the use of treated water and maximising rainwater harvesting. Policy 5.10 of the
draft replacement London Plan is also noted, stating that the amount of urban greening in CAZ
should be increased.
71 There are limited passive adaptation methods to control surface water. The applicant
has not considered green or brown roofs for example, and surface water will be dealt with
through attenuation tanks. The site is within flood zone 3 and whilst appropriate mitigation in
terms of residential units has been integral in the design the applicant should consider use of
green or brown roofs in the context of the CAZ location. Water efficient sanitary units will be
installed, however the City Council should ensure the maximum water use targets of 105 litres
per person per day is conditioned.
Transport for London’s comments
73 A total of 245 car parking spaces will be provided at basement level to serve the 285
proposed residential units. This is equivalent to a car parking per unit ratio, across both the
sites, of 0.86. This level of car parking contradicts London Plan policy objectives to ensure
that on-site car parking at new developments is the minimum necessary and that there is no
over-provision that could undermine the use of more sustainable non-car modes. As such, TfL
will require a lower level of car parking within the submitted application than that currently
74 TfL would welcome the provision of two on street car club spaces and requests the
applicant enters into discussion with the City Council on how these spaces are to be secured.
A reduced car parking provision and car club spaces located on street will ensure consistency
with draft replacement London Plan policy 6.13 Parking and London Plan policy 3C.23 Parking
75 TfL supports that a total of 377 cycle spaces are proposed for residential use in line with
draft replacement London Plan standards. The proposed basement cycle parking should be
well lit and covered by CCTV. Additional visitor cycle parking will need to be included ideally
on street so not to compromise the secure nature of the internal cycle parking. TfL is satisfied
that allowing staff access to the proposed leisure facilities and associated showers and changing
rooms would be sufficient to cater for any expected demand in this particular instance.
76 To ensure that sufficient capacity is available, the minimum number of docking points
provided by the proposed Mayor’s Cycle Hire scheme should be no lower than 25. Further
discussions between the applicant, Westminster City Council and TfL are required to establish
the final design and layout of the proposed Mayor’s Cycle Hire docking station. A contribution
of £132,000 towards establishing the docking station is also requested, to be secured within
the section 106 agreement. TfL requests that a minimum of 3 additional cycle parking spaces
are provided and allocated for staff use only. The provision of a Mayors Cycle Hire docking
station, visitor cycle parking and access to showering and changing facilities are required to
ensure conformity with London Plan policy 3C.22 Improving conditions for cycling and draft
replacement London Plan policy 6.9 Cycling.
77 To promote inclusive accessibility to all users of the proposed development and
encourage bus use, TfL requests that the nearby bus stops on John Islip Street are upgraded,
and accordingly requests a contribution of £20,000 be secured within the section 106
agreement. This will ensure consistency with London Plan Policy 3C.20 Improving conditions
for buses and draft replacement London Plan policy 6.7 Buses, bus transits, trams.
Construction, Deliveries and Servicing
78 TfL welcomes that a delivery and servicing plan and construction and logistics plan will
both be secured by condition. The delivery and servicing plan should be linked to the travel
plan in line with TfL’s new travel plan guidance. The construction and logistics plan should be
a standalone document that enables construction impacts to be managed, minimising impact on
the highway network and transport system. These documents should be secured by condition
to ensure consistency with London Plan policies 3C.17 Tackling congestion and reducing traffic
and 3C.25 Freight strategy and draft replacement London Plan policy 6.14 Freight.
79 TfL welcomes the submission of a full travel plan and requests this is secured through
the section 106 agreement. A wide range of green travel planning measures should be secured,
monitored and funded through the section 106 agreement. Examples include subsidised Oyster
cards, cycle vouchers/free bicycles, subsidised car club membership, marketing and
promotional events. An appropriate figure, to fund their provision should be agreed with TfL
and secured within the section 106 agreement.
80 Securing of these travel plan measures within the section 106 agreement will ensure
consistency with London Plan Policy 3C.2 Matching development to transport capacity and draft
replacement London Plan policy 6.3 Assessing transport capacity.
81 In summary, the level of car parking should be reduced substantially, car clubs should
be located in a publically accessible location, a plan detailing the location of the proposed
Mayor’s Cycle Hire Docking station and a contribution of £132,000 to facilitate its
implementation is required in addition to visitor cycle parking along with a contribution of
£20,000 towards local bus stops. In addition both a construction and logistics plan and a
delivery and servicing plan will need to be secured by condition. Sustainable travel plan
measures should also be secured and funded through the section 106 agreement.
Local planning authority’s position
83 The City Council’s position is currently unknown.
84 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.
85 There are no financial considerations at this stage.
86 London Plan policies on CAZ, affordable housing, housing mix, density, urban design,
access, climate change and transport are relevant to this application. The application complies
with some of these policies but not with others, for the following reasons:
Central Activities Zone: (non-compliant) It is not clear the extent to which demand for
office provision in this location is required, and the extent the site has been considered
for marketing. The proposals should not undermine the functions of the CAZ and in
particular the mixed use and state character present locally.
Affordable housing, tenure split, bedroom size mix and density (non-compliant):
Currently it is not clear that the proposals will provide the maximum reasonable
amount of affordable housing. The financial appraisal requires scrutiny to ensure the
quantum proposed represents the maximum reasonable amount of affordable housing in
this case. These discussions will inform the tenure split, bedroom size mix and density.
Urban design and access (non-compliant): The report identifies some detailed design
matters that require further consideration, including the arrangements to the entrance
of the buildings, provision of front doors onto the street and residential quality
including space standards and number and layout of north facing single aspect flats.
Climate change mitigation (non-compliant): Evidence to support meeting 2010 Building
Regulations through energy efficiency alone, links to the Pimlico heat network,
provision of cooling, strategy for the sale of electricity at this scale and the lack of
renewable energy contribution.
Climate change adaptation (non-compliant): provision of green roof needs further
Transport (non-compliant): the level of car parking, car clubs, location of the Mayor’s
Cycle Hire Docking station, financial contributions and conditions required.
87 On balance, the application does not comply with the London Plan.
88 The following changes might, however, remedy the above-mentioned deficiencies, and
could possibly lead to the application becoming compliant with the London Plan:
Central Activities Zone: Evidence to support the scale of demand for office in this
location should be provided.
Affordable housing: The viability appraisal should be independently scrutinised and
further discussion should commence on all housing related matters.
Urban design and access: The design team need to reconsider the ground floor access
arrangements, update the space standards schedule to allow direct comparison to the
Mayor space standards, and comprehensively revisit residential design quality of the
north facing single aspect units. Lifetime homes and 10% wheelchair units should be
conditioned by the City Council.
Climate change mitigation: Further technical material is required regarding energy
efficiency, the options considered for linking into Pimlico heat network, provision of
cooling and renewable energy contribution.
Climate change adaptation: provision of green roof.
Transport: The level of car parking should be reduced substantially, car clubs should be
located in a publically accessible location, a plan detailing the location of the proposed
Mayor’s Cycle Hire Docking station and a contribution of £132,000 to facilitate its
implementation is required in addition to visitor cycle parking along with a contribution
of £20,000 towards local bus stops. In addition both a construction and logistics plan
and a delivery and servicing plan will need to be secured by condition. Sustainable
travel plan measures should also be secured and funded through the section 106
for further information, contact Planning Decisions Unit:
Colin Wilson, Senior Manager - Planning Decisions
020 7983 4783 email email@example.com
Justin Carr, Strategic Planning Manager (Development Decisions)
020 7983 4895 email firstname.lastname@example.org
Matthew Carpen, Case Officer
020 7983 4272 email email@example.com