1. city development pipeline, 75,000 sq ft +, 2013 · pdf file6 bevis marks, ec3 cottons...

1. CITY DEVELOPMENT PIPELINE, 75,000 SQ FT +, 2013-2017 INCLUDING U/O/ LET

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2013 2014 2015 2016 2016+ 2017 2017+

New 999,989 sq ft 2,025,755 sq ft 1,306,000 sq ft 2,473,853 sq ft 2,271,370 sq ft 703,000 sq ft 5,982,526 sq ft

Returning 553,329 sq ft 750,000 sq ft 578,676 sq ft 1,247,000 sq ft 71,000 sq ft 275,000 sq ft 1,295,733 sq ft

Total 1,553,318 sq ft 2,775,755 sq ft 1,884,676 sq ft 3,720,853 sq ft 2,342,370 sq ft 978,000 sq ft 7,278,259 sq ft

2013

2014

2014

2014 2015 2016 2016+ 2017 2017+

Concept MasterplanGround Floor Plan

The concept design at No.3 Lower Thames Street has not been developed in consultation with the adjoining landowners and is included solely for the purposes of demonstrating the opportunity and potential benefits of a co-ordinated approach to mixed use development across both sites.

Concept MasterplanRoof Plan

The concept design at No.3 Lower Thames Street has not been developed in consultation with the adjoining landowners and is included solely for the purposes of demonstrating the opportunity and potential benefits of a co-ordinated approach to mixed use development across both sites.

richxm

Typewritten Text

17

REPRESENTATIONS TO THE LOCAL PLAN

DP9

REPRESENTATIONS TO

THE CITY OF LONDON LOCAL PLAN

REPRESENTATIONS SUBMITTED

ON BEHALF OF NORTHERN & SHELL

February 2014


DP9

CONTENTS

1.0 Introduction 1

2.0 Policy CS9: Thames and the Riverside 2

3.0 Policy DM 1.1: Protection of office accommodation 9

APPENDICES

Appendix A – GM Real Estate letter dated 27 February 2014

Appendix B – PLP Concept Masterplan

Appendix C – PLP Development Option for 10 Lower Thames Street


1

1.0 INTRODUCTION

1.1 Northern & Shell are the freehold owners of their headquarter offices located at 10

Lower Thames Street, London. Northern & Shell was founded in December 1974 as

the publisher of the music magazine International Musician and Recording World.

Northern & Shell is a major force in British and worldwide media, with a portfolio

including newspapers, magazines and television.

1.2 Northern & Shell’s current office building does not meet their operational needs, and

Northern & Shell wish to explore the opportunity to redevelop their site for

residential and commercial development, including their new headquarters. The site

could also form part of a comprehensive masterplan with the adjacent site to the west

at No.3 Lower Thames Street, allowing the delivery of significant planning benefits.

1.3 Since publication of the Local Plan in January 2013, the City of London has made

modifications to the Local Plan. These modifications seek to further restrict the loss

of office floorspace in the City, including the Thames Policy Area. Northern & Shell

is concerned that this will prevent sustainable mixed use development coming

forward. Northern & Shell object to the approach outlined in the Local Plan, and set

out in detail below why this policy approach is not sound and should be modified.


2

2.0 Policy CS9: THAMES AND THE RIVERSIDE

2.1 The Northern & Shell site and the adjacent site to the west (No.3 Lower Thames

Street), fall within an area defined as the Thames Policy Area within the Local Plan on

Policies Map B. The area stretches along the southern boundary of the City from

Temple in the west to the Tower of London in the east. It therefore represents a

significant stretch of the river which is very different in character to the main financial

centre of the City to the north of Lower Thames Street. Recognising this distinct

character, the Local Plan, under Policy CS9, seeks to ensure that the City capitalises

on its unique riverside location. However, Northern & Shell object to the current

wording of Policy CS9 in respect of its emphasis on promoting solely commercial and

office-led development and consider it fails to realise the unique opportunity of the

riverside location as a diverse and mixed use location.

The long term viability of the current office building and scope for

redevelopment

2.2 The building at 10 Lower Thames Street is currently in office use. However, the

building provides poor quality office accommodation which does not meet modern

office occupier needs. It has had little investment or refurbishment since it was built

in 1985.

2.3 Our client has asked GM Real Estate to consider the potential long term viability of

redeveloping the site for office use. A letter from GM Real Estate is contained in

Appendix A. GM Real Estate conclude that:

The building is dated and refurbishment of the building is not viable. As a

consequence the owners have been forced into letting surplus space at

uneconomic rents to assist on cost mitigation.

GM Real Estate has looked at redevelopment options on the site over the

last 5 years, but the viability tests have shown that there are insufficient

levels of return to make the scheme viable, due to the planning designations

restricting development (see below). A redevelopment would be viable if

the scheme was mixed use.


3

A mixed use approach would not adversely affect the commercial financial

district since the presence of mixed use including residential in this location

would not restrict commercial development elsewhere.

There is an abundance of office schemes permitted elsewhere in the City of

London which total in excess of 20 million square feet as of February 2014,

which equates to approximately one fifth of the entire office stock in the

City. Thus the loss of office floorspace at 10 Lower Thames Street will not

harm the ability of the City to meet its current and future office

requirements.

2.4 As mentioned in the GM Real Estate letter, the potential for redevelopment of the site

in planning terms is restricted by its location on the riverside and moreover by the

heritage policy designations which apply. The potential to increase the height,

massing and scale of the building is limited by virtue of:

Monument views (to and from the site).

LVMF views, including views to St Paul’s and the River Prospect Views.

The proximity of the World Heritage Site.

The adjacent listed buildings of Billingsgate Market (Grade II) and Saint

Magnus the Martyr Church (Grade I), along with Adelaide House (Grade II)

and Custom House (Grade I).

The poor quality environment of Lower Thames Street which sterilises the

northern frontage and acts as a barrier/ boundary to the main City to the

north.

Opportunity to create a comprehensive mixed-use development

2.5 It is considered that there is a unique opportunity to redevelop 10 Lower Thames

Street, along with the adjoining 3 Lower Thames Street, in a co-ordinated approach to

provide a mixed use development which can contribute to the diversity of uses and

activity along the River Thames. Both buildings are currently of low architectural


4

quality and make no contribution to the townscape or animation of Lower Thames

Street or the River Thames frontage.

2.6 No. 10 Lower Thames Street is a blue framed and glass clad building constructed in

1985. Architecturally it is of no significance. Its ground floor is set back in part from

the pavement edge, but the mixture of steps, overhangs and solid panels presents a

blank and uninviting presence to the street. On the Thames River frontage, the

building presents a blank unanimated frontage.

2.7 No.10 Lower Thames Street has no architectural relationship with Grade II listed

Billingsgate Market to the east. The relationship between the two buildings is

awkward.

2.8 No. 3 Lower Thames Street is an office building which dates from the 1960s. It is a

horizontally banded concrete clad building of no architectural significance. It

currently dominates and is harmful to the setting of the Grade I listed Saint Magnus

the Martyr Church to the west which was designed by Sir Christopher Wren. It has a

poor relationship with the street, with no activity at ground floor to Lower Thames

Street or the River Thames.

2.9 PLP Architecture has been asked by Northern & Shell to undertake an initial

masterplan to consider how these two sites could be developed jointly, and explore in

more detail development options on 10 Lower Thames Street. The brief was to

assume that a mixed-use residential and commercial scheme would be delivered across

the sites. The initial masterplan for 10 and 3 Lower Thames Street is contained in

Appendix B. PLP has also undertaken more detailed studies of development options

for 10 Lower Thames Street and these are contained in Appendix C.

2.10 The work undertaken by PLP clearly illustrates that major public benefits can be

delivered through the redevelopment of these sites for a mixed use residential and

office development. It is considered that a comprehensive mixed use proposal would

deliver the following benefits:

Removal of buildings of low architectural quality and their replacement

with buildings which could positively enhance the townscape and river

views.


5

Introduction of ground floor uses which will animate Lower Thames Street

and the river frontage to enliven and diversify the area.

Improve public realm and open space both along the edges of the site and

between the buildings and along the river front.

Improve the setting of the Grade II Billingsgate Market and the Grade I

listed Saint Magnus the Martyr Church.

Provide high quality residential/office and commercial uses, which would

have no impact on existing business.

2.11 The opportunities and benefits presented by the masterplan and the long term viability

of developing Lower Thames Street mean that there are sound planning reasons why

the current policy approach requires re-consideration.

Soundness of Policy CS9

Under the previous draft of the Local Plan, the proposals outlined above to create a

mixed-use residential and commercial development would have been supported in

principle by Policy CS9. Our client is very disappointed that the City has determined

that changes to this policy are necessary. Northern & Shell object to the wording of

this policy, and consider it is not sound.

Justified

2.12 It is not considered that the change in wording to Policy CS9 is the most appropriate

strategy when considered against reasonable alternatives. Firstly, we are not clear as

to why Policy CS9 has been amended since its publication in January 2013. There is

no justification for the change in approach to the Thames Policy Area provided, and

no explanation as to why the City considers a change is necessary. The supply and

demand of office floorspace in the City does not support the need for an increased

protection of office floorspace in this area, particularly the protection of this type of

office floorspace which is of low quality.

2.13 We consider that even if a more restrictive office policy approach is considered

necessary for the Thames Policy Area, there are sound planning reasons why 10


6

Lower Thames Street, along with the adjacent site at 3 Lower Thames Street, should

be excluded from the office-led only policy approach. As indicated above, there is no

reasonable prospect of 10 Lower Thames Street being redeveloped for office

development over the life of the Local Plan - any such proposal is commercially not

viable.

2.14 Paragraph 19 of the NPPF makes it clear that “planning should operate to encourage

and not act as an impediment to sustainable growth”. Sustainable growth in this case

must take account of the prospects of sites being redeveloped over the life of the Local

Plan for higher quality office development. The evidence all points towards the fact

that this will not happen as it is not commercially viable. Therefore the Plan is

effectively condemning the site to remain as poor quality office accommodation

within poor quality buildings for the next 15 years. We do not consider that this meets

Paragraph 20 of the NPPF which states that “..local planning authorities should plan

proactively to meet the development needs of business and support an economy fit for

the 21st Century.”

2.15 The NPPF (paragraph 51) states that local planning authorities should normally

approve planning applications for changes to residential use and any associated

development from commercial buildings (including offices) where there is an

identified need for additional housing in that area, provided that there are not strong

economic reasons why such development would be inappropriate. We are not

convinced that there are strong economic reasons for the protection of all office

floorspace in the Thames Policy Area.

2.16 It is important to understand the character of this stretch of the River Thames between

London Bridge and the Tower of London. It is not an area which is dominated by

office uses, and indeed has a mixed use character which is typical of other parts of

River Thames frontage in Central London. This is evidenced by the recent residential

developments and permissions which have been granted by the City at Three Quays

and Sugar Quays respectively.

2.17 Sugar Quay is located to the east of 10 Lower Thames Street beyond the Grade I

Custom House and Grade II listed Billingsgate Market. It was granted planning

permission for 165 residential units in 2013. Beyond Sugar Quay is Three Quays


7

which is an existing residential building. To the west beyond the listed Saint Magnus

the Martyr Church, is located Adelaide House, a Grade II listed office building which

provides office accommodation.

2.18 The character of the stretch of the Thames east of London Bridge to the Tower of

London is of mixed use, with a townscape interspersed with listed buildings of Grade I

and Grade II. East of the site has already established a residential character which will

be enhanced by the development of Sugar Quay. The buildings at 10 and 3 Lower

Thames Street make no positive contribution to the townscape or diversity of the area,

and can be considered to be negative contributors.

2.19 In reaching the decision on Sugar Quay, the City of London noted in paragraph 38 of

its report to committee that the potential to deliver a large office development is

limited by height constraints resulting from its location adjacent to the River Thames,

the setting of listed buildings and the World Heritage Site. As indicated above, the

same constraints apply at 10 Lower Thames Street, as well as 3 Lower Thames Street.

Both sites are limited in terms of their potential increase in height due to the St Paul’s

protected viewing corridor and the protected views to the Monument. Both 10 and 3

Lower Thames Street lie adjacent to listed buildings. The ability therefore to deliver

large office development is the same as at Sugar Quay.

2.20 Allowing the two sites to be developed for a mixture of residential and commercial

use would in no way harm the primary business function of the City or threaten the

retention or creation of office floorspace within the remainder of the Thames Policy

Area. The primary business area of the City is north of Lower Thames Street, with the

road providing a physical and commercial point of differentiation in the demand for

office floorspace.

2.21 No.10 and No.3 Lower Thames Street are positioned between two listed buildings.

There are no prospects of the listed buildings being redeveloped for alternative uses in

the future, and therefore no prospect that the provision of residential on these two sites

could have the effect of spreading residential further east or west along the river.

There would no harm to the existing uses within the area, and in particular the existing

commercial uses to the east.


8

Effective

2.22 The strategy being put forward under Policy CS9 is not one which can be considered

to be effective. A blanket approach of protecting existing office floorspace is not

appropriate for the Thames Policy Area. The policy approach adopted in the Thames

Policy Area does not reflect the specific characterises of the area. A broad office

protection policy is being applied to an area which has unique uses, buildings and

characteristics.

2.23 Policy CS9 is not flexible to respond to any changes in housing which may come

forward over the life of the Plan. The Thames Policy Area is clearly an area which

could be suitable for residential and indeed was previously considered to be so by the

City of London. Adopting a policy which prevents the introduction of residential into

this area could be harmful to the City achieving the objectives of its Local Plan.

2.24 The policy approach being put forward under Policy CS9 is not deliverable. No. 10

Lower Thames Street is unlikely to be redeveloped for office schemes in the life of the

Local Plan. The Local Plan has failed to outline the timescales and mechanisms for

delivery of office development in the Thames Policy Area.

Proposed Modifications

2.25 In order to make the Plan sound, Northern & Shell request that the following changes

be made to Policy CS9:

“(iii) improving the vibrancy of the riverside by encouraging a mix of appropriate

commercial uses, including residential and promoting office-led commercial

development, between St Magnus the Martyr Church and Billingsgate Market,

particularly at Three Quay, the Millennium Bridge, and Blackfriars, whilst preserving

privacy, security and noise abatement amenity for residents, businesses and other

stakeholders;”


9

3.0 POLICY DM 1.1: PROTECTION OF OFFICE ACCOMMODATION

3.1 With reference to our comments set out under Policy CS9, we consider that Policy

DM 1.1 is not sound in its current form.

3.2 The policy approach adopted under DM 1.1 is a blanket approach to the protection of

offices in the City. Whilst it is recognised, and this is supported by policy in the

London Plan and by the Government’s exclusion of the City of London from the

permitted development rights from office to residential, that the protection of office

floorspace in the City is nationally and strategically important, the adoption of a

blanket approach is not sound. There are areas within the City, as we have indicated

in our representations under Policy CS9 on the Thames Policy Area, which have a

very different character to other parts of the City. To adopt a one size fits all approach

is not considered sufficiently flexible and could prevent redevelopment coming

forward which is sustainable and beneficial.

3.3 The criteria set out under Policy DM 1.1 is onerous. The draft SPD has clarified what

‘suitable for long-term viable office use’ means which is a period of 10 years or more,

with robust evidence required to be submitted to demonstrate the case. The adoption

of such a policy across the whole of the City is likely to lead to very few proposals

coming forward for changes of use from offices to residential. We would therefore

question the City’s assumption that the historic trend for residential windfall sites will

continue over the Plan period. We consider there is the potential for Policy DM 1.1 to

harm the delivery of housing in the City.

Proposed Modifications

3.4 We consider the Policy DM 1.1 should be amended to so that it is consistent with

Policy CS21 of the Local Plan on identified residential areas and to reflect our

representations to Policy CS9 which identifies the potential for residential between St

Magnus the Martyr Church and Billingsgate Market. We would request that Policy

DM 1.1 be amended as follows:

“With the exception of the identified residential areas under Policy CS21 or

within the residential location identified under Policy CS9 within the Thames

Policy Area, Tto refuse the loss of existing (B1) office accommodation to other uses


10

where the building or its site is considered to be suitable for long-term viable office

use and there are strong economic reasons why the loss would be inappropriate.

Losses would be inappropriate for any of the following reasons:

• prejudicing the primary business function of the City;

• jeopardising the future assembly and delivery of large office development sites;

• removing existing stock for which there is demand in the office market or long term

viable need;

• introducing uses that adversely affect the existing beneficial mix of commercial

uses.”


11

APPENDIX A (separately attached)


12

APPENDIX B (separately attached)


13

APPENDIX C (separately attached)

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