ADDRESS: Railway Bridge

Upper Marsh

London

Application Number: 19/00071/FUL Case Officer: Emily Leighton

Ward: Bishops Date Received: 10.01.2019

Proposal: Refurbishment and change of use of 9 arches at Upper Marsh and Westminster Bridge

Road to provide 3,542sqm of office space (Use Class B1) arranged over ground and new

mezzanine floor level; installation of glazed facade to the arches; public realm and landscaping

improvements; ancillary waste storage and cycle parking facilities; and other associated works.

Applicant:

Urbanest UK Lambeth North Limited

Partnership

Agent:

Henry Farrar

Gerald Eve

72 Welbeck Street

London

W1G 0AY

RECOMMENDATION

1. Resolve to grant planning permission subject to the conditions as set out in the report and

subject to the completion of an agreement under Section 106 of the Town and Country

Planning Act 1990 to secure the planning obligations listed in this report.

2. Agree to delegate authority to the Director of Planning, Transport and Sustainability to:

a. Finalise the recommended conditions as set out in this report; and

b. Negotiate, agree and finalise the planning obligations as set out in this report pursuant

to Section 106 of the Town and Country Planning Act.

3. In the event that the committee resolves to refuse planning permission and there is a

subsequent appeal, delegated authority is given to the Director of Planning, Transport and

Sustainability having regard to the proposed planning obligations set out in the report,

addendums and/or PAC minutes, to negotiate and complete a document containing

obligations pursuant to Section 106 of the Town and Country Planning Act 1990 (as

amended) in order to meet the requirement of the Planning Inspector.

4. In the event that the Section 106 Agreement is not completed within six months of

committee, delegated authority is given to the Director of Planning, Transport and

Sustainability to refuse planning permission for failure to enter into a section 106 agreement

for the mitigating contributions identified in this report, addendums and/or the PAC minutes.

SITE DESIGNATIONS

Relevant site designations:

Flood Risk Area Flood Zone 3

Archaeological Priority Area North Lambeth Archaeological Priority Area

Local View NNE from Norwood Park to the City, and from

Battersea Park to The Gherkin and Canary Wharf

Other Central Activities Zone (CAZ)

Waterloo Opportunity Area

Thames Policy Area

Area of Open Space Deficiency

Tunnel Safeguarding Lines

Adjacent Site Designations:

Conservation Areas South Bank Conservation Area

Lower Marsh Conservation Area

Albert Embankment Conservation Area

LAND USE DETAILS

Site area (ha): 4257.07sqm (0.4257Ha)

NON-RESIDENTIAL DETAILS

Use Class Use Description Floorspace (m2)

(Gross Internal Area)

Existing Sui

Generis/Ancillary

D1

Railway arches

Disabled car parking,

cycle parking and refuse

storage for Urbanest

2,180sqm

Proposed B1(a) Office space 3,699sqm (including the

mezzanine)

PARKING DETAILS

Car Parking Spaces

(General)

Car Parking Spaces

(Disabled)

% of

EVCP

Bike Spaces Motor-

cycle

Spaces

Commercial Commercial

Existing 0 0

(3 existing disabled spaces

associated with Urbanest)

0 0

(250 associated

with Urbanest)

0

Proposed 0 2 0 58 long-stay

10 short-stay

(648 associated

with Urbanest)

0

LEGAL SERVICES CLEARANCE

AUDIT TRAIL

Consultation

Name/Position Lambeth

department

Date Sent Date

Received

Report

Cleared

Comments in

para:

Susan Boucher

Lawyer

Legal Services 05.06.2020 05.06.2020 09/06/2020 Throughout

EXECUTIVE SUMMARY

The application site comprises 9 railway arches beneath Waterloo Station located adjacent to the Urbanest

site, a mixed use development serving student accommodation, a college and business uses. Access to the

application site is from both Westminster Bridge Road and Upper Marsh.

The application proposes the change of use of the 9 arches from Sui Generis use (vacant arches) and

associated with D1 Use of Urbanest for the cycle parking (two arches closest to Westminster Bridge Road),

disabled car parking and waste/refuse storage to create 3,699sqm (GIA) of B1 floor space. The proposal

would present an opportunity for the redevelopment of under-utilised arches into a productive, employment-

generating office use consistent with development plan policies, which support such uses located within the

Central Activities Zone (CAZ), the London Plan Waterloo Opportunity Area and the Southbank and Waterloo

Neighbourhood area.

The application proposes that the B1 floorspace would be leased to Sustainable Workspaces (an affordable

workspace operator) at a significant reduction to market rent levels. The application further proposes that

should the preferred lessee not take up the B1 space, a planning obligation would be entered into to secure

affordable workspace in line with emerging policy ED2 of the Draft Revised Lambeth Local Plan (2018).

The design of the proposal includes a new glazed curtain wall façade on the western elevation of the arches

which would read as a cohesive design and would respect the railway arches. It would also animate an

inactive edge and increase passive surveillance. The proposed development allows an opportunity to open

up a service road that was secured under an earlier Section 106 agreement completed in respect of the

adjacent Urbanest development. The earlier agreement identifies the service road as being for private

vehicular access. It is currently gated at either end. The proposal is for the gates to be removed in their

entirety should development on the Royal Street site come forward in the future and develop the lowline (the

area of land that runs adjacent to the railway viaduct) to Archbishops Park, with the gates opened between

7am and 10pm from the implementation of the first phase of any of the Royal Street planning permissions. In

the event that the Royal Street site does not come forward for development, a ‘backstop’ date has been

agreed to open the service road in mid-2023.The opening of the gates would allow permeability to the arches

and the low-line and achieves greater pedestrian access within this part of the Borough. It is proposed to

impose a ‘Grampian’ condition that would prevent the development being able to be occupied until a

satisfactory planning obligation is entered into in relation to the operation of and future arrangements for the

gates, and the facilitating of pedestrian use of the service road.

Officers have given due consideration to any potential amenity impacts that may arise from the change of

use of the arches, in particular to the adjacent use of Urbanest serving student accommodation. Subject to

conditions, the proposed development would not result in any unacceptable amenity impacts, namely noise

and disturbance.

The Council’s transport officer has confirmed that the proposal would not result in any unacceptable

transport impacts and advised that the cycle parking, disabled bay parking and servicing proposed for the

office use and adjacent Urbanest site is acceptable. A non-material amendment has been granted

(application reference: 20/00906/NMC) in respect of the existing planning permission for the adjacent

Urbanest development in respect of reconfigured cycle parking, disabled parking and refuse storage for the

existing development. The resulting amendments would enable the proposed development to be

accommodated without adversely affecting cycle parking, disabled parking and refuse storage for the

adjacent Urbanest development. The proposal would be car free, to be secured by a planning obligation.

Benefits would arise from the proposal in terms of employment and skills contributions which would allow for

the further training of local residents and an Employment and Skills Plan relating to the end-use occupation

of the building, which includes advertising any job vacancies with Lambeth Council. This is proposed to be

secured by way of planning obligation.

In relation to planning obligations other than that proposed in relation to the opening up of the service road, it

is proposed that planning permission be granted subject to completion of a S106 agreement. Although the

applicant itself has only a leasehold interest in the application site land, the applicant has indicated that

agreement in principle of other relevant parties to the completion of a S106 agreement, including Network

Rail, Secretary of State for Transport and Guys’ and St. Thomas’ Charitable Foundation.

The development would be acceptable, subject to conditions in terms of environmental matters such as

sustainability, flood risk, air quality and land decontamination.

Officers consider that the development would comply with the development plan for the Borough and there

are no material considerations of sufficient weight that would dictate that the application should otherwise be

refused. Officers are therefore recommending approval of the scheme, subject to conditions and planning

obligations in accordance with the presumption in favour of sustainable development conferred upon local

planning authorities by the National Planning Policy Framework (NPPF).

OFFICER REPORT

Reason for referral to PAC: The application is reported to the Planning Applications Committee in

accordance with (1)(ii) of the Committee’s terms of reference as it relates to a major application for

the change of use of floor space exceeding 1,000sqm.

1 THE APPLICATION SITE

1.1 The application site comprises nine railway arches located between Westminster Bridge Road and

Upper Marsh with an adjoining ‘service road’. The arches are currently used for cycle parking,

disabled car parking, and refuse and recycling storage for the adjacent Urbanest development or are

otherwise empty.

1.2 The site does not contain any listed buildings nor is it adjacent to any listed buildings.

1.3 The proposal is for the change of use to Class B1 office use and refurbishment of nine arches east of

the existing adjacent ‘Urbanest’ development on Westminster Bridge Road. The site is identified within

the Lambeth Local Plan (2015) as being located within the Waterloo Railway Character Area.

2 THE SURROUNDING AREA

2.1 The surrounding area has a mixture of uses. The application site is directly adjacent to the existing

development that provides a mix of student housing accommodation, a college and business uses

(known as ‘Urbanest’) approved in 2013 under application reference 12/04421/FUL. Other uses

surrounding the site are offices, hotel and residential uses.

2.2 The site has excellent access to public transport with a public transport accessibility rating (PTAL) of

6(b) because of its access to Waterloo railway station, the London Underground and numerous bus

routes. The application site is situated approximately 200m from Waterloo Station.

2.3 The application site is located outside of the South Bank Conservation Area (CA38) which lies to the

north of the site. The Lower Marsh Conservation Area (CA40) is also located nearby to the east of

the arches/railway line and Albert Embankment Conservation Area (CA57) is located west of the site,

beyond Urbanest and Becket House. There are no listed buildings/structures or locally listed

buildings that would be affected by the proposal.

3 SITE PHOTOGRAPHS

Figure 1: Looking from Upper Marsh towards the vacant arches.

Figure 2: Looking at toward the application site and the amenity space of Urbanest.

Figure 3: Internal view of the arches looking towards the southern end of the site.

Figure 4: View of southern gate adjacent Upper Marsh entranceway.

Figure 5: Underside of (former) Eurostar platform canopy and supporting structure.

Figure 6: View of northern gates adjacent Westminster Bridge Road.

Figure 7: View toward the arches from Upper Marsh with the Urbanest amenity space to the left and

the arches to the right.

4 PROPOSAL

4.1 The application proposes the refurbishment and change of use of 9 arches at Upper Marsh and

Westminster Bridge Road from cycle parking, disabled parking and waste/refuse storage associated

with Urbanest to provide 3,699sqm of office space (Use Class B1(a)) arranged over ground and a

new mezzanine floor level; installation of glazed facade to the arches; public realm and landscaping

improvements; ancillary waste storage and cycle parking facilities; and other associated works.

4.2 The proposal would result in 7 of the 9 arches being developed for the B1 office use. The remaining

2 arches closest to Westminster Bridge Road would serve as the cycle parking for the Urbanest

scheme.

4.3 The office space would be set out over the ground floor and a mezzanine floor area with a Gross

Internal Area (GIA) of 3,699sqm of B1 office space. The Net Internal Area (NIA) of the ground floor is

1,248sqm and the mezzanine floor is 1,587sqm totalling 2,358sqm.

Figure 8: Proposed ground floor layout of the arches.

Figure 9: Proposed mezzanine floor of arches.

4.4 The majority of the façade will be glazed with large format glazed curtain walling with a dark

grey/black aluminium cover caps externally and glu-lam (glue laminated) transoms and mullions

internally. These are matched with dark grey/black louvres used on the high level vents and also as

cladding over back of house areas such as cycle storage and loading bays.

4.5 The Section 106 agreement associated with the adjacent Urbanest development permitted in 2013

under application ref: 12/04421/FUL contained an obligation relating to a strip of land described in

the agreement as the ‘Safeguarded Land’. The ‘Safeguarded Land’ is the service road that runs

along the front of the arches between Upper Marsh and Westminster Bridge Road (see Figure 10).

The existing obligation requires the maintenance and repair of the Safeguarded Land as private

vehicular access to the Urbanest development. The agreement contemplated that the Safeguarded

Land might be reconfigured at a future date, including in the event of increased pedestrian use of

that land. Currently gates are situated at either end of the service road. It is proposed that the service

road is to be opened and the gates removed in line with the following triggers:

Planning permission granted for the Royal Street site In the event that a planning application for the Royal Street site (Strategic Site 1) is approved by no later than 1 January 2023, the service road gates must be opened between the hours of 7am-10pm daily on implementation of the first phase of any of planning permission for Strategic Site 1 and in any event by no later than 1 July 2023. The gates are then to be removed in their entirety when the Royal Street ‘low line’ is implemented (opening up pedestrian access adjacent the railway viaduct) and in any event by no later than 1 January 2024. Backstop In the event that a planning application for the Royal Street site (Strategic Site 1) is not approved by 1 January 2023 the following fall-back is proposed: the service road gates would be retained with no opening hours until 1 July 2023, from which date the gates would need to be open between the hours of 7am to 10pm daily. The gates would then need to be removed in their entirety by 1 January 2024.

4.6 It is noted that there may be a period during which the B1 floorspace is occupied by a tenant but the

service road would remain closed. The applicant’s reasoning for this delay is due to concerns about

opening the service road too early, which may affect Urbanest and their tenants’ current and further

operational requirements, particularly in the event that the Royal Street site (Strategic Site 1) did not

come forward and the service road was opened ‘in isolation’. The concerns relate principally to the

following matters:

Urbanest’s obligations to its tenants (Build Studios and DLD College), whose premises are situated directly adjacent to the service road, and ensuring they can continue to occupy their premises securely and without detrimental impact to their operations.

Impacts on vehicle servicing of Urbanest’s existing building, in light of increased pedestrian flows along the service road;

Security implications for the existing College (and its external areas) at ground floor level, and the necessary enhancements to the building and systems necessary to address this;

Monitoring and maintenance of the pedestrian road on a day-to-day basis and how this will be managed;

How and whether improvements to pedestrian crossings, surfacing, kerbsides etc. in the adjoining roads would be delivered to cope with increased pedestrian flow.

While these concerns are capable of being addressed and mitigated, it is important that there is sufficient time to do so and for Urbanest to undertake necessary discussions and arrangements with their tenants, investors (and other stakeholders), such that the service road opens in an organised and coordinated way. It is therefore proposed that there is a period after occupation of the arches being established, to review and consider the operational management, servicing, and access of the offices and how this will relate to the service road once opened. As noted above, this will also allow for further discussion and arrangements to be made with Urbanest’s tenants and other local stakeholders, to ensure there is awareness and consensus on the approach to the service road opening. Accordingly, Urbanest have accepted a backstop date of 1 July 2023 for the opening of the service road.

4.7 The Royal Street site is identified in the Lambeth Local Plan as Site 1 under Policy S2 of the

Lambeth Local Plan (see Figure 12). The Royal Street site is owned by the Trustees of the Guy’s and St Thomas’ Charity and other related charities and provides the opportunity to be developed as an expansion for St Thomas’ hospital to provide clinical and ancillary hospital uses. It would be necessary to secure the proposed arrangement in relation to the gates, and pedestrian use of the

service road, by way of a replacement planning obligation. The area of the Safeguarded Land is included within the ‘red line’ for the current proposal (see Figure 11). However, because the relevant obligation relates to the adjacent Urbanest development, consideration would need to be given to any impact on that development of any changes to that obligation. Accordingly, it is recommended to impose a ‘Grampian condition’ (condition 3) preventing occupation of the scheme currently under consideration until the existing Safeguarded Land obligation can be suitably amended. This would be most likely to be done through a freestanding application to vary the relevant obligation. The amended obligation in relation to the Safeguarded Land would be able to be ‘mirrored’ in the S106 agreement attaching to the proposed development if this is considered necessary.

Figure 10: ‘Safeguarded Land’ outlined in Blue as defined in the Section 106 agreement for

12/04421/FUL and shown on Plan 5.

Figure 11: The figure shows how the current application site ‘overlaps’ the application site for

12/04421/FUL. The ‘red line’ boundary for 12/04421/FUL is shown in green, with the red line being

the ‘red line boundary’ for the current application. The yellow area shown is the ‘safeguarded land’

referred to in Schedule 6 of the S106 agreement for 12/04421/FUL. This is located within the area of

‘overlap’ of the application site boundaries for the extant permission 12/04421/FUL and the current

permission.

Figure 12: Location of Royal Street (Strategic Site 1) in relation to the application site (pink dot).

4.8 It should be noted as regards the remaining planning obligations proposed in this report in

connection with the application site itself, the applicant has a leasehold interest in the land. The

applicant submitted an amended Certificate B form on 19.03.2020 advising that the

owner/agricultural tenants of the application site ‘red line’ are:

Secretary of State for Transport;

Guys’ and St Thomas Charity;

Network Rail Infrastructure.

4.9 Cycle parking and refuse storage is proposed at ground floor level with access from the arch closest

to Upper Marsh. The applicant is proposing to retain the existing fire escape staircase to Waterloo

Station within the arch located closest to Upper Marsh. A ‘no build’ area is proposed to the front of

the emergency stairs and access to the cycle and refuse store is gated either side of the staircase.

Figure 13: Proposed front elevation of the arches.

Figure 14: Proposed CGI of the front elevation of the arches.

4.10 The applicant is proposing 58 cycle parking spaces and 10 short-stay spaces for visitors. Changing

rooms and showers are provided at ground floor level.

4.11 A non-material amendment application (application reference: 20/00906/NMC) was submitted to the

Council on 06.03.2020 to reconfigure the cycle parking, waste and refuse storage and disabled car

parking associated with Urbanest. The applicant is proposing to move and reconfigure these facilities

as they are currently located within arch 1 and 2, the area proposed for B1 office space under the

current application. The NMC application was permitted on 03.04.2020.

5 Amendment(s)

5.1 Amended floor plans were submitted on 04.03.2020 which showed the updated provision of cycle

parking for the existing Urbanest scheme within Arch 1 and 2 (adjacent Westminster Bridge Road).

5.2 To accommodate the cycle parking within Arch 1 and 2, the applicant has revised the B1 floor space

of the scheme. The overall B1 floor space (GIA) is 3,699sqm as advertised. The NIA of B1 floor

space has decreased from 2,475sqm to 2,358sqm.

5.3 The applicant originally proposed to subdivide the external amenity space associated with Urbanest.

The applicant has amended the plans to remove this from the scheme.

6 RELEVANT PLANNING HISTORY

6.1 18/01680/PREAPP - Change of use of the railway arches to Class B1 office use. Advice given

27.06.2018.

6.2 18/04762/PREAPP - Refurbishment of railway under archers for Class B1 use. Advice given

14.01.2019.

Urbanest Applications – 203 York Road

6.3 12/04421/FUL - Demolition of York House and the Florence Nightingale Public House and the

redevelopment of the site comprising the erection of a 19 storey building (plus basement) to

accommodate student accommodation and ancillary facilities (Use Class Sui Generis; 35,926 sqm

GEA; 1,093 bed spaces), a college (Use Class D1; 6,340 sqm GEA) and affordable workspace (Use

Class B1; 382 sqm GEA) and associated servicing arrangements, landscaping, new public realm

and public realm improvements.

The development is EIA Development for the purposes of the Town and Country Planning

(Environmental Impact Assessment) Regulations 2011. The application is accompanied by an

Environmental Statement). The application was permitted 29.01.2013.

6.4 14/06123/DET - Approval of details pursuant to condition 32 (Cycle parking) of planning permission

ref: 12/04421/FUL (Demolition of York House and the Florence Nightingale Public House and the

redevelopment of the site comprising the erection of a 19 storey building (plus basement) to

accommodate student accommodation and ancillary facilities (Use Class Sui Generis; 35,926 sqm

GEA; 1,093 bed spaces), a college (Use Class D1; 6,340 sqm GEA) and affordable workspace (Use

Class B1; 382 sqm GEA) and associated servicing arrangements, landscaping, new public realm

and public realm improvements) granted on 06/03/2013. Application permitted 18.03.2015.

6.5 15/05919/DET - Approval of details, pursuant to condition 32 (cycle parking) of planning permission

12/04421/FUL (Demolition of York House and the Florence Nightingale Public House and the

redevelopment of the site comprising the erection of a 19 storey building (plus basement) to

accommodate student accommodation and ancillary facilities (Use Class Sui Generis; 35,926 sqm

GEA; 1,093 bed spaces), a college (Use Class D1; 6,340 sqm GEA) and affordable workspace (Use

Class B1; 382 sqm GEA) and associated servicing arrangements, landscaping, new public realm

and public realm improvements). Granted on 06.03.2013. Application permitted 24.11.2015.

Under this discharge of condition application, a lesser number of cycle parking spaces were

approved within the Urbanest amenity space area for a temporary period to allow for Network Rail to

utilise 4 arches whilst undertaking construction works.

6.6 15/05972/NMC - Application for a Non-Material Amendment following a grant of planning permission

Non-material amendment 12/04421/FUL (Demolition of York House and the Florence Nightingale

Public House and the redevelopment of the site comprising the erection of a 19 storey building (plus

basement) to accommodate student accommodation and ancillary facilities (Use Class Sui Generis;

35,926 sqm GEA; 1,093 bed spaces), a college (Use Class D1; 6,340 sqm GEA) and affordable

workspace (Use Class B1; 382 sqm GEA) and associated servicing arrangements, landscaping, new

public realm and public realm improvements.) Granted on 06.03.2013. Application permitted

16.11.2015.

Under this application, the plans were varied in order to show the temporary location of the cycle

parking approved under the application 15/05919/DET.

6.7 16/00063/DET - Partial approval of details pursuant to condition 32 (cycle parking) of planning

permission 12/04421/FUL (Demolition of York House and the Florence Nightingale Public House and

the redevelopment of the site comprising the erection of a 19 storey building (plus basement) to

accommodate student accommodation and ancillary facilities (Use Class Sui Generis; 35,926 sqm

GEA; 1,093 bed spaces), a college (Use Class D1; 6,340 sqm GEA) and affordable workspace (Use

Class B1; 382 sqm GEA) and associated servicing arrangements, landscaping, new public realm

and public realm improvements) granted on 06.03.2013. Application permitted 05.02.2016.

Under this application, the applicant discharged their obligation to provide cycle hire docking stations

and an associated pay station.

6.8 19/04233/VOC - Variation of condition 32 (Cycle Parking) and 37 (Waste Management Strategy) of

planning permission 12/04421/FUL (Demolition of York House and the Florence Nightingale Public

House and the redevelopment of the site comprising the erection of a 19 storey building (plus

basement) to accommodate student accommodation and ancillary facilities (Use Class Sui Generis;

35,926 sqm GEA; 1,093 bed spaces), a college (Use Class D1; 6,340 sqm GEA) and affordable

workspace (Use Class B1; 382 sqm GEA) and associated servicing arrangements, landscaping, new

public realm and public realm improvements) granted on 06.03.2013.

(Re-consultation due to corrected description)

Variation sought:

Amend wording of Condition 32 to 'Cycle Parking must be provided and maintained in accordance

with the details shown on plans 18107_(00)_P099 18107_(00)_P100 and 18107_(00)_P01. The

cycle parking shall thereafter be retained solely for its designated use unless otherwise approved

with the local planning authority'.

Amend wording of Condition 37 to: 'The management and storage of waste shall be carried out in

accordance with the [Waste Management Statement] (November 2019). The facilities shall be

operated in accordance with the plan and retained for the duration of the permitted use, unless

otherwise agreed with the Local Planning Authority'.

Insert new condition as proposed: '3no. disabled car parking spaces for the student accommodation

must be provided in accordance with details shown in the Disabled Parking Statement (November

2019) and thereafter retained for the duration of the permitted use, unless otherwise agreed with the

Local Planning Authority'.

This application was withdrawn on 28.02.2020 on the advice of Officers as the proposed changes

were not considered material. The applicant submitted an NMC application addressing the changes

to the cycle parking, disabled car parking and the refuse and recycling storage serving the Urbanest

development on 05.03.2020. Officers have provided the applicant with informal pre-application

advice noting that the proposed changes would constitute a non-material change to the parent

permission. However at the time of writing this report a formal decision has not be issued and will be

reported to Members by way of an addendum.

6.9 20/00906/NMC – Application for a non-material amendment following a grant of planning permission

ref : 12/04421/FUL (Demolition of York House and the Florence Nightingale Public House and the

redevelopment of the site comprising the erection of a 19 storey building (plus basement) to

accommodate student accommodation and ancillary facilities (Use Class Sui Generis; 35,926 sqm

GEA; 1,093 bed spaces), a college (Use Class D1; 6,340 sqm GEA) and affordable workspace (Use

Class B1; 382 sqm GEA) and associated servicing arrangements, landscaping, new public realm

and public realm improvements) granted 06.03.2013

Amendment sought to wording of conditions 32 and 37 to reflect reconfiguration of cycle parking

provision, and waste management/storage for the building, as a consequence of the proposed

change of use of adjacent Railway Arches to provide new office floorspace. Proposed additional

condition to reflect disabled parking re-provision. Application permitted 03.04.2020.

7 CONSULTATIONS

7.1 Statutory External Consultees

Environment Agency – Received 18.02.2019. Advised that there is no objection to the proposal

subject to conditions on contamination measures, piling methods and sustainable drainage systems.

The EA have advised that the submitted Flood Risk Assessment (FRA) provides an accurate

assessment of the tidal and fluvial flood risks associated with the proposed development. (refer to

conditions 25-29).

TFL Road Network Development – Received 13.02.2019. No objection to the proposal subject to

conditions ensuring the proposal being car-free, compliance with the London Plan cycle parking

standards, Delivery and Servicing Plan and Construction and Logistics Plan. (refer to conditions 5-8).

Veolia Waste Lambeth – Received 12.02.2019. No objection to proposal – noted that Veolia had

met with the applicants during pre-application meetings to discuss the submitted Operational Waste

Management Strategy. (refer to condition 8).

Design Out Crime Officer – Received 28.01.2019. No objection subject to conditions: pre-

commencement condition to incorporate security measures and pre-occupation condition to ensure a

secured by design inspection is undertaken. (refer to conditions 30 & 31).

Bioregional – Received 05.02.2019. No objection to proposal subject to conditions on connecting to

a decentralized network, BREEAM design stage and post construction certificates, design stage and

as-built calculations and a cash in lieu contribution to offset the remaining carbon contributions.

Following the initial comments, the applicant provided further information on 19.03.2019 which

addressed Bioregionals’ concerns on connecting to decentralised systems, BREEAM ratings and

carbon offsetting contribution. Bioregional advised on 22.03.2019 that conditions requiring the

scheme to connect to a decentralized network would not be required and that a ‘Very Good’ rating of

60% would be acceptable. (refer to conditions 19-22).

EHST Land Contamination – Received 17.02.2019. No objection to the proposal subject to

conditions on contamination, a delivery and servicing plan, and post-installation noise conditions.

(refer to conditions 6, 23 and 24)

Thames Water – Received 28.01.2019. No objection to the proposal, however note that the

development is close to water main pipes. Informatives are suggested.

Network Rail – no comments received at the time of writing this report. Any comments will be

reported by way of an addendum.

Historic England (archaeology) - no comments received at the time of writing this report. Any

comments will be reported by way of an addendum.

7.2 Internal Consultees

LBL Noise Pollution – Received 13.02.2019. No objection to the proposal.

Flooding – SUDS – Received 12.02.2019. No objection with the proposal due as the applicants are

proposing to utilise an existing Sustainable Drainage System which has been designed to accept

flows from this development.

Conservation & Urban Design – Received 06.02.2019. Note that whilst supportive of the scheme

which would animate an inactive edge and increase passive surveillance, there are concerns with

the proposed curtain wall of the proposal and with the retention of the gates which fail to allow

permeability and connectivity of the site. (refer to conditions 11-17).

Planning Policy – Received 07.02.2019. No objection to the introduction of office space in the

arches. Officers advise that flexible/affordable workspace should be provided with the scheme.

Transport Lambeth – Received 29.01.2019. No objection to the proposal subject to conditions

securing details of refuse/recycling, design/layout of cycle parking, Method of Construction

Statement, Service and Delivery Plan and Travel Plan. Car free development and financial

contributions for disabled car parking is also requested to be secured through a Section 106

agreement. (refer to conditions 5-10).

Sustainability Team On Air Quality – Received 08.02.2019. The site is classed as being at

Medium Risk. No objection to the proposal subject to conditions on NRMM and including more

details in the Construction Management Plan. (refer to conditions 4 & 6).

Employment And Skills – Received 18.02.2019. Advised that the proposal would trigger the

requirements to provide a financial contribution for local employment and training which would be

secured through a Section 106 agreement.

Regeneration Team Bishop Ward – Received 04.03.2019. No objection to the proposal. The

proposal would reactivate an area with potential for linkages to strategic sites. The service road

alongside the arches should be for pedestrian and cyclists only. The service road alongside the arches

should be opened and if required, a condition for the opening hours of any gates could be added to

the decision notice with a requirement in any S106 agreement for full opening should any strategic

sites come forward in the future. Officer comment: The proposed ‘Grampian’ condition requires a

planning obligation to be entered into providing for the removal of the gates if and when the Royal

Street Site is developed, and securing daily opening times of the gates, as well as securing the service

road as a pedestrian road adjacent railway lines, thereby increasing the permeability of the proposed

arch redevelopment as per Policies PN1 and ED5 of the Lambeth Local Plan. The opening up of this

road would accord with the current requirements of Policy ED5(d) which requires applications affecting

railway arches to improve the immediate environment around the arches, including the public realm.

This is to include accessibility, safety, servicing and lighting appropriate to the location.

7.3 Other Consultees

WeAreWaterloo – Received 18.02.2019. No objection to the proposal. Supportive of the creation of

additional office space within the Waterloo BID area as this meets the objectives of supporting the

growth of a mixed economy. The following requests and suggestions were outlined in the comments:

Request that there is a provision for affordable workspace – the applicant could consult with

WeAreWaterloo and the Council to determine whether a part of the office development may

be able to be offered at below market rates for start-up companies;

Request that the noise from the proposal would not impact on Build Studios which is located

within the lower levels of the Urbanest – hours of operation should be conditioned;

Request that the developer funds reasonable costs for installing artwork on the hoardings to

be erected whilst construction is undertaken. This request is common and has been

undertaken on applications along Lower Marsh – helps to brighten the area and provides an

opportunity to showcase local independent artists;

Support increased public access to linear car free pathways alongside elevated railway

infrastructure. Note that the Design and Access Statement submitted with the proposal does

not suggest that this element will be opened up and requested that the developer look into

this issue;

Suggest that the treatment of the Westminster Bridge Road (WBR) elevation is looked at –

note that there is limited opportunities to create entrances on this elevation however WBR is

a key access point for tenants, most of all those who would use ‘EXIT 1’ of Waterloo Station.

WeAreWaterloo would be happy to work with the developer to improve the streetscape on

this elevation;

Furthermore, the air quality in the WBR underpass is some of the worst in the capital - the

WSP Air Quality Assessment fails to note the data collected as part of the Love Lambeth Air

project facilitated by WeAreWaterloo in 2016/17. With plant from the development expelling

exhaust air into the underpass, no assessment is made of how this will affect air quality in

that space;

Section 2.3. of the draft Construction Management Plan does not include Build Studios as

one of the sensitive tenants which Urbanest is consulting with over operations requirements.

Given that the facility offers 24 hour access to tenants, we would advise immediate

consultation is entered into with the management of Build Studios. WeAreWaterloo as a

tenant of this space would be glad to facilitate this. Furthermore the construction

management plan mentions that deliveries will be made alternately between Upper Marsh

and Westminster Bridge Road. As a red route featuring a segregated cycle lane, there is no

potential to make any deliveries by vehicle from the Westminster Bridge Road entrance.

The Construction Coordination Group is not a stakeholder consultation mechanism - most of

the stakeholders concerned with the development (Becket House, Build Studios, Canterbury

and Stangate House etc) have no involvement with this group and it will be contingent on the

developer to ensure those adjacent to the site are kept fully informed, with a site manager

available by phone at all times of operation.

The Construction Management Plan does not enter into sufficient detail regarding rodent

controls. The railway viaducts contain a significant population of rodents which are likely to

be displaced as a result of the construction works, as was noted during the Wessex Capacity

works to Waterloo Station in 2017. Given the proximity of a food market at Lower Marsh, it is

contingent on the developer to ensure that every effort is being made to manage this issue,

including but not limited to the funding of rodent control measures for those neighbours

experiencing an increase during the construction.

WeAreWaterloo and Build Studios would hope that the developers could broker a meeting

with the new tenants as soon as possible to develop partnerships aimed at strengthening the

network of co-working spaces in the area. Reciprocal arrangements on meeting rooms,

social value programmes and events would be beneficial to both operators, and as future

levy payers the BID will help the operator develop local supply chain arrangements to serve

the local economy.

Officer Response: The majority of the comments raised by WeAreWaterloo are matters that require

the parties to undertake their own discussions and cannot be conditioned under this application. A

condition has been added to the proposed decision notice to secure a hoarding strategy with public

art (refer condition 5).

LCR (London and Continental Railways) – received 31.03.2020. LCR have advised that they have

a leasehold interest at the former Waterloo International Terminal and landlord of the Leake Street

Arches.

LCR is supportive of the scheme as proposed. It will be a further step to securing comprehensive

regeneration in the wider Waterloo area.

For the reasons set out above, LCR’s main comment on the scheme would be that the proposal to

retain the existing gates at both ends of the public realm in front of the Urbanest development would

cause an interruption to the pedestrian realm in this area, going against the aspiration of the 2014

Masterplan and LB Lambeth proposals to implement the Spine Route.

We understand from Urbanest however that the gates would only be closed at night and that, once

the Guy’s and St. Thomas’ Charity Royal Street development is completed, the gates would be

removed/left open.

To that end we would request that London Borough of Lambeth utilises its vires as the local planning

authority to ensure that this is the case by securing this through Planning Condition. Subject to

London Borough of Lambeth securing the removal of the gates once the Royal Street development is

brought online, LCR has no objection to this scheme.

Officer Response: The treatment of the Safeguarded Land is dealt with through the proposed

‘Grampian’ condition as explained in section 4.5 of this report.

7.4 Adjoining owners/occupiers

7.4.1 Three site notices were displayed from 01.02.2019 and the application was advertised in the local

paper on 01.02.2019. The formal consultation period ended on 22.02.2019.

7.4.2 The applicant advised on 11.03.2020 that Certificate B had been served incorrectly, that is, not all

those parties with an interest in the land in the application site had been correctly notified about the

application. The applicant provided an updated Certificate B. Site notices were posted on 01.04.2020

and a press notice was published on 27.03.2020. The expiry date of this round of consultation ended

on 22.04.2020.

7.4.3 At the time of writing this report, no objections to the proposal have been received. Should objections

be made prior to the Committee date, these will be reported in the form of an addendum.

7.4.4 A comment in support of the application was received from Alpha Plus Group Ltd who run the

college use within the adjacent Urbanest Building as follows:

These proposals will transform prime opportunity space into regenerating life style working spaces

adding buzz to the area. Also as a result of this other excellent hard and soft landscaping designs

can be brought forward that will further enhance the immediate environment for all (incl our students)

and additionally safeguarding and security measures that are much needed will be sensitively and

attractively completed.

8 POLICIES

8.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning decisions to be

made in accordance with the development plan unless material considerations indicate otherwise.

The development plan in Lambeth is the London Plan (2016, consolidated with alterations since

2011), the Lambeth Local Plan (September 2015) and the South Bank and Waterloo neighbourhood

development plan (‘the SoWNDP’) (October 2019).

8.2 In December 2019 the London Plan (Intend to Publish version) was published by the Mayor of London.

This followed the Examination in Public on the Draft London Plan (published in December 2017), which

was held between January and May 2019. On 21 October 2019 the Panel of Inspectors appointed by

the Secretary of State issued their report and recommendations. Many of these recommendations

(although not all) were incorporated into the Intend to Publish version. The Draft London Plan has a

significant amount of weight in planning decisions, although it will not be given full weight until the final

version is published.

8.3 On 13 March 2020 the Secretary of State formally directed the Mayor to make a number of detailed

modifications to the wording of various policies in the Intend to Publish version released in December

2019. Under the Greater London Authority Act 1999, whilst such a direction remains in force, the Mayor

must not proceed to publish the London Plan (in its final form) without modifying the Intend to Publish

version so as to comply with the direction. From the Mayor’s reply to the Secretary of State on 24 April

2020 as published on the GLA website, it appears that there may be further dialogue between the

Mayor and the Secretary of State about the modifications. However, the outcome of this process is not

known at present. Officers have therefore needed to take into account the effect of the Secretary of

State’s direction on emerging London Plan policies.

8.4 It is not considered that the Secretary of State’s modifications to the Intend to Publish version alter the

assessment of the application. This is because the emerging London Plan policies that are affected

by the direction are not considered relevant to the current proposal. The degree of weight to be

attached to the draft London Plan as a whole is noted above.

8.5 The LLP is currently under partial review to ensure it complies with amendments to changes in the

National Planning Policy Framework (NPPF) and London Plan. The Draft Revised Lambeth Local Plan

underwent public consultation from October to December 2018 under Regulation 18 of the Town and

Country Planning (Local Plans) (England) Regulations 2012. Pre-submission publication (Regulation

19) of the Draft Revised Lambeth Local Plan Proposed Submission Version occurred between 31

January and 13 March 2020. The Council submitted the draft plan for examination on 22 May 2020.

Officers consider that this should be afforded very limited weight at this stage.

8.6 The site falls within the Southbank and Waterloo neighbourhood area. The adopted Southbank and

Waterloo Neighbourhood Plan 2017-2032 is in place for this neighbourhood area (referred to in this

report as the SOWN Neighbourhood Plan).

8.7 The latest National Planning Policy Framework was published in 2018 and updated in 2019. This

document sets out the Government’s planning policies for England including the presumption in

favour of sustainable development and is a material consideration in the determination of all

applications.

8.8 The current planning application has been considered against all relevant national, regional and local

planning policies as well as any relevant guidance. A full list of relevant policies and guidance has

been set out in Appendix 3 to this report.

ASSESSMENT

9 LAND USE

9.1 Appropriateness of an office use on the site

9.1.1 Policy ED3(a) of the Lambeth Local Plan (LLP) 2015 states that proposals for offices greater than

1,000sqm will be supported in the Central Activities Zone, Vauxhall and Waterloo London Plan

Opportunity Areas and Brixton and Streatham major town centres.

9.1.2 Policy ED5(a) of the Lambeth Local Plan (LLP) 2015 states that the use of railway arches for B1 use

will be supported within the London Plan Opportunity Area.

9.1.3 Office use is supported in the CAZ under London Plan Policy 2.11 and within the Waterloo

Opportunity Area under Policy 2.13. The additional floorspace would contribute towards the strategic

aim of supporting 15,000 jobs in the Opportunity Area with the potential to provide approximately 206

jobs. LP Policy 4.2 supports new office development in viable locations with good public transport

where there is evidence to show sustained demand for office based activities. The London Plan

identifies a demand for 2.71-3.07 million sqm of new office space in the CAZ and north of the Isle of

Dogs. The latest figures in the draft London Plan show an increased forecast demand of 3.5 million

sqm for the period 2016 and 2041. The proposed development would help achieve this target by

providing 3,699sqm (GIA) of high quality office space. This space would be flexible so that it could

support small, medium and larger enterprises in compliance with Policy 4.2 and Policy E1 under the

draft LP.

9.1.4 Policy 2.11(a) and 4.3 of the London Plan states that proposals to increase office floorspace in the

CAZ should include housing. There is no housing on the site and no housing is proposed under this

application. The Mayor’s CAZ SPG and Policy SD5 of the draft London Plan identifies that offices

and other CAZ strategic functions should be given greater weight relative to new residential use in

the Waterloo Opportunity Area. Policy 2.11 of the London Plan requires proposals for office space

within the CAZ to provide a mixed use unless such a mix would demonstrably conflict with other

policies set out in the London Plan and Local Plan. The applicant has submitted a Planning

Statement which states that a mixed-use scheme has not been proposed in line LP Policy 2.11 as

the site is heavily constrained due to its location beneath the Waterloo Station railway bridge,

resulting in significant structural and design constraints, including the need for Network Rail to

access the site regularly for maintenance works. Noting the location and the constraints of the site, it

would not be suitable to provide a mixed-use scheme at the site which would include a residential

element. As such, a wholly commercial scheme is considered to be acceptable in this location.

9.1.5 Policy P12 of the SOWN Neighbourhood Plan states that schemes will be encouraged which provide

office or workspace.

19.1.6 The application site is within the Central Activities Zone and is therefore an appropriate location for

an office use. The proposal would present an opportunity for the re-development of underused

arches into a productive, employment-generating office use. The proposed B1 use is acceptable for

the site and is welcomed and would accord with the principles of Policies 2.11 and 2.13 of the

London Plan, Policy ED3 and ED5 of the Lambeth Local Plan (2015) and Policy P12 of the SOWN

(2018).

9.2 Provision of Affordable Workspace

9.2.1 The Intend to Publish London Plan (2019) seeks to ensure that new commercial developments

creating more than 2500sqm of business space provide low-cost business space (Policy E2) and also

affordable workspace (Policy E3). Policy E3 further notes that particular consideration of affordable

workspace should be provided in the CAZ. The policy advises boroughs to consider detailed affordable

workspace policies in light of local evidence of need and viability. Accordingly, in Lambeth’s draft new

Local Plan, Policy ED2 requires major developments that include B1 floorspace to provide a portion of

affordable workspace depending on its location. In Waterloo, the draft requirement is that 10 per cent

of B1 floorspace shall be discounted at 50 per cent of market rents for a period of 15 years.

9.2.2 Furthermore, Policy ED2 of the Draft Revised Lambeth Local Plan (October 2018) states that all major

developments proposing B1 floorspace are to provide a proportion of affordable workspace within the

Waterloo Opportunity Area. Emerging policy ED2 is further supported by Lambeth’s Draft Affordable

Workspace SPD (Feb 2020) – this document has been through one round of consultation with another

expected late 2020. The SPD carries very limited weight.

9.2.3 Policy P12 of the SOWN Neighbourhood Plan states that schemes will be encouraged which provide

office or workspace with the following characteristics:

i) are able to be subdivided to encourage flexible use and co-working and/or;

ii) include a range of unit sizes including offices of under 1000sqm and/or;

iii) are able to provide accommodation for a range of jobs which are accessible to local people

and/or;

iv) commit to working with third party employment support providers and local schools to provide

work placements, apprenticeships and training support for unemployed people.

9.2.4 Whilst it is noted that the draft London Plan policies do not currently have full weight, but do have

significant weight, the proposal would result in the creation of affordable workspace which the applicant

proposes would be operated by Sustainable Workspaces (an affordable workspace operator).

9.2.5 In the applicant’s ‘Consultation Response Schedule’ dated 19.03.2019 (reiterated in an email dated

28.02.2020), they advise that they expect Sustainable Workspaces will lease all of the B1 space at a

rent of £30/sqft, which would be at a significant discount (£1,194,480 for an GIA of 39,816sqft) to open

market rent (approximately around £50-60/sq ft which would equate to £1,990,800 - £2,388,960 for an

GIA of 39,816sqft). The website for Sustainable Workspaces states that the business is ‘the largest

ecosystem of sustainable start-ups and corporates in the UK and Europe’. The business brings

together startups, corporates, government and NGOs into their workspaces which are uniquely

focused on sustainable development (buildings, food, energy, transport, circular economy and clean

air). Strictly applying emerging Policy ED2 would require the provision of 369sqm (3972sqft) of

affordable space. The letting of the whole unit to Sustainable Workspaces is sequentially preferable to

applying emerging Policy ED2 in the first instance, as the former would enable the larger area to be

taken on by Sustainable Workspaces. It is noted that the applicant has not provided details of how

long Sustainable Workspaces would be leasing the floorspace – in the absence of this information it

is considered that any obligation should relate to a period of 15 years to align with provision of

affordable workspace set out in emerging policy ED2. Any affordable workspace terms would need to

be secured by way of a planning obligation.

9.2.6 Lambeth’s Economy and Inward Investment Team have set out the proposed Affordable Workspace

obligations that they wish to secure through a Section 106 agreement as follows:

To let all the proposed B1 floorspace to Sustainable Workspaces (the applicant’s preferred provider)

for the discounted rent of £30/sqft;

Approval of an Affordable Workspace Management Plan with Lambeth Council to produce annual

report detailing and quantifying social impact, as well as setting out matters such as the basis on

which the space will be let to end use occupiers as set out in Section 5 of the Draft Affordable

Workspace SPD;

In the event that Sustainable Workspaces do not lease all of the proposed B1 floorspace, the

following cascade mechanism is proposed:

i. Sustainable Workspaces to lease all the B1 floorspace and agree an Affordable Workspace

Management Plan with the Council;

ii. If (i) does not occur or if Sustainable Workspaces vacate the B1 floorspace before the end of

15 years, 10% of the floorspace is to be provided at 50% market rent for 15 years and

leased to a suitable organisation on the Council’s emerging Approved Workspace Provider

List or Charitable/Not-for profit Register. The workspace should have a sectoral focus on the

low carbon and/or life sciences sectors, building on multi-stakeholder efforts locally (for

example within the Guys & St Thomas’ Charity Estate which adjoins the site to support the

growth of low carbon focussed and life science enterprise in South Bank, Waterloo and the

wider SE1 economic geography. Should this focus not be possible, a wider focus of

supporting the creative and cultural economy should be sought for the occupation of the

arches;

iii. In the event that both i) and ii) are unable to be secured, a financial contribution as

calculated in Appendix 10 of the Draft Revised Lambeth Local Plan will be sought.

A review mechanism will be required in the Section 106 agreement should Sustainable Workspaces

vacate the site before the end of the 15 year period. The mechanism would require that a new

affordable workspace operator will need to be sought to manage the workspace and be subject to an

Affordable Workspace Management Plan.

9.2.7 Regeneration Officers and the Economy and Inward Investment Team have requested that Officers

include an obligation that directs the occupation of the affordable workspace element towards a

sectoral focus on the low carbon and/or life sciences sectors. Planning Policy Officers have advised

that the emerging policy ED2 allows for affordable workspace to be taken up by a specific sector in

line with what the Economy and Inward Investment Team have requested. It is noted that the

applicant has agreed that in the event that Sustainable Workspaces do not take the affordable

workspace, the floorspace would then be leased to a new affordable workspace provider with a

preference for a provider that has a sectoral focus on the low carbon and/or life sciences. Officers

have therefore added this preference into the proposed cascade mechanism. It is recommended that

the affordable workspace obligation provides for the following:

Securing of the B1 floorspace as affordable workspace subject to the following cascade mechanism:

i) Sustainable Workspaces to lease the B1 space, which is to be managed in accordance with an approved Affordable Workspace Management Plan (including requirements for annual report detailing and quantifying social impact);

ii) If (i) does not occur or if Sustainable Workspaces vacate the B1 space before the end of 15 years, 10% of the floorspace to be provided at 50% of market rent for the balance of the 15 year period running from the date of original occupation by Sustainable Workspaces and such floorspace to be leased to a suitable organisation on the Council’s emerging Approved Workspace Provider List or Charitable / Not-for-profit Register (with reasonable endeavours to be used to secure a provider with a low carbon/life sciences sectoral focus) and a replacement Affordable Workspace Management Plan entered into;

iii) In the event that both i) and ii) are unable to be secured, a financial contribution as calculated in Appendix 10 of the Draft Revised Lambeth Local Plan (Proposed Submission Version January 2020).

There is no requirement for a separate ‘review mechanism’ as requested by the Economy and

Inward Investment Team, as this is able to be covered by what is proposed at (ii) above.

9.2.8 Officers welcome the proposed affordable workspace and note this reflects emerging London Plan

policy and emerging borough level policy, albeit that neither of these has full weight and the

emerging borough policy is at a relatively early stage of preparation. In this instance, Officers agree

that the affordable workspace is secured through a ‘cascade’ mechanism whereby should

Sustainable Workspaces not lease the unit for discounted market rent or vacate the unit before the

end of their 15 year period, that 369sqm (3972sqft) affordable workspace can be secured for 10% of

the floorspace at 50% of the market rent for a period of 15 years from the first occupation of the B1

floorspace to accord with the emerging policy. In the event that occupation by Sustainable

Workspaces is unable to be secured or they vacate the premises within the 15 year period, the

cascade mechanism will apply and the applicant will need to provide an amount of affordable

workspace in accordance with emerging policy. If this is also unable to be secured, a financial

contribution following the formula set out in Appendix 10 of the Draft Revised Lambeth Local Plan

(2018) will be secured. Should a financial contribution be secured, emerging policy provides that this

can be spent on the provision of affordable workspace anywhere within the Borough. The cascade

mechanism is proposed because of the potential difficulty of letting an area of 369 sqm (3972sqft) in

the event that Sustainable Workspaces does not take on the whole of the B1 floorspace.

9.2.9 The proposed provision of affordable workspace reflects the aims of emerging Policy ED2 and draft

London Plan Policy E3. This element of the proposal is supported.

10 Design and Conservation

10.1 The beginning of the Agenda Pack contains a summary of the legislative and national policy context

for the assessment of the impact of a development proposal on the historic environment and its

heritage assets. This is in addition to Lambeth Local Plan and London Plan policies.

10.2 Turning to consider the application of the legislative and policy requirements referred to above, the

first step is for the decision-maker to consider each of the designated heritage assets (referred to

hereafter simply as “heritage assets”) which would be affected by the proposed development in turn

and assess whether the proposed development would result in any harm to the heritage asset.

10.3 The decision of the Court of Appeal in Barnwell Manor confirms that the assessment of the degree of

harm to the heritage asset is a matter for the planning judgement of the decision-maker.

10.4 However, where the decision-maker concludes that there would be some harm to the heritage asset,

in deciding whether that harm would be outweighed by the advantages of the proposed development

(in the course of undertaking the analysis required by s.38(6) PCPA 2004) the decision-maker is not

free to give the harm such weight as the decision-maker thinks appropriate. Rather, Barnwell Manor

establishes that a finding of harm to a heritage asset is a consideration to which the decision-maker

must give considerable importance and weight in carrying out the balancing exercise.

10.5 There is therefore a “strong presumption” against granting planning permission for development

which would harm a heritage asset. In the Forge Field case the High Court explained that the

presumption is a statutory one. It is not irrebuttable. It can be outweighed by material considerations

powerful enough to do so. But a local planning authority can only properly strike the balance

between harm to a heritage asset on the one hand and planning benefits on the other if it is

conscious of the statutory presumption in favour of preservation and if it demonstrably applies that

presumption to the proposal it is considering.

10.6 The case-law also establishes that even where the harm identified is less than substantial (i.e. falls

within paragraph 196 of the NPPF), that harm must still be given considerable importance and

weight.

10.7 Where more than one heritage asset would be harmed by the proposed development, the decision-

maker also needs to ensure that when the balancing exercise in undertaken, the cumulative effect of

those several harms to individual assets is properly considered. Considerable importance and weight

must be attached to each of the harms identified and to their cumulative effect.

10.8 What follows is an officer assessment of the extent of harm which would result from the proposed

development to the scoped heritage assets provided by the applicant as part of its submission. This

includes adjacent Conservation Areas.

10.9 Impact on heritage assets: Conservation Areas

10.10 The Council’s Conservation and Design Officer has considered the impact of the development on the

following heritage assets:

South Bank Conservation Area

Albert Embankment Conservation Area

Lower Marsh Conservation Area

Figure 15: Location of Conservation Areas near the application site (shown in pink).

10.11 Noting the location of the proposal within the railway arches and adjacent to the existing Urbanest

development, there would be limited views of the proposed development from the surrounding

Conservation Areas.

South Bank Conservation Area

10.12 From Addington Street (within the South Bank Conservation Area), there would be restricted views

looking southeast towards the proposal. In this view the proposal would appear modest compared to

its larger neighbour Urbanest. As such, the proposal would not harm the setting or views in and out

of the South Bank Conservation Area.

Albert Embankment Conservation Area

10.13 From Lambeth Palace Road (Albert Embankment Conservation Area) there would be restricted

views looking eastward toward the application site. The proposal is screened by Urbanest and

Becket House, again the proposal would compare modest next to both these buildings. As such, the

proposal would not harm the setting or views in and out of the Albert Embankment Conservation

Area.

Lower Marsh Conservation Area

10.14 The proposal is not visible from within the Lower Marsh Conservation Area. As such, the proposal

would not harm views in or out of the Lower Marsh Conservation Area.

Impact upon Heritage Assets: Summary

10.15 The proposal is not considered to cause harm to the significance of any heritage assets. It would

preserve the character and appearance of the adjacent conservation areas. The proposal would

therefore accord with the LLP Policy Q22, the requirements of the NPPF and the statutory duty

placed on the local planning authority.

Assessment of Harm versus Benefits

10.16 No assessment is required in terms of harm to heritage assets versus the public benefits of the

proposal given that officers have identified no harm to heritage assets.

10.17 Local views

10.18 Whilst it is noted that the application site is located within Local Views (NNE from Norwood Park to

the City, and from Battersea Park to The Gherkin and Canary Wharf), due to the location of the

proposal within the existing arch space beneath the Waterloo railway bridge, the proposal would not

impact on local views. As such, the proposal would accord with LLP Policy Q25.

10.19 Impact on heritage assets: Archaeological Priority Area

10.20 The application site is located within the North Lambeth Archaeological Priority Area. Historic

England Archaeology (GLAAS) were consulted on the application but no comments were received. It

is noted that the application is not proposing significant ground works to accommodate the change of

use at the site.

10.21 Scale, massing, layout and appearance

10.22 The proposal is for a glazed façade with expressed frame along the western elevation of the railway

viaduct. The façade treatment takes inspiration from S.R. Crown Hall by Mies van der Rohe (Chicago)

and would provide a lightweight visually permeable contrast to the heavy concrete structure of the

viaduct. Whilst there is in-principle support for a glazed infill approach which achieves a ‘clean, clear

and crisp expression’, Design Officers have previously raised concerns about its detailing during pre-

application advice. The glass façade would project beyond the viaduct by 1.4m and would rise above

the viaduct fascia by 0.8m. Design Officers are concerned that the combined forward and upward

projection would envelope the viaduct fascia and as a result the purity of the viaduct form and structure

would be lost and dominated by the glass façade. It is worthwhile noting that these concerns are

exacerbated by the increase in forward projection compared to the pre-application position, where

officers were told the projected was 300mm. Design Officers consider that their concerns have not

been considered in this regard.

10.23 Whilst the Design Officer has raised concerns with height and projection of the proposal, this has been

considered alongside the positive aspects of the scheme such as activating the arches, improved

semi-public realm and overall pleasing design. Officers consider that the design of the proposal to

include a new glazed curtain wall façade on the western elevation of the arches would read as a

cohesive design and would respect the railway arch. It would also animate an inactive edge and

increase passive surveillance. As such, it is considered that the design of the structure would be in

accordance with the principles of LLP Policies Q5, Q6, Q7, Q8 and Q11.

10.24 Public Realm

10.25 One of the key general aspirations for the Waterloo Area as set out in the Local Plan (Policy PN1) and

Waterloo SPD is to address existing problems of severance by increasing permeability throughout the

area. The Waterloo SPD outlines the Railway Character Area and advises that this area is dominated

by Waterloo Station and viaducts. The SPD seeks that development within this area should enhance

pedestrian routes and the public realm. This goes hand in hand with activating arches and improved

public realm. The Waterloo Opportunity Area Policy Framework (2007) supports this position and the

executive summary begins with statement ‘To give Waterloo a new ‘City Square’ to create a radically

improved public space; to improve permeability to and within the area and provide new development

principally in the area around and above Waterloo Station’. Appendix 4 further outlines that

improvements to pedestrian links along Upper Marsh were a priority. The proposal would upgrade

surfaces in front of the new development which is currently tarmac, improving the immediate

environment around the arches which complies with Policy ED5.

10.26 Design Officers however have raised concerns that the proposal retains gates at each end of the site;

along Westminster Bridge Road and Upper Marsh and consider that gating this area is not within the

spirit of the policy and does not seek to secure the wider ambitions for the area. They have commented

that opening up this road to the general public would provide increased permeability; improving

linkages between future major development coming forward to Waterloo Station in line with the

Waterloo SPD and Waterloo Opportunity Area Policy Framework (2007). The activity and animation

created by the proposed change of use will help with natural surveillance of the road and therefore the

need for gates would not be necessary. Officers note that the applicant has previously expressed

concerns regarding the safety of the students’ amenity area should the road become publicly

accessible. Design Officers believe this could be resolved by securing the communal amenity area

with a boundary.

10.27 The opening up of the service road which includes the ‘Safeguarded Land’ identified in the S106

agreement for application 12/04421/FUL would further meet the current requirements of Policy ED5(d)

which requires applications affecting railway arches to improve the immediate environment around the

arches, including the public realm. This is to include accessibility, safety, servicing and lighting

appropriate to the location.

10.28 Officers agree with the Design Officers’ comments and note that agreement has been reached

between the applicant and parties that have an interest in the land to enter into a section 106 obligation

to provide for the opening up the service road and removal of the gates as outlined in paragraph 4.5

of this report. The imposition of a ‘Grampian’ condition is therefore recommended to prevent the

application site development being occupied until the necessary planning obligation has been entered

into in respect of the service road (as shown in Figure 11). This is proposed as Condition 3.

10.29 Furthermore, as one of the triggers to opening the service road (which sits within the ‘Safeguarded

Land’) ties in with the potential adjacent Royal Street development (Strategic Site 1) (see Figure 12),

the applicant has proposed that an Estate Coordination Management Plan be developed between

parties who have an interest in the ‘Safeguarded Land’. Officers are therefore recommending provision

for an Estate Coordination Management Plan between relevant landowning parties to be submitted to

the Council for approval which will outline how the ‘Safeguarded Land’ will be managed and maintained

by relevant landowners, including how anti-social behaviour will be monitored along the ‘Safeguarded

Land’. The applicant has suggested that the Estate Coordination Management Plan covers a number

of issues relating to the ongoing use of the service road. Officers do not consider that these issues are

able properly to be addressed at this stage or that it is necessary to do so. They are recommending

that a planning obligation is entered into that will require adherence to an approved Estate

Coordination Management Plan and that the obligation will need to set out the agreed principles which

any such Plan will need to address in respect of matters including the future use of the service road.

10.29 The proposed ground floor plan initially showed a division of the Urbanest amenity space area.

Amended plans were received on 03.03.2020 with this fence removed. This is considered acceptable

and would ensure that the landscaped area is useable and functional.

10.30 A relatively large refuse holding area is proposed close to the Lower Marsh and would be sited over

an existing swale within the Urbanest amenity area. Further details would be secured by condition 11

to include how the area will be treated, its relationship with the swale and screening.

11 Amenity for Neighbouring Occupiers

11.1 Privacy and Outlook

11.2 The proposed office space would look towards Urbanest located 6.9m from the arches at the closest

point. The approved floor plans of Urbanest (application ref: 12/04421/FUL) show that the approved

floor space at ground and first floor facing the arches are in affordable workspace and college use.

As such, there would be no loss of privacy or outlook to the residential element of the Urbanest

scheme.

11.3 Noise and Vibration

11.4 An Environmental Noise Survey prepared by RBA Acoustics has been submitted and reviewed by

the Council’s Environmental Health Consultants. The Consultants have advised that the Noise

Survey identified that the development site will be impacted by high levels of environmental noise

and vibration. Consultants have recommended conditions with respect to the internal noise

environment of the proposed offices and building services plant and a condition is proposed to

ensure these recommendations are implemented. Officers agree with the suggested condition and

these have been added to the proposed decision notice as Condition 23.

11.5 Given the commercial nature of the surrounding location it is considered that the use of a B1 office is

appropriate and would not be out of character or result in undue noise or disturbance impacts.

12 Designing Out Crime

12.1 London Plan 2015 Policy 7.3 states that development should amongst other things, reduce

opportunities for crime and contribute to a sense of security in particular, well maintained routes, clear

indication of spaces being private, semi-private or public and natural surveillance, encourage activity

appropriate to the location, promote a sense of ownership of spaces, places and buildings, integrate

security features into the design. Policy Q3 (Community safety) requires developments to be designed

in a manner that does not engender opportunities for crime or anti-social behaviour or create a hostile

environment that would produce fear of crime.

12.2 The application was referred to the Metropolitan Police Design out Crime advisor who raised no

concerns regarding the proposed development. This is subject to a recommended conditions requiring

the development to adhere to the principles of secured by design and advised that the application

should benefit from the same standards, measures and principles applied to the Leake Street Tunnel

Development.

12.3 The applicant advised in their consultation response of 19.03.2019 that they did not consider that a

full secure-by design certification would be appropriate for the proposed development and noted that

the Leake Street redevelopment involved a greater area and is a publicly accessible development

incorporating thoroughfare and premises that are open late into the evening. The applicant argues that

the proposed development is more modest and involves the refurbishment of the arches for office use

within a private and access controlled site rather than a public thoroughfare.

12.4 Since the consultation response, the applicant has proposed the ‘opening up’ of the adjacent service

road with the gates being open between the hours of 7am and 10pm as set out at paragraph 6.4 of

the report. Once the Royal Street site has been developed, the applicant has proposed that these

gates would be removed in their entirety. The southern-most arch adjacent Upper Marsh is partially

used as an emergency escape route from Waterloo Station. The applicants are proposing to retain

the emergency access and have specified a ‘no build zone’ adjacent the base of the staircase to

ensure that there is no obstruction should an emergency arise. The ‘no build area’ will be secured by

a planning obligation to ensure that emergency access is not obstructed. Noting this, the scheme

would be publicly accessible due to the opening up of the adjacent service road, increasing the

permeability of the arches, improving pedestrian linkages and the proposed conditions are

considered to be acceptable, affording the scheme with security through design. On this basis, it is

considered that the proposed development in consistent with the Council’s policies about community

safety in Local Plan Policy Q3 and Officers have retained the suggested conditions 33 and 34 from

the MET Police.

13 Transport

13.1 Site context

13.2 The application site is in close proximity to Waterloo Station and has a PTAL (Public Transport

Accessibility Level) score of 6(b), which is considered excellent on a scale of 0-6, where 0 is

considered ‘very poor’ and 6a/b is classified as ‘excellent’. Office users at the proposed development

site would benefit from excellent access to local public/passenger transport services.

13.3 No new or amended pedestrian or vehicular access is proposed in the application, hence access

arrangements remain as present from the service lane adjacent the arches. Access to the service

lane is gained from Upper Marsh. To the west of the application site, the road divides into two

branches; one branch linking directly onto Lambeth Palace Road to the west (restricted access) and

the other providing access to Royal Street to the south. Upper Marsh also provides access to

Westminster Bridge Road to the west of the Development, although vehicles are not permitted to

turn into Upper Marsh from Westminster Bridge Road.

13.4 Trip Generation

13.5 Lambeth advises/uses a 12sqm per employee employment density which sets out the suggested

space required in an office to support each employee as set out in the Employment and Skills SPD

(2018). This suggests that approximately 196.5 employees will be working within the proposed B1

use, resulting in approximately 66 arrivals/departures in the morning and evening peaks,

respectively. In a centrally and well-connected location such as this, particularly mindful of the

highest possible PTAL rating, Transport Officers advise that the local highway/footway network will

readily absorb any associated/projected increase of this level.

13.6 Car parking & servicing

13.7 A Controlled Parking Zone (CPZ) spans the Waterloo area within Lambeth. The CPZ for the area

within which the Development is located is Waterloo ‘W’, which operates between 08:30 to 18:00

Monday to Friday and 08:30 to 13:00 on Saturdays. The nearest on-street pay and display and

permit holder parking bays are located on Royal Street, to the south of the application site. Given the

local high quality public transport links/provision and the need to reduce dependence on private car

use in line with development plan policies the proposal will be secured as car-free. A car parking

permit free agreement restricting employees from applying for on-street business parking permits

would be secured by way of a planning obligation.

13.8 Whilst the development is required to be car-free (Draft London Plan Policy T6.2) adequate provision

for disabled people/parking (Lambeth Local Plan Policy T7) should be made. The applicant has

shown on the revised plans submitted on 17.01.2020 that 2 disabled car parking spaces are to be

provided for the proposal. These are to be located along the adjacent service road. It is noted that

the number of disabled car parking spaces would accord with the requirements of the current London

Plan which requires a minimum of 2 spaces as per Table 6.2 of Policy 6.13 of the London Plan.

Figure 16: Table 6.2 of the London Plan setting out the disabled parking requirements for an office use.

13.9 The proposed 2 disabled parking spaces also meets the requirements of the Draft New London Plan

(Figure 16) which requires that office uses provide a disabled parking spaces that equate to 5% of

the overall parking provision. Noting that the application is car-free, the requirement for 2 disabled

car parking spaces would meet the requirement (1 designated bay and 1 enlarged bay).

Figure 17: Table outlining the provision of disabled car parking spaces for office use under the Draft

New London Plan.

13.10 Cycle Parking

13.11 The applicant is proposing to provide 58 long-stay cycle parking spaces and 10 short-stay cycle

parking spaces for the office use. The cycle parking is to be located at ground floor level. The

proposed cycle parking meets the London Plan requirements for B1 use as set out in Figure 18.

Figure 18: Current London Plan cycle parking requirements.

13.12 London Cycling Design Standards (LCDS) state that where cycle parking is inside a building, it

should have step-free access, wide doorways and spacious corridors. Accessing the parking area

should involve passing through no more than two sets of doors, with a recommended minimum

external door width of 2 metres. Lifts or shallow gradient ramps should be provided to any basement

cycle parking.

13.13 LCDS further states that cycle parking must be well located: close to the entrance of the property

and avoiding obstacles such as stairs, multiple doors, narrow doorways (less than 1.2 metres wide)

and tight corners. To accommodate all types of cycle, any lifts proposed lifts should have minimum

dimensions of 1.2 by 2.3 metres, with a minimum door opening of 1000mm, and any door to a cycle

parking area should be automated –push button or pressure pad operated.

13.14 The cycle parking will be provided via a variety of cycle stand types, including cradles, wishbones

and hoops, to ensure a suitable provision of cycle parking is available on-site to cater for all types of

cycles, including adapted cycles for disabled cyclists. Lambeth Transport Planning welcomes this.

Additionally, the office will include showers, with changing facilities and lockers for use by

employees.

13.15 The proposed cycle parking spaces for the office use meet the requirements for cycle parking set out

in the draft new London Plan (Figure 19) which requires 1 long-stay space per every 70sqm of floor

space (requires 33 cycle spaces) and 1 short-stay space for every 500sqm of floorspace up to

5000sqm (requires 4.95 cycle spaces).

Figure 19: Draft New London Plan cycle parking requirements for B1 Business uses.

13.16 Overall, the proposed cycle parking for the B1 office use meets the requirements of both the current

and draft new London Plan and that of Policy T3 and Q13 of the Lambeth Local Plan (2015). TFL

Road Network have no objection to the levels of cycle parking proposed for the office use.

13.17 Service and Delivery

13.18 Deliveries and refuse collection will be undertaken on-site, with deliveries by vehicles up to and

including a 7.5T Box Van being accommodated on-site and allowing access and egress in forward

gear. A Servicing & Delivery Plan is submitted in support of the application and this reflects

discussion Lambeth Transport Planning has had with the applicant during pre-application stages.

This is welcomed and presents there most appropriate fork of servicing for this site. Transport

Officers have reviewed the supporting swept-path (vehicular tracking) drawings and the proposed

manoeuvres associated with arriving/departing vehicles appear to be acceptable.

13.19 It is also noted that industry standard data (TRAVL/TRICS) assumes 0.25 deliveries per 100sqm

(GEA), therefore, the proposed 3,921sqm (GEA) office development will generate approximately 9 –

10 deliveries per day, all of which will be undertaken on-site. It is concluded this will not have a

severe (or notable even) impact on the free flow of traffic on the surrounding road network. TFL

Road Network have advised that the Service and Delivery Plan (prepared by Caneparo Associates –

February 2020). TFL have suggested that should the application be permitted, that a full Delivery

and Servicing Plan be secured by condition in accordance with draft London Plan Policy T7 and

Policy T6 and T8 of the Lambeth Local Plan (2015). Officers agree that a full, updated Service and

Delivery Plan should be submitted and this has been secured as Condition 7.

13.20 Refuse and Recycling

13.21 The applicant has proposed a dedicated refuse and recycling store within the office at ground floor

level. Waste is proposed to be consolidated in 1,100 wheeled bins. Waste will be collected from the

office units daily or multiple times a day (as required) and taken to the dedicated waste storage area.

The submitted Operational Waste Strategy (December 2018) document outlines that the store will be

designed to BS5906:2005 Waste Management in Buildings – Code of Practice. Full details of

servicing, delivery and waste management have been requested as Condition 7 of the draft decision

notices.

13.22 The Operational Waste Strategy (December 2018) estimates that the office use would generate

8,323L of waste per week (5,576L of refuse and 2,747L of recycling). Based on this, the waste store

would require 3x 1,100L refuse bins and 2x 1,100L recycling bins – 5 bins total.

13.23 The bins will be delivered to the waste collection point (see Figure 20) on the nominated collection

days and collected by waste collection operatives.

Figure 20: Location of waste collection point adjacent Upper Marsh.

13.24 Veolia Waste and Lambeth Transport Officers both have raised no objections to the proposed refuse

and recycling servicing. Full details of the proposed waste collection point will be required to be

submitted to ensure that the store meets the requirements of “Waste & Recycling Storage &

Collection Requirements – Technical Specification for Architects & Developers (October 2013)” and

accords with the principles of Policies T6, T8 and Q12 of the Lambeth Local Plan (2015).

Figure 21: Swept path assessment of refuse vehicles servicing the waste collection point.

13.25 Construction and Logistics Plan

13.26 Local Plan Policy T8(d) requires planning applications to be accompanied by a construction and

logistics plan, demonstrating arrangements for construction traffic and how environmental, traffic and

amenity impacts would be minimised.

13.27 TFL Road Network have reviewed the Draft Construction Management Plan (19th December 2018)

and requested that a full Construction Logistics Plan be secured by condition and that this should be

prepared in line with TfLs latest guidance, and should include details of construction vehicle routing,

alongside the expected number, frequency and types of vehicles that will be entering the site during

construction works. This is considered acceptable and has been added to the draft decision notice

as Condition 5.

13.28 It is noted that the Air Quality Officer has requested that Section 6.1 of the submitted Air Quality

Assessment (December 2018) titled ‘Construction’ should be incorporated into the CLP. This is

acceptable and has been added into the details of Condition 5.

14 Sustainable Design and Construction

14.1 Carbon Reductions and BREEAM

14.2 Non-residential developments should also be accompanied by a pre-assessment, demonstrating how

the following BREEAM standards, or any future replacement standards, will be met. Policy EN4(b) (i)

states that all new non-residential development and non-self-contained residential accommodation,

should meet at least BREEAM ‘Excellent’ unless it is demonstrated that it is not technically feasible or

viable to do so, in which case proposals should demonstrate a ‘Very Good’ rating with a minimum

score of 63 per cent.

14.3 London Plan Policy 5.2 requires that major development should provide a detailed energy assessment

to demonstrate that the targets for carbon dioxide emissions reduction of 35% over Part L of the

Building regulations for non-residential buildings can be met. The policy further notes that should the

carbon reduction targets not be met onsite, any shortfall may be provided off-site or through a cash in

lieu contribution to be ring fenced to secure the delivery of carbon dioxide savings elsewhere.

14.4 The Council’s Sustainability Consultant advised the application fails to meet the minimum 35%

reduction in CO2 emissions over Part L of the Building Regulations (2013), only meeting a target of

17.5%. However, the consultant has noted that whilst the proposal does not meet the policy

requirement reduction of 35%, the applicant has done everything possible to maximise the carbon

reduction of the scheme (providing high levels of thermal insulation, selecting glass that will provide

adequate levels of solar control and light transmittance, AHSP systems, energy efficient light fittings

and external lighting systems that are controlled by a timer). Noting this, the Sustainability Consultant

has recommended that in the event of a permission, that design stage and as-built calculations are

submitted to ensure that the development has achieved the 17.5% reduction as outlined in the Energy

and Sustainability Statement. This is acceptable and would accord with the principles of Policies 5.2

and 5.7 of the London Plan (2015).

14.5 Noting that the proposal does not meet the requirement of 35% reduction in carbon emissions, the

applicants are required to provide a cash in lieu payment for carbon off-setting. The Council’s

Sustainability Consultant advised that this was not addressed in the submitted Energy and

Sustainability Statement. The applicant provided a ‘Consultation Response Schedule’ on 19.03.2019

which advised that the rate for carbon offsetting tax as recommended by the Sustainable Design and

Construction SPG to the London Plan is £60 per tCO2 per year over a period of 30 years and should

be calculated in comparison to a building achieving 35% carbon reduction. Using these rates, the total

estimated cash in lieu payment for the development would be £29,800. The financial contribution

would accord with the requirements of Policy 5.2 of the London Plan and will be secured through a

Section 106 agreement.

14.6 Local Plan Policy EN3 states that all major development will be expected to connect to, and where

appropriate extend, existing decentralised heating, cooling or power networks in the vicinity of the site,

unless a feasibility assessment demonstrates that connection is not reasonably possible. Major

development proposals that cannot immediately connect to an existing heating or cooling network

should evaluate the feasibility of combined heat and power (CHP) systems and where appropriate,

examine the feasibility of extending the system beyond the site boundary.

14.7 The submitted Energy and Sustainability Statement has been reviewed by the Council’s Sustainability

Consultants who have noted that the applicants have made provisions to connect to a decentralised

network if it becomes operational in the future. The Consultant requested further information on how

the development will have the capability to connect to a future planned decentralized network and has

suggested that this could be addressed through a pre-commencement condition. Further information

has been provided by the applicant on 19.03.2019 with an amended plan (00)_P100 rev P01 outlining

where the potential connections to the network could be undertaken. The plan shows the site location

and distance to the potential district heating network, a floor plan identifying the space allowance for

future capped-off connection and valved pipework and a more detailed LTHW schematic. The

Sustainability Consultant has advised that the applicant had specifically responded to the request for

additional information on the proposed connection to the SPEG network by providing plans of the

proposed technology and as such, this element of the scheme was satisfactory and no condition was

required.

15 Other Environmental Matters

15.1 Flood Risk

15.1.1 The site is in Flood Zone 3 and is located within an area benefitting from flood defences. Whilst the

site is protected by the River Thames tidal flood defences up to a 1 in 1000 (0.1%) chance in any

year, the Environment Agency (EA) have commented that their most recent flood modelling

(December 2017) shows that the site is at risk if there was to be a breach in the defences.

15.1.2 The EA have reviewed the submitted Flood Risk Assessment (FRA) by WSP (dated January 2019

with reference 70052923 DI-001) provides an accurate assessment of the tidal and fluvial flood risks

associated with the proposed development.

15.1.3 The EA advise that the site is located over a Secondary Aquifer. The EA note that the submitted

‘preliminary environmental risk assessment desk study’ document by WSP (dated December 2018

with reference 70052923GEO) has indicated the potential for historic ground contamination to be

present and has recommended an intrusive investigation to assess this situation. The EA have

recommended 5 conditions relating to the protection of the secondary aquifer and ensuring that there

is no contamination of groundwater. These conditions are considered acceptable and have been

added to the decision notice as Conditions 25-29.

15.1.4 Lambeth’s Flood Risk Officers have advised that there is no objection to the proposal noting that the

proposal will utilise and existing Sustainable Drainage System that has been designed to accept

flows from this development.

15.1.5 Overall, the proposal would accord with Policies EN5 and EN6 of the Lambeth Local Plan (2015) and

Policies 5.3 and 5.12 of the London Plan.

15.2 Air Quality

15.2.1 The application has been supported by an air quality assessment as required for all major

developments in the borough. The proposed development is a major development located within a

borough-wide Air Quality Management Area (AQMA), within 400m of a GLA-designated Air Quality

Focus Area (area of high pollution combined with high exposure) of Waterloo Road and in Central

Activities Zone for the purpose of Non-Road Mobile Machinery Low Emission Zone requirements. It

is located in an area where Air Quality Objectives for nitrogen dioxide NO2 are exceeded (both

annual mean and predicted hourly mean) and in the immediate vicinity of St. Thomas’ Hospital and a

number of residential properties, all classed as sensitive receptors to air pollutants.

15.2.2 The development is proposed to be car-free, with limited number of daily servicing and delivery trips.

The development does not include static combustion plant. Instead, electric air source heat pumps

will provide building heating and cooling. Officers commend this approach and welcome the proposal

from the air quality perspective.

Air Quality Impacts from Demolition and Construction

15.2.3 The Air Quality Assessment’s conclusion that the site is Medium Risk in respect of demolition and

Low Risk in respect of earthwork, construction and trackout is accepted. As the classification falls

between two categories Officers accept that the site is Medium Risk overall.

15.2.4 Construction impacts mitigation measures proposed in the AQA, which are based on the Control of

Dust and Emissions during Construction and Demolition SPG 2014, are accepted.

15.2.5 Air Quality Officers have reviewed the draft Construction Management Plan (CMP) and have found

limited air quality and dust mitigation measures in section 4.2 Air Pollution, Dust and Dirt Control.

Officers request that mitigation measures listed in the AQA section 6.1 Construction are included in

the final CMP. As the measures in AQA area based on the Control of Dust and Emissions during

Construction and Demolition SPG 2014, Officers would refer the Applicant to Appendix 7 of the SPG

which contains a list of recommended and desirable measures. The site is classified as Medium Risk

overall.

15.2.6 Due to the presence of sensitive receptors in the vicinity of the area, the Applicant is encouraged to

install green hoardings/walls and other vegetation around the construction site to minimise the

impact of dust and pollution and also to improve the local environment during construction.

Air Quality Impacts During Operation, including Air Quality Neutral Assessments

15.2.7 As the development is car-free and the TEB calculations related to servicing and delivery trips are

accepted, the site is Air Quality Neutral in terms of Transport.

15.2.8 As the proposed development will be heated and cooled using electric air source heat pumps and

there will be no on-site static combustion plant, the conclusion that the air quality neutrality in terms

of building emissions is not relevant to this development is accepted and it may be concluded that

the development is therefore Air Quality Neutral in terms of Building emissions. In addition, air

intakes are proposed on the western façade - avoiding Westminster Bridge Road where air pollutant,

particularly concentrations are likely to be highest.

15.2.9 No other air quality impacts of the development and on the development have been identified.

Emissions from the nearby railway lines are considered negligible given the development’s location,

design and the proposed office use. Officers are therefore satisfied that the scheme would accord

with the aims of Policy 7.14 of the London Plan.

16 Employment and Training

16.1 Policy ED14 of the Lambeth Local Plan states that planning obligations should be used to secure

employment opportunities and apprenticeships arising from major developments, so that local

residents are given access to the right skills training so that they can take advantage of opportunities

created by new development. The SPD on Employment and Skills (2018) sets out a ‘headline’ target

of 25% of jobs generated by developments as being for local residents. The SPD envisages that an

applicant will be asked to work towards delivery of that target through the carrying out of an

approved employment and skills plan, which would be designed so as to include the intended target

numbers and types of job opportunities. The SPD envisages an element of flexibility in how the

applicant may agree to work towards delivery of employment and skills obligations, for example as

regards the target mix of jobs, apprenticeships and/or bespoke employment training and support

arrangements. The employment and skills plan should also set out how the applicant will aim to

deliver young people’s training and careers initiatives. The SPD also envisages the possibility in

individual cases of an applicant making a payment in lieu rather than seeking to deliver employment

and skills obligations ‘in kind’ and the SPD sets out the broad basis on which such payment would be

calculated.

16.2 The application has been reviewed by the Employment and Skills Team who have requested that an

Employment and Skills Plan is produced for both the construction and end phase of the development

and a financial contribution towards local employment and training be secured. Based on the

applicant’s figures, the following contribution is to be secured through a planning obligation:

2,358 sqm(NIA) / 12 sqm per job for B1 office = 196.5 jobs

(2,358/12) x 25% x 17.8% x £6,500 = £56,838.

16.3 LLP Policy ED14 (c) states that the Council will work with local training providers and aim to ensure

that local residents are given access to the right skills training so that they can take advantage of

opportunities create by new development. The financial contribution of £56,838 is directly linked to

this part of Policy ED14 and would ensure that the training referred to in the policy is able to be

funded.

17 Accessibility

17.1 Access to the site is gained from the service road adjacent the arches. Lifts are proposed in the

reception area to give access to the raised ground floor and another lift is proposed to enable access

from the ground floor to the mezzanine floor. Both the ground floor and mezzanine floor contain a

bathroom that would allow for wheelchair access. As such, the proposal accords with Policy Q1 of

the Lambeth Local Plan (2015).

18 Planning Obligations and CIL

Planning Obligations

18.1 The LLP Policy D4 and Annex 10 sets out the Council’s policy in relation to seeking planning

obligations and the charging approaches for various types of obligation. For contributions that are

not covered by Annex 10, the Council’s approach to calculating contributions is guided by the

Development Viability SPD (adopted 2017) and the Employment and Skills SPD (adopted 2018).

18.2 The planning obligations that are proposed are considered necessary to make the development

acceptable in planning terms, are directly related to the development and are fairly and reasonably

related in kind and in scale to the development. They are therefore compliant with the requirements

of Regulation 122 of the Community Infrastructure Levy Regulations 2010.

18.3 The proposed obligations to be secured are as follows:

Item Details

Carbon offsetting Payment of £29,800 to achieve zero carbon

Employment and Skills Employment and Skills Plan for both the

construction and end phase;

Financial contribution of £56,838.

Service road (to be addressed via amendment to

existing S106 obligation relating to the adjoining

development and through any necessary

‘mirroring’ of that amended obligation in relation to

the proposed development)

Provision for opening up of the service road to

provide for pedestrian use of the service road

and to limit vehicular access accordingly as set

out in paragraph 4.5.

Affordable Workspace Secure the B1 floorspace as affordable workspace subject to the cascade mechanism as set out in paragraph 9.2.7.

Transport Parking permit free designation for

business/employees

To be included in relation to the Estate

Coordination Management Plan via amendment

to existing S106 obligation relating to the

adjoining development and through any

necessary ‘mirroring’ of that amended obligation

in relation to the proposed development

Obligation that requires adherence to terms of

an approved Estate Coordination Management

Plan for the Safeguarded Land and sets out the

agreed principles which any such Plan will need

to address in respect of matters including the

future use of the service road

Other Ensure ‘no build zone’ remains clear to ensure

no obstruction in an emergency from Waterloo

Station

Monitoring fee of up to 5% of the total financial

obligations

CIL

18.4 If the application is approved and the development is implemented, a liability to pay the Lambeth

Community Infrastructure Levy (CIL) will arise.

18.5 The Lambeth CIL contribution is estimated, on the basis of information supplied with the planning

application to be £646,164.23. This figure is subject to indexation which will be charged at the date of

the decision. Expenditure of the majority of a future CIL receipt will be applied towards Borough

infrastructure needs in accordance with the applicable policies and procedures relating to

expenditure decisions.

18.6 Allocation of CIL monies to particular infrastructure projects is not a matter for consideration in the

determination of planning applications. Separate governance arrangements are being put in place for

Borough Infrastructure needs.

18.7 The Mayoral CIL2 contribution is estimated, on the basis of the information provided with the

planning application, to be approximately £686,370.00.

19 CONCLUSION

19.1 The application would activate arches to provide much needed office space within the Waterloo

Opportunity Area and CAZ, including affordable workspace in line with emerging Local Plan policy.

The proposal would result in improved pedestrian access linkages within Waterloo. The proposal

would not result in significant amenity or transport impacts to surrounding sensitive properties or

road networks. Furthermore, the proposal accords with design, flooding, air quality, contamination

and sustainability matters.

19.2 The conditions and informatives recommended by officers are set out in the Draft Decision Notice

(Appendix 1). The proposed conditions are considered necessary to make the application acceptable

in planning terms.

19.3 Officers consider that the development would comply with the development plan for the Borough and

there are no material considerations of sufficient weight that would dictate that the application should

otherwise be refused. Officers are therefore recommending approval of the scheme, subject to

conditions in accordance with the presumption in favour of sustainable development conferred upon

local planning authorities by the NPPF.

20 EQUALITY DUTY AND HUMAN RIGHTS

20.1 In line with the Public Sector Equality Duty the council must have due regard to the need to eliminate

discrimination and advance equality of opportunity, as set out in section 149 of the Equality Act 2010.

In making this recommendation, regard has been given to the Public Sector Equality Duty and the

relevant protected characteristics (age, disability, gender reassignment, pregnancy and maternity,

race, religion or belief, sex, and sexual orientation).

20.2 In line with the Human Rights Act 1998, it is unlawful for a public authority to act in a way which is

incompatible with a Convention right, as per the European Convention on Human Rights. The human

rights impact have been considered, with particular reference to Article 1 of the First Protocol

(Protection of property), Article 8 (Right to respect for private and family life) and Article 14

(Prohibition of discrimination) of the Convention.

20.3 The Human Rights Act 1998 does not impair the right of the state to make decisions and enforce

laws as deemed necessary in the public interest. The recommendation is considered appropriate in

upholding the council's adopted and emerging policies and is not outweighed by any engaged rights.

21 RECOMMENDATION

21.1 Resolve to grant planning permission subject to the conditions as set out in the report and subject to

the completion of an agreement under Section 106 of the Town and Country Planning Act 1990 to

secure the planning obligations listed in this report.

21.2 Agree to delegate authority to the Director of Planning, Transport and Sustainability to:

a. Finalise the recommended conditions as set out in this report; and

b. Negotiate, agree and finalise the planning obligations as set out in this report pursuant to

Section 106 of the Town and Country Planning Act.

21.3 In the event that the committee resolves to refuse planning permission and there is a subsequent

appeal, delegated authority is given to the Director of Planning, Transport and Sustainability having

regard to the proposed planning obligations set out in the report, addendums and/or PAC minutes, to

negotiate and complete a document containing obligations pursuant to Section 106 of the Town and

Country Planning Act 1990 (as amended) in order to meet the requirement of the Planning Inspector.

21.4 In the event that the Section 106 Agreement is not completed within six months of committee,

delegated authority is given to the Director of Planning, Transport and Sustainability to refuse

planning permission for failure to enter into a section 106 agreement for the mitigating contributions

identified in this report, addendums and/or the PAC minutes.

APPENDICES

Appendix 1: Draft Decision Notice

Appendix 2: List of consultees (statutory and Other Consultees)

Conservation & Urban Design

Planning Policy

TFL Road Network Development (non-referable)

Transport Lambeth

Veolia Waste Lambeth Planning App

Ward Councillors

Regeneration Team Bishop Ward

Network Rail

Design Out Crime Officer

Building Control

Enterprise, Employment And Skills

Highway Team Lambeth

Parks & Open Spaces

Bioregional

Flooding - SUDS

Environment Agency

Historic England - Archaeology

London Ecology Unit

Development Control Department Thames Water

Sewers Major Development (20+) Thames Water

LBL Noise Pollution

South Bank And Waterloo Neighbours

L.F.C.D Authority

Association of Waterloo Groups

Lambeth Estates Residents Association

South Bank Employers Group

Waterloo Community Development Group

Kennington Association Planning Forum

Friends Of Hatfield Green

Friends Of Archbishop's Park

Kennington Oval & Vauxhall Forum

Kennington Park Road Residents' Association

We Are Waterloo

Sustainability Team On Air Quality

Friends Of Lambeth High Street Rec

Friends Of St John's Churchyard

Southbank & Waterloo Forum

Neighbourhood Regeneration Project Manager

Westminster Square Residents' Association

EHST Land Contamination

Cleaver Square, Cleaver Street , Bowden St

Friends Of Jubilee Gardens

List of Neighbours Consulted Flat 312 203 Westminster Bridge Road London SE1 7FR Flat 307 203 Westminster Bridge Road London SE1 7FR Flat 304 203 Westminster Bridge Road London SE1 7FR Flat 302 203 Westminster Bridge Road London SE1 7FR Residential Accommodation The Walrus Social 172 Westminster Bridge Road London SE1 7RW First Floor 142 Lower Marsh London SE1 7AE Build Studios 203 Westminster Bridge Road London SE1 7FR DLD College London 199 Westminster Bridge Road London SE1 7FX Flat 1614 203 Westminster Bridge Road London SE1 7FU Flat 1613 203 Westminster Bridge Road London SE1 7FU Flat 1519 203 Westminster Bridge Road London SE1 7FT Flat 1506 203 Westminster Bridge Road London SE1 7FT Flat 1411 203 Westminster Bridge Road London SE1 7FT Flat 1401 203 Westminster Bridge Road London SE1 7FT Flat 1315 203 Westminster Bridge Road London SE1 7FT Flat 1308 203 Westminster Bridge Road London SE1 7FT Flat 1304 203 Westminster Bridge Road London SE1 7FT Flat 1212 203 Westminster Bridge Road London SE1 7FT

Flat 1207 203 Westminster Bridge Road London SE1 7FT Flat 1115 203 Westminster Bridge Road London SE1 7FS Flat 1113 203 Westminster Bridge Road London SE1 7FS Flat 1016 203 Westminster Bridge Road London SE1 7FS Flat 1010 203 Westminster Bridge Road London SE1 7FS Flat 1006 203 Westminster Bridge Road London SE1 7FS Flat 922 203 Westminster Bridge Road London SE1 7FS Flat 920 203 Westminster Bridge Road London SE1 7FS Flat 914 203 Westminster Bridge Road London SE1 7FS Flat 908 203 Westminster Bridge Road London SE1 7FS Flat 902 203 Westminster Bridge Road London SE1 7FS Flat 817 203 Westminster Bridge Road London SE1 7FS Flat 814 203 Westminster Bridge Road London SE1 7FS Flat 813 203 Westminster Bridge Road London SE1 7FS Flat 802 203 Westminster Bridge Road London SE1 7FS Flat 702 203 Westminster Bridge Road London SE1 7FR Flat 1833 203 Westminster Bridge Road London SE1 7FU Flat 1829 203 Westminster Bridge Road London SE1 7FU Flat 1814 203 Westminster Bridge Road London SE1 7FU Flat 1812 203 Westminster Bridge Road London SE1 7FU Flat 1808 203 Westminster Bridge Road London SE1 7FU Flat 513 203 Westminster Bridge Road London SE1 7FR Flat 416 203 Westminster Bridge Road London SE1 7FR Flat 1720 203 Westminster Bridge Road London SE1 7FU Flat 1719 203 Westminster Bridge Road London SE1 7FU Flat 1716 203 Westminster Bridge Road London SE1 7FU Flat 1712 203 Westminster Bridge Road London SE1 7FU Flat 1708 203 Westminster Bridge Road London SE1 7FU Flat 1701 203 Westminster Bridge Road London SE1 7FU Flat 311 203 Westminster Bridge Road London SE1 7FR Flat 308 203 Westminster Bridge Road London SE1 7FR

Arches 216 To 218 Upper Marsh London SE1 7EL Flat 722 203 Westminster Bridge Road London SE1 7FR Flat 422 203 Westminster Bridge Road London SE1 7FR Flat 322 203 Westminster Bridge Road London SE1 7FR Flat 1611 203 Westminster Bridge Road London SE1 7FU Flat 1602 203 Westminster Bridge Road London SE1 7FU Flat 1510 203 Westminster Bridge Road London SE1 7FT Flat 1509 203 Westminster Bridge Road London SE1 7FT Flat 1504 203 Westminster Bridge Road London SE1 7FT Flat 1415 203 Westminster Bridge Road London SE1 7FT Flat 1413 203 Westminster Bridge Road London SE1 7FT Flat 1305 203 Westminster Bridge Road London SE1 7FT Flat 1219 203 Westminster Bridge Road London SE1 7FT Flat 1216 203 Westminster Bridge Road London SE1 7FT Flat 1215 203 Westminster Bridge Road London SE1 7FT Flat 1204 203 Westminster Bridge Road London SE1 7FT Flat 1102 203 Westminster Bridge Road London SE1 7FS Flat 1019 203 Westminster Bridge Road London SE1 7FS Flat 1009 203 Westminster Bridge Road London SE1 7FS Flat 1002 203 Westminster Bridge Road London SE1 7FS Flat 903 203 Westminster Bridge Road London SE1 7FS Flat 815 203 Westminster Bridge Road London SE1 7FS Flat 812 203 Westminster Bridge Road London SE1 7FS Flat 810 203 Westminster Bridge Road London SE1 7FS Flat 801 203 Westminster Bridge Road London SE1 7FS Flat 717 203 Westminster Bridge Road London SE1 7FR Flat 709 203 Westminster Bridge Road London SE1 7FR Flat 708 203 Westminster Bridge Road London SE1 7FR Flat 614 203 Westminster Bridge Road London SE1 7FR Flat 1820 203 Westminster Bridge Road London SE1 7FU Flat 1815 203 Westminster Bridge Road London SE1 7FU

Flat 1811 203 Westminster Bridge Road London SE1 7FU Flat 1809 203 Westminster Bridge Road London SE1 7FU Flat 512 203 Westminster Bridge Road London SE1 7FR Flat 415 203 Westminster Bridge Road London SE1 7FR Flat 413 203 Westminster Bridge Road London SE1 7FR Flat 409 203 Westminster Bridge Road London SE1 7FR Flat 408 203 Westminster Bridge Road London SE1 7FR Flat 1803 203 Westminster Bridge Road London SE1 7FU Flat 1705 203 Westminster Bridge Road London SE1 7FU Flat 1702 203 Westminster Bridge Road London SE1 7FU Flat 1621 203 Westminster Bridge Road London SE1 7FU Flat 1620 203 Westminster Bridge Road London SE1 7FU Flat 1618 203 Westminster Bridge Road London SE1 7FU Flat 317 203 Westminster Bridge Road London SE1 7FR Flat 316 203 Westminster Bridge Road London SE1 7FR Flat 310 203 Westminster Bridge Road London SE1 7FR 1 Carlisle Lane London SE1 7LH 141 Westminster Bridge Road London SE1 7HR Tenth Floor Becket House 1 Lambeth Palace Road London SE1 7EU Sixth - Eighth Floors Becket House 1 Lambeth Palace Road London SE1 7EU Eleventh Floor Becket House 1 Lambeth Palace Road London SE1 7EU Flat 1615 203 Westminster Bridge Road London SE1 7FU Flat 1606 203 Westminster Bridge Road London SE1 7FU Flat 1603 203 Westminster Bridge Road London SE1 7FU Flat 1517 203 Westminster Bridge Road London SE1 7FT Flat 1514 203 Westminster Bridge Road London SE1 7FT Flat 1416 203 Westminster Bridge Road London SE1 7FT Flat 1414 203 Westminster Bridge Road London SE1 7FT Flat 1409 203 Westminster Bridge Road London SE1 7FT Flat 1408 203 Westminster Bridge Road London SE1 7FT Flat 1402 203 Westminster Bridge Road London SE1 7FT

Flat 1319 203 Westminster Bridge Road London SE1 7FT Flat 1314 203 Westminster Bridge Road London SE1 7FT Flat 1210 203 Westminster Bridge Road London SE1 7FT Flat 1202 203 Westminster Bridge Road London SE1 7FT Flat 1121 203 Westminster Bridge Road London SE1 7FS Flat 1112 203 Westminster Bridge Road London SE1 7FS Flat 1022 203 Westminster Bridge Road London SE1 7FS Flat 1017 203 Westminster Bridge Road London SE1 7FS Flat 1014 203 Westminster Bridge Road London SE1 7FS Flat 1007 203 Westminster Bridge Road London SE1 7FS Flat 1005 203 Westminster Bridge Road London SE1 7FS Flat 1004 203 Westminster Bridge Road London SE1 7FS Flat 918 203 Westminster Bridge Road London SE1 7FS Flat 912 203 Westminster Bridge Road London SE1 7FS Flat 909 203 Westminster Bridge Road London SE1 7FS Flat 811 203 Westminster Bridge Road London SE1 7FS Flat 809 203 Westminster Bridge Road London SE1 7FS Flat 705 203 Westminster Bridge Road London SE1 7FR Flat 615 203 Westminster Bridge Road London SE1 7FR Flat 1832 203 Westminster Bridge Road London SE1 7FU Flat 1830 203 Westminster Bridge Road London SE1 7FU Flat 1817 203 Westminster Bridge Road London SE1 7FU Flat 1816 203 Westminster Bridge Road London SE1 7FU Flat 516 203 Westminster Bridge Road London SE1 7FR Flat 508 203 Westminster Bridge Road London SE1 7FR Flat 503 203 Westminster Bridge Road London SE1 7FR Flat 1804 203 Westminster Bridge Road London SE1 7FU Flat 1709 203 Westminster Bridge Road London SE1 7FU Flat 1616 203 Westminster Bridge Road London SE1 7FU Flat 318 203 Westminster Bridge Road London SE1 7FR Flat 315 203 Westminster Bridge Road London SE1 7FR

Flat 309 203 Westminster Bridge Road London SE1 7FR Flat 305 203 Westminster Bridge Road London SE1 7FR Arches 219 To 220 Upper Marsh London SE1 7EL 141 Lower Marsh London SE1 7AE Second Floor Becket House 1 Lambeth Palace Road London SE1 7EU Fifth Floor Becket House 1 Lambeth Palace Road London SE1 7EU Third Floor Becket House 1 Lambeth Palace Road London SE1 7EU Flat 1607 203 Westminster Bridge Road London SE1 7FU Flat 1513 203 Westminster Bridge Road London SE1 7FT Flat 1511 203 Westminster Bridge Road London SE1 7FT Flat 1503 203 Westminster Bridge Road London SE1 7FT Flat 1420 203 Westminster Bridge Road London SE1 7FT Flat 1419 203 Westminster Bridge Road London SE1 7FT Flat 1405 203 Westminster Bridge Road London SE1 7FT Flat 1403 203 Westminster Bridge Road London SE1 7FT Flat 1316 203 Westminster Bridge Road London SE1 7FT Flat 1310 203 Westminster Bridge Road London SE1 7FT Flat 1221 203 Westminster Bridge Road London SE1 7FT Flat 1220 203 Westminster Bridge Road London SE1 7FT Flat 1211 203 Westminster Bridge Road London SE1 7FT Flat 1208 203 Westminster Bridge Road London SE1 7FT Flat 1205 203 Westminster Bridge Road London SE1 7FT Flat 1203 203 Westminster Bridge Road London SE1 7FT Flat 1118 203 Westminster Bridge Road London SE1 7FS Flat 1110 203 Westminster Bridge Road London SE1 7FS Flat 1103 203 Westminster Bridge Road London SE1 7FS Flat 1101 203 Westminster Bridge Road London SE1 7FS Flat 1020 203 Westminster Bridge Road London SE1 7FS Flat 917 203 Westminster Bridge Road London SE1 7FS Flat 906 203 Westminster Bridge Road London SE1 7FS Flat 808 203 Westminster Bridge Road London SE1 7FS

Flat 806 203 Westminster Bridge Road London SE1 7FS Flat 803 203 Westminster Bridge Road London SE1 7FS Flat 716 203 Westminster Bridge Road London SE1 7FR Flat 704 203 Westminster Bridge Road London SE1 7FR Flat 611 203 Westminster Bridge Road London SE1 7FR Flat 609 203 Westminster Bridge Road London SE1 7FR Flat 1810 203 Westminster Bridge Road London SE1 7FU Flat 606 203 Westminster Bridge Road London SE1 7FR Flat 514 203 Westminster Bridge Road London SE1 7FR Flat 410 203 Westminster Bridge Road London SE1 7FR Flat 1715 203 Westminster Bridge Road London SE1 7FU Flat 306 203 Westminster Bridge Road London SE1 7FR The Walrus Social 172 Westminster Bridge Road London SE1 7RW Arches 222A B And C Upper Marsh London SE1 7EL Flat 1608 203 Westminster Bridge Road London SE1 7FU Flat 1515 203 Westminster Bridge Road London SE1 7FT Flat 1507 203 Westminster Bridge Road London SE1 7FT Flat 1421 203 Westminster Bridge Road London SE1 7FT Flat 1417 203 Westminster Bridge Road London SE1 7FT Flat 1412 203 Westminster Bridge Road London SE1 7FT Flat 1313 203 Westminster Bridge Road London SE1 7FT Flat 1312 203 Westminster Bridge Road London SE1 7FT Flat 1218 203 Westminster Bridge Road London SE1 7FT Flat 1116 203 Westminster Bridge Road London SE1 7FS Flat 1107 203 Westminster Bridge Road London SE1 7FS Flat 1106 203 Westminster Bridge Road London SE1 7FS Flat 1011 203 Westminster Bridge Road London SE1 7FS Flat 1003 203 Westminster Bridge Road London SE1 7FS Flat 1001 203 Westminster Bridge Road London SE1 7FS Flat 916 203 Westminster Bridge Road London SE1 7FS Flat 915 203 Westminster Bridge Road London SE1 7FS

Flat 905 203 Westminster Bridge Road London SE1 7FS Flat 904 203 Westminster Bridge Road London SE1 7FS Flat 901 203 Westminster Bridge Road London SE1 7FS Flat 807 203 Westminster Bridge Road London SE1 7FS Flat 715 203 Westminster Bridge Road London SE1 7FR Flat 713 203 Westminster Bridge Road London SE1 7FR Flat 711 203 Westminster Bridge Road London SE1 7FR Flat 706 203 Westminster Bridge Road London SE1 7FR Flat 701 203 Westminster Bridge Road London SE1 7FR Flat 1828 203 Westminster Bridge Road London SE1 7FU Flat 1825 203 Westminster Bridge Road London SE1 7FU Flat 1823 203 Westminster Bridge Road London SE1 7FU Flat 1819 203 Westminster Bridge Road London SE1 7FU Flat 1818 203 Westminster Bridge Road London SE1 7FU Flat 604 203 Westminster Bridge Road London SE1 7FR Flat 515 203 Westminster Bridge Road London SE1 7FR Flat 509 203 Westminster Bridge Road London SE1 7FR Flat 506 203 Westminster Bridge Road London SE1 7FR Flat 501 203 Westminster Bridge Road London SE1 7FR Flat 417 203 Westminster Bridge Road London SE1 7FR Flat 1801 203 Westminster Bridge Road London SE1 7FU Flat 1721 203 Westminster Bridge Road London SE1 7FU Flat 1718 203 Westminster Bridge Road London SE1 7FU Flat 1714 203 Westminster Bridge Road London SE1 7FU Flat 1711 203 Westminster Bridge Road London SE1 7FU Flat 1710 203 Westminster Bridge Road London SE1 7FU Flat 1707 203 Westminster Bridge Road London SE1 7FU Flat 1704 203 Westminster Bridge Road London SE1 7FU Flat 1703 203 Westminster Bridge Road London SE1 7FU Flat 1619 203 Westminster Bridge Road London SE1 7FU Flat 1617 203 Westminster Bridge Road London SE1 7FU

Flat 314 203 Westminster Bridge Road London SE1 7FR Flat 303 203 Westminster Bridge Road London SE1 7FR Third Floor 142 Lower Marsh London SE1 7AE Arches 206 To 207 Carlisle Lane London SE1 7LH Arch 205 Carlisle Lane London SE1 7LH Ground Floor Becket House 1 Lambeth Palace Road London SE1 7EU Flat 1612 203 Westminster Bridge Road London SE1 7FU Flat 1610 203 Westminster Bridge Road London SE1 7FU Flat 1604 203 Westminster Bridge Road London SE1 7FU Flat 1520 203 Westminster Bridge Road London SE1 7FT Flat 1518 203 Westminster Bridge Road London SE1 7FT Flat 1508 203 Westminster Bridge Road London SE1 7FT Flat 1501 203 Westminster Bridge Road London SE1 7FT Flat 1407 203 Westminster Bridge Road London SE1 7FT Flat 1311 203 Westminster Bridge Road London SE1 7FT Flat 1306 203 Westminster Bridge Road London SE1 7FT Flat 1302 203 Westminster Bridge Road London SE1 7FT Flat 1301 203 Westminster Bridge Road London SE1 7FT Flat 1214 203 Westminster Bridge Road London SE1 7FT Flat 1213 203 Westminster Bridge Road London SE1 7FT Flat 1119 203 Westminster Bridge Road London SE1 7FS Flat 1105 203 Westminster Bridge Road London SE1 7FS Flat 1013 203 Westminster Bridge Road London SE1 7FS Flat 1012 203 Westminster Bridge Road London SE1 7FS Flat 921 203 Westminster Bridge Road London SE1 7FS Flat 910 203 Westminster Bridge Road London SE1 7FS Flat 714 203 Westminster Bridge Road London SE1 7FR Flat 703 203 Westminster Bridge Road London SE1 7FR Flat 613 203 Westminster Bridge Road London SE1 7FR Flat 610 203 Westminster Bridge Road London SE1 7FR Flat 607 203 Westminster Bridge Road London SE1 7FR

Flat 1827 203 Westminster Bridge Road London SE1 7FU Flat 1824 203 Westminster Bridge Road London SE1 7FU Flat 605 203 Westminster Bridge Road London SE1 7FR Flat 603 203 Westminster Bridge Road London SE1 7FR Flat 511 203 Westminster Bridge Road London SE1 7FR Flat 507 203 Westminster Bridge Road London SE1 7FR Flat 505 203 Westminster Bridge Road London SE1 7FR Flat 504 203 Westminster Bridge Road London SE1 7FR Flat 502 203 Westminster Bridge Road London SE1 7FR Flat 414 203 Westminster Bridge Road London SE1 7FR Flat 407 203 Westminster Bridge Road London SE1 7FR Flat 1717 203 Westminster Bridge Road London SE1 7FU Flat 1706 203 Westminster Bridge Road London SE1 7FU Flat 405 203 Westminster Bridge Road London SE1 7FR Flat 403 203 Westminster Bridge Road London SE1 7FR Flat 313 203 Westminster Bridge Road London SE1 7FR Ninth Floor Becket House 1 Lambeth Palace Road London SE1 7EU First Floor Becket House 1 Lambeth Palace Road London SE1 7EU Flat 1422 203 Westminster Bridge Road London SE1 7FT Flat 1609 203 Westminster Bridge Road London SE1 7FU Flat 1605 203 Westminster Bridge Road London SE1 7FU Flat 1521 203 Westminster Bridge Road London SE1 7FT Flat 1516 203 Westminster Bridge Road London SE1 7FT Flat 1512 203 Westminster Bridge Road London SE1 7FT Flat 1321 203 Westminster Bridge Road London SE1 7FT Flat 1317 203 Westminster Bridge Road London SE1 7FT Flat 1309 203 Westminster Bridge Road London SE1 7FT Flat 1307 203 Westminster Bridge Road London SE1 7FT Flat 1217 203 Westminster Bridge Road London SE1 7FT Flat 1209 203 Westminster Bridge Road London SE1 7FT Flat 1206 203 Westminster Bridge Road London SE1 7FT

Flat 1109 203 Westminster Bridge Road London SE1 7FS Flat 1108 203 Westminster Bridge Road London SE1 7FS Flat 1018 203 Westminster Bridge Road London SE1 7FS Flat 1015 203 Westminster Bridge Road London SE1 7FS Flat 1008 203 Westminster Bridge Road London SE1 7FS Flat 919 203 Westminster Bridge Road London SE1 7FS Flat 913 203 Westminster Bridge Road London SE1 7FS Flat 805 203 Westminster Bridge Road London SE1 7FS Flat 804 203 Westminster Bridge Road London SE1 7FS Flat 712 203 Westminster Bridge Road London SE1 7FR Flat 616 203 Westminster Bridge Road London SE1 7FR Flat 608 203 Westminster Bridge Road London SE1 7FR Flat 1826 203 Westminster Bridge Road London SE1 7FU Flat 1821 203 Westminster Bridge Road London SE1 7FU Flat 1813 203 Westminster Bridge Road London SE1 7FU Flat 1807 203 Westminster Bridge Road London SE1 7FU Flat 602 203 Westminster Bridge Road London SE1 7FR Flat 510 203 Westminster Bridge Road London SE1 7FR Flat 418 203 Westminster Bridge Road London SE1 7FR Flat 412 203 Westminster Bridge Road London SE1 7FR Flat 406 203 Westminster Bridge Road London SE1 7FR Flat 1713 203 Westminster Bridge Road London SE1 7FU Flat 404 203 Westminster Bridge Road London SE1 7FR Flat 402 203 Westminster Bridge Road London SE1 7FR Flat 401 203 Westminster Bridge Road London SE1 7FR Flat 301 203 Westminster Bridge Road London SE1 7FR Second Floor 142 Lower Marsh London SE1 7AE 31 Stangate Royal Street London SE1 7EQ 53 Canterbury House Royal Street London SE1 7LW 24 Stangate Royal Street London SE1 7EQ 52 Canterbury House Royal Street London SE1 7LW

44 Stangate Royal Street London SE1 7EQ 16 Stangate Royal Street London SE1 7EQ 42 Stangate Royal Street London SE1 7EQ 72 Canterbury House Royal Street London SE1 7LW 23 Canterbury House Royal Street London SE1 7LN 56 Canterbury House Royal Street London SE1 7LW 47 Canterbury House Royal Street London SE1 7LW 58 Canterbury House Royal Street London SE1 7LW 57 Canterbury House Royal Street London SE1 7LW 14 Canterbury House Royal Street London SE1 7LN 20 Stangate Royal Street London SE1 7EQ 69 Canterbury House Royal Street London SE1 7LW 67 Canterbury House Royal Street London SE1 7LW 54 Canterbury House Royal Street London SE1 7LW 48 Stangate Royal Street London SE1 7EQ 46 Stangate Royal Street London SE1 7EQ 36 Canterbury House Royal Street London SE1 7LN 29 Stangate Royal Street London SE1 7EQ 50 Canterbury House Royal Street London SE1 7LW Day Nursery Canterbury House Royal Street London SE1 7LN 11 Stangate Royal Street London SE1 7EQ 22 Canterbury House Royal Street London SE1 7LN 1 Stangate Royal Street London SE1 7EQ 40 Canterbury House Royal Street London SE1 7LN 71 Canterbury House Royal Street London SE1 7LW 22 Stangate Royal Street London SE1 7EQ 52 Stangate Royal Street London SE1 7EQ 8 Stangate Royal Street London SE1 7EQ 6 Stangate Royal Street London SE1 7EQ 5 Stangate Royal Street London SE1 7EQ 49 Canterbury House Royal Street London SE1 7LW

38 Stangate Royal Street London SE1 7EQ 34 Canterbury House Royal Street London SE1 7LN 66 Canterbury House Royal Street London SE1 7LW 35 Canterbury House Royal Street London SE1 7LN 12 Canterbury House Royal Street London SE1 7LN 21 Canterbury House Royal Street London SE1 7LN 45 Stangate Royal Street London SE1 7EQ 4 Canterbury House Royal Street London SE1 7LN 37 Stangate Royal Street London SE1 7EQ 18 Stangate Royal Street London SE1 7EQ 73 Canterbury House Royal Street London SE1 7LW 65 Canterbury House Royal Street London SE1 7LW 47 Stangate Royal Street London SE1 7EQ 8 Canterbury House Royal Street London SE1 7LN 9 Stangate Royal Street London SE1 7EQ 41 Canterbury House Royal Street London SE1 7LW 11 Canterbury House Royal Street London SE1 7LN 5 Canterbury House Royal Street London SE1 7LN 38 Canterbury House Royal Street London SE1 7LN 13 Canterbury House Royal Street London SE1 7LN 33 Stangate Royal Street London SE1 7EQ 6 Canterbury House Royal Street London SE1 7LN 24 Canterbury House Royal Street London SE1 7LN 32 Stangate Royal Street London SE1 7EQ 51 Stangate Royal Street London SE1 7EQ 41 Stangate Royal Street London SE1 7EQ 35 Stangate Royal Street London SE1 7EQ 43 Stangate Royal Street London SE1 7EQ 17 Stangate Royal Street London SE1 7EQ 12 Stangate Royal Street London SE1 7EQ 63 Canterbury House Royal Street London SE1 7LW

60 Canterbury House Royal Street London SE1 7LW 29 Canterbury House Royal Street London SE1 7LN 18 Canterbury House Royal Street London SE1 7LN 16 Canterbury House Royal Street London SE1 7LN 28 Stangate Royal Street London SE1 7EQ 2 Stangate Royal Street London SE1 7EQ 25 Canterbury House Royal Street London SE1 7LN 30 Stangate Royal Street London SE1 7EQ 4 Stangate Royal Street London SE1 7EQ 1 Royal Street London SE1 7LL 34 Stangate Royal Street London SE1 7EQ 10 Stangate Royal Street London SE1 7EQ 21 Stangate Royal Street London SE1 7EQ 76 Canterbury House Royal Street London SE1 7LW 74 Canterbury House Royal Street London SE1 7LW 2 Canterbury House Royal Street London SE1 7LN 9 Canterbury House Royal Street London SE1 7LN 7 Canterbury House Royal Street London SE1 7LN 45 Canterbury House Royal Street London SE1 7LW 19 Canterbury House Royal Street London SE1 7LN 15 Canterbury House Royal Street London SE1 7LN 36 Stangate Royal Street London SE1 7EQ 3 Stangate Royal Street London SE1 7EQ 46 Canterbury House Royal Street London SE1 7LW 48 Canterbury House Royal Street London SE1 7LW 27 Stangate Royal Street London SE1 7EQ 13 Stangate Royal Street London SE1 7EQ 23 Stangate Royal Street London SE1 7EQ 43 Canterbury House Royal Street London SE1 7LW 51 Canterbury House Royal Street London SE1 7LW 10 Canterbury House Royal Street London SE1 7LN

42 Canterbury House Royal Street London SE1 7LW 20 Canterbury House Royal Street London SE1 7LN 40 Stangate Royal Street London SE1 7EQ 14 Stangate Royal Street London SE1 7EQ 1 Canterbury House Royal Street London SE1 7LN 68 Canterbury House Royal Street London SE1 7LW 39 Canterbury House Royal Street London SE1 7LN 19 Stangate Royal Street London SE1 7EQ 33 Canterbury House Royal Street London SE1 7LN 44 Canterbury House Royal Street London SE1 7LW 62 Canterbury House Royal Street London SE1 7LW 15 Stangate Royal Street London SE1 7EQ 50 Stangate Royal Street London SE1 7EQ 7 Stangate Royal Street London SE1 7EQ 39 Stangate Royal Street London SE1 7EQ 27 Canterbury House Royal Street London SE1 7LN 17 Canterbury House Royal Street London SE1 7LN 28 Canterbury House Royal Street London SE1 7LN 32 Canterbury House Royal Street London SE1 7LN 49 Stangate Royal Street London SE1 7EQ 3 Canterbury House Royal Street London SE1 7LN 61 Canterbury House Royal Street London SE1 7LW 55 Canterbury House Royal Street London SE1 7LW 25 Stangate Royal Street London SE1 7EQ 77 Canterbury House Royal Street London SE1 7LW 59 Canterbury House Royal Street London SE1 7LW 75 Canterbury House Royal Street London SE1 7LW 37 Canterbury House Royal Street London SE1 7LN 26 Stangate Royal Street London SE1 7EQ 26 Canterbury House Royal Street London SE1 7LN 70 Canterbury House Royal Street London SE1 7LW

64 Canterbury House Royal Street London SE1 7LW 31 Canterbury House Royal Street London SE1 7LN 30 Canterbury House Royal Street London SE1 7LN Fourth Floor Becket House 1 Lambeth Palace Road London SE1 7EU Flat 1601 203 Westminster Bridge Road London SE1 7FU Flat 1505 203 Westminster Bridge Road London SE1 7FT Flat 1502 203 Westminster Bridge Road London SE1 7FT Flat 1418 203 Westminster Bridge Road London SE1 7FT Flat 1410 203 Westminster Bridge Road London SE1 7FT Flat 1406 203 Westminster Bridge Road London SE1 7FT Flat 1404 203 Westminster Bridge Road London SE1 7FT Flat 1320 203 Westminster Bridge Road London SE1 7FT Flat 1318 203 Westminster Bridge Road London SE1 7FT Flat 1303 203 Westminster Bridge Road London SE1 7FT Flat 1201 203 Westminster Bridge Road London SE1 7FT Flat 1120 203 Westminster Bridge Road London SE1 7FS Flat 1117 203 Westminster Bridge Road London SE1 7FS Flat 1114 203 Westminster Bridge Road London SE1 7FS Flat 1111 203 Westminster Bridge Road London SE1 7FS Flat 1104 203 Westminster Bridge Road London SE1 7FS Flat 1021 203 Westminster Bridge Road London SE1 7FS Flat 911 203 Westminster Bridge Road London SE1 7FS Flat 907 203 Westminster Bridge Road London SE1 7FS Flat 816 203 Westminster Bridge Road London SE1 7FS Flat 710 203 Westminster Bridge Road London SE1 7FR Flat 707 203 Westminster Bridge Road London SE1 7FR Flat 617 203 Westminster Bridge Road London SE1 7FR Flat 612 203 Westminster Bridge Road London SE1 7FR Flat 1834 203 Westminster Bridge Road London SE1 7FU Flat 1831 203 Westminster Bridge Road London SE1 7FU Flat 1822 203 Westminster Bridge Road London SE1 7FU

Flat 1806 203 Westminster Bridge Road London SE1 7FU Flat 601 203 Westminster Bridge Road London SE1 7FR Flat 411 203 Westminster Bridge Road London SE1 7FR Flat 1805 203 Westminster Bridge Road London SE1 7FU Flat 1802 203 Westminster Bridge Road London SE1 7FU Arches 228 To 232 Waterloo Station Approach London SE1 7LY

Appendix 3: List of relevant policies in London Plan, Lambeth Local Plan. Reference to SPGs, SPD

and other relevant guidance

NPPF 2019

Lambeth Local Plan (2015) policies:

D1 Delivery and monitoring

D2 Presumption in favour of sustainable development

D3 Infrastructure

D4 Planning obligations

D5 Enforcement

H1 Maximising housing growth

H2 Delivering affordable housing

H3 Safeguarding existing housing

H4 Housing mix in new developments

H5 Housing standards

H6 Residential conversions

H7 Student housing

H8 Housing to meet specific community needs

H9 Hostels and houses in multiple occupation

H10 Gypsy and traveller needs

ED1 Key Industrial and Business Areas (KIBAs)

ED2 Business, industrial and storage uses outside KIBAs

ED3 Large offices (greater than 1,000 m2)

ED4 Work-live development

ED5 Railway arches

ED6 Town centres

ED8 Public houses

ED9 A2 uses

ED10 Local centres and dispersed local shops

ED11 Visitor attractions, leisure, arts and culture uses

ED12 Hotels and other visitor accommodation

ED13 Markets

ED14 Employment and training

S1 Safeguarding existing community premises

S2 New or improved community premises

S3 Schools

T1 Sustainable travel

T2 Walking

T3 Cycling

T4 Public transport infrastructure

T5 River transport

T6 Assessing impacts of development on transport capacity

T7 Parking

T8 Servicing

T9 Minicabs, taxis and private hire vehicles

T10 Telecommunications

EN1 Open space and biodiversity

EN2 Local food growing and production

EN3 Decentralised energy

EN4 Sustainable design and construction

EN5 Flood risk 106

EN6 Sustainable drainage systems and water management

EN7 Sustainable waste management

Q1 Inclusive environments

Q2 Amenity

Q3 Community safety

Q4 Public art

Q5 Local distinctiveness

Q6 Urban design: public realm

Q7 Urban design: new development

Q8 Design quality: construction detailing

Q9 Landscaping

Q10 Trees

Q11 Building alterations and extensions

Q12 Refuse/recycling storage

Q13 Cycle storage

Q14 Development in gardens and on backland sites

Q15 Boundary treatments

Q16 Shop fronts

Q17 Advertisements and signage

Q18 Historic environment strategy

Q19 Westminster World Heritage Site

Q20 Statutory listed buildings

Q21 Registered parks and gardens

Q22 Conservation areas

Q23 Undesignated heritage assets: local heritage list

Q24 River Thames

Q25 Views

PN1 Waterloo

Draft Revised Lambeth Local Plan (2018) policies:

Policy D1 Delivery and monitoring

Policy D2 Presumption in favour of sustainable development

Policy D4 Planning Obligations

Policy ED1 Offices (B1a)

Policy ED2 Affordable Workspace

Policy ED6 Railway Arches

Policy ED7 Town centres

Policy ED15 Employment and training

Policy T1 Sustainable travel

Policy T3 Cycling

Policy T7 Parking

Policy T8 Servicing

Policy T10 Digital connectivity infrastructure

Policy EN3 Decentralised energy

Policy EN4 Sustainable design and construction

Policy EN5 Flood risk

Policy EN6 Sustainable drainage systems and water management

Policy EN7 Sustainable waste management

Policy Q1 Inclusive environments

Policy Q2 Amenity

Policy Q3 Safety, crime prevention and counter terrorism

Policy Q4 Public Art

Policy Q5 Local distinctiveness

Policy Q6 Urban design: public realm

Policy Q7 Urban design: new development

Policy Q9 Landscaping

Policy Q12 Refuse/recycling storage

Policy Q13 Cycle storage

Policy Q15 Boundary Treatments

Policy Q17 Advertisements and signage

Policy Q22 Conservation Areas

Policy Q3 Non-designated heritage assets: local heritage list

Policy Q25 Local views

Policy PN1 Waterloo and South Bank

South Bank and Waterloo Neighbourhood Plan (2019) policies:

Policy P2 – Publically accessible open space

Policy P4 – Amenity in public space

Policy P5 – Air Quality

Policy P12 – Office or workspace schemes

London Plan (2016)

Policy 1.1 Delivering the strategic vision and objectives for London

Policy 2.10 Central Activities Zone – Strategic priorities

Policy 2.11 Central Activities Zone – Strategic functions

Policy 2.12 Central Activities Zone – predominately local activities

Policy 2.13 Opportunity Areas and Intensification Areas

Policy 2.15 Town Centres

Policy 4.2 Offices

Policy 4.3 Mixed use development and offices

Policy 5.1 Climate change mitigation

Policy 5.2 Minimising carbon dioxide emissions

Policy 5.3 Sustainable design and construction

Policy 5.5 Decentralised energy networks

Policy 5.6 Decentralised energy in development proposals

Policy 5.9 Overheating and cooling

Policy 5.12 Flood risk management

Policy 5.13 Sustainable drainage

Policy 5.14 Water quality and wastewater infrastructure

Policy 5.15 Water use and supplies

Policy 5.21 Contaminated land

Policy 6.3 Assessing effects of development on transport capacity

Policy 6.9 Cycling

Policy 6.10 Walking

Policy 6.13 Parking

Policy 7.2 An inclusive environment

Policy 7.3 Designing out crime

Policy 7.4 Local character

Policy 7.5 Public realm

Policy 7.6 Architecture

Policy 7.8 Heritage assets and archaeology

Policy 7.11 London View Management Framework

Policy 7.14 Improving air quality

Policy 7.15 Reducing and managing noise, improving and enhancing the acoustic environment and

promoting appropriate soundscapes

Draft New London Plan (2017)

Policy SD1 Opportunity Areas

Policy SD4 The Central Activities Zone

Policy SD5 Offices, other strategic functions and residential development in the CAZ

Policy SD6 Town centres

Policy D2 Delivering good design

Policy D3 Inclusive design

Policy D7 Public Realm

Policy D13 Noise

Policy E1 Offices

Policy E2 Low-cost business space

Policy E3 Affordable Workspace

Policy HC1 Heritage conservation and growth

Policy HC4 London View Management Framework

Policy HC5 Supporting London’s culture and creative industries

Policy G1 Green Infrastructure

Policy SI1 Improving air quality

Policy SI2 Minimising greenhouse gas emissions

Policy SI3 Energy Infrastructure

Policy SI6 Digital connectivity infrastructure

Policy SI7 Reducing Waste and supporting the circular economy

Policy SI8 Waste capacity and net waste self-sufficiency

Policy SI12 Flood Risk management

Policy SI13 Sustainable drainage

Policy T1 Strategic approach to transport

Policy T4 Assessing and mitigating transport impacts

Policy T5 Cycling

Policy T6 Car parking

Policy T6.2 Office parking

Policy T6.5 Non-residential disabled persons parking

Policy T7 Freight and servicing

Supplementary Planning Documents (SPDs) & Other Relevant Documents:

Lambeth

Waterloo SPD

Advertising & Signage Guidance

Refuse & Recycling Storage Design Guide

Waste Storage and Collection Requirements - Technical Specification

Air Quality Planning Guidance Notes

Lambeth Employment and Skills SPD (2018)

Draft Supplementary Planning Document: Affordable Workspace (Feb 2020)

London Plan Supplementary Planning Guidance (SPG)

Central Activities Zone (March 2016)

Social Infrastructure (May 2015)

Accessible London: Achieving an Inclusive Environment (October 2014)

The control of dust and emissions during construction and demolition (July 2014)

Town Centres (July 2014)

Character and Context (June 2014)

Sustainable Design and Construction (April 2014)

London View Management Framework (March 2012)

Waterloo Opportunity Area Planning Framework (2007)

Appendix 4: Other relevant Plans and Photos

Existing Site Plan

Existing GF Plan

Existing Roof Plan

Existing West Elevation

Existing North Elevation

Existing Sections

Proposed Site Location Plan

Proposed Site Plan

Proposed Roof Plan

Proposed West Elevation

Proposed North Elevation

Proposed Sections

Area Schedule