Hammersmith Town Hall Extension report PDF - Greater London ...

planning report PDU/1011/01
22 December 2010
Hammersmith Town Hall, King Street
in the London Borough of Hammersmith & Fulham
planning application no.10/03465/FUL
Strategic planning application stage 1 referral (new powers)
Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and
2007; Town & Country Planning (Mayor of London) Order 2008.
The proposal
Redevelopment to provide a new civic square (3,470 sq.m.), civic offices (10,863 sq.m. GIA), 320
residential units, new food store (2,680 sq.m. GIA), five retail units (total 895 sq.m. GIA) and a
new bridge link across the A4 to Furnival Gardens. The proposals include 100 car parking spaces
for the residential component of the scheme, plus 322 cycle parking spaces. The food store will
include 120 car parking spaces and 50 cycle parking spaces.
The applicant
The applicant is King Street Developments (Hammersmith) LTD and the architect is
Sheppard Robson.
Strategic issues
The principle of the town hall regeneration is supported. There are a number of strategic issues
that require further discussion including the scale and impact of the proposals on river
views, the listed building and the conservation area. Other matters include the affordable
housing offer, loss of affordable housing and the strategy for re-housing for existing
residents. Climate change and transport are also relevant.
Recommendation
That Hammersmith & Fulham Council be advised that the application does not comply with the
London Plan, for the reasons set out in paragraph 98 of this report; but that the possible
remedies set out in paragraph 100 of this report could address these deficiencies.
Context
1 On 18 November 2010, the Mayor of London received documents from Hammersmith &
Fulham Council notifying him of a planning application of potential strategic importance to develop
the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor
of London) Order 2008 the Mayor has until 29 December 2010, to provide the Council with a
statement setting out whether he considers that the application complies with the London Plan,
and his reasons for taking that view. The Mayor may also provide other comments. This report
sets out information for the Mayor’s use in deciding what decision to make.
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2 The application is referable under Category 1A, 1B(c) and 1C1(c) of the Schedule to the
Order 2008:
1A: “Development which comprises or includes the provision of more than 150 houses, flats, or
houses and flats.”
1B (c): “Development (other than development which only comprises the provision of houses,
flats, or houses and flats) which comprises or includes the erection of a building or buildings
Outside Central London and with a total floorspace of more than 15,000 square metres.”
1C.1(c): “Development which comprises or includes the erection of a building of one or more of
the following descriptions— the building is more than 30 metres high and is outside the City of
London.”
3 Once Hammersmith & Fulham Council has resolved to determine the application, it is
required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over
for his own determination; or allow the Council to determine it itself.
4 The environmental information for the purposes of the Town and Country Planning
(Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken into
account in the consideration of this case.
5 The Mayor of London’s statement on this case will be made available on the GLA website
www.london.gov.uk.
Site description
6 The site is 2.04 hectares and includes the existing Town Hall Extension, properties on King
Street, The Friends Meeting House and Registrar Office, Thomas Pocklington Trust Buildings on
Cromwell Avenue and King Street (Cromwell Mansions) and the existing Cineworld Cinema. Land
in Furnival Gardens, located south of the A4, is also part of the application. The vast majority of
the site is within the Hammersmith town centre. The original town hall, which is not part of the
application, but is an integral element of the regeneration strategy, is a grade II listed building, and
is within the King Street (east) Conservation Area. Furnival Gardens is within the Mall
Conservation Area.
7 The eastern element of the site, with the cinema and Cromwell Avenue lies outside the
conservation area. Other relevant listed buildings include Sussex House, listed grade II*
(residential property adjacent to Furnival Gardens), and the Salutation Inn on King Street, listed as
grade II. The cinema is identified locally as a building of merit. The surrounding environment is
fairly low-grade retail uses as part of the fringe of town centres uses. The built form ranges in
scale from 3, 4, 5 and 7 storey.
8 King Street (A315), forms part of the Strategic Road Network (SRN). The site is bounded
to the west by Cromwell Avenue and to the south by the A4, which forms part of the Transport for
London Road Network (TLRN), although there is no direct vehicular access from the site to the A4.
The site is served by six bus routes along King Street, two night buses plus two other services
within walking distance. The site lies within a five minute walk (approximately 350 metres) of
Ravenscourt Park London Underground station which is served by the District line and is also
within ten minutes walk (approximately 900 metres) of Hammersmith London Underground
station where a wide variety of public transport services are available including access to the
District, Piccadilly and Hammersmith and City lines. The A4 also forms part of the Olympic Route
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Network (ORN). The site has a public transport accessibility level (PTAL) of 5, on a scale of 1-6
where 6 is the highest.
Details of the proposal
9 The proposed development includes demolition of the Town Hall Extension to create a new
public square in front of the grade II listed Town Hall. The ceremonial entrance steps in front of
the Town Hall and facing the new public square will be reinstated. A new bridge link is proposed
along the west side of the existing Town Hall rising over the A4 and landing in Furnival Gardens.
The proposals include new civic office space, 320 new homes, a new food store and smaller retail
units along with 417 cycle spaces and 250 car parking spaces for residents and retail uses.
Table 1 bedroom size mix
Studio 1-bed 2-bed 3-bed penthouse Total Habitable rooms
Market 9 136 144 13 18 320 841
10 There is currently no provision of affordable housing as part of the proposals. The
proposals include four main blocks, which will range in building height from, four, six, seven, nine
14 and 15 storeys.
Case history
11 There has been no pre-application discussion with the GLA. TfL has, however, been in
discussion with the applicant over the last year (see transport section).
Strategic planning issues and relevant policies and guidance
12 The relevant issues and corresponding policies are as follows:
Housing
Affordable housing
Density
Urban design
Mix of uses
Regeneration
Transport
Parking
Retail/town centre uses
Access
Equal opportunities
London Plan; PPS3; Housing SPG; Providing for Children and
Young People’s Play and Informal Recreation SPG, Housing
Strategy; Interim Housing SPG; Housing SPG EiP draft
London Plan; PPS3; Housing SPG, Housing Strategy; Interim
Housing SPG; Housing SPG EiP draft
London Plan; PPS3; Housing SPG; Interim Housing SPG; Housing
SPG EiP draft
London Plan; PPS1
London Plan
London Plan; the Mayor’s Economic Development Strategy
London Plan; the Mayor’s Transport Strategy; PPG13
London Plan; the Mayor’s Transport Strategy; PPG13
London Plan; PPG13, PPS4
London Plan; PPS1; Accessible London: achieving an inclusive
environment SPG; Planning and Access for Disabled People: a
good practice guide (ODPM)
London Plan; Planning for Equality and Diversity in Meeting the
spatial needs of London’s diverse communities SPG; Diversity and
Equality in Planning: A good practice guide (ODPM)
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Tall buildings/views
Sustainable development
Tourism/leisure
Historic Environment
London Plan; RPG3A, Revised View Management Framework SPG
London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22;
draft PPS Planning for a Low Carbon Future in a Changing
Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate
Change Mitigation and Adaptation Strategies; Mayor’s draft
Water Strategy; Sustainable Design and Construction SPG
London Plan; Good Practice Guide on Planning for Tourism
(DCLG)
London Plan; PPS5
13 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the
development plan in force for the area is the Hammersmith & Fulham 2003 Unitary Development
Plan and the London Plan (Consolidated with Alterations since 2004).
14 The following are also relevant material considerations:
The draft replacement London Plan, published in October 2009 for consultation.
The Hammersmith & Fulham Core Strategy proposed submission.
Principle of development
Hammersmith Town Centre
15 London Plan policy 3D.1 seeks to strengthen the role of London’s town centres and secure
a sustainable pattern of retail provision by encouraging retail, leisure and other related uses in
town centres and discouraging them outside town centres. London’s strategic town centre
network is illustrated on map 3D.1 and in Annex 1 of the London Plan, which identifies
Hammersmith town centre as a major town centre. Policy 3D.2 states that the scale of retail,
commercial and leisure development should be related to the size and role of a centre and its
catchment, and that retail and other service provision should be managed in line with the
sequential approach, seeking to reduce car dependency and traffic generation and to improve
public transport access to promote more sustainable forms of development. These principles are
reflected in draft replacement London Plan policy 4.7 Retail and town centre development.
16 National planning policy guidance for retail, leisure and entertainment, offices, arts, culture
and tourism and other main town centre uses is provided by Planning Policy Statement 4 (PPS4)
Planning for Sustainable Economic Growth. This was published in December 2009 and replaced
PPG4 (1992), PPG5 (1992) and PPS6 (2005). The key change from PPS6 to PPS4 is the
replacement of the need test with a wider ranging six-point impact test. The sequential test
remains, as does the scale test, which has been incorporated into the new impact test alongside
accessibility by a choice of means of transport. PPS4’s main objectives include delivering more
sustainable patterns of development, reducing the need to travel, especially by car, and responding
to climate change, and promoting the vitality and viability of town and other centres as important
places for communities.
17 At the sub-regional level, Chapter 5F of the London Plan sets out specific policies for West
London. Policy 5F.1, states that a strategic priority for the sub-region will be to enhance the
attractiveness of town centres and manage the restructuring of town centres where necessary.
Paragraph 5.168 of the London Plan recognises growth in retail within the sub-region and that
consumer expenditure could generate demand for 145,000 to 227,000 sq.m. extra comparison
goods floorspace to 2016 and that provision for this should be made in strategically designated
town centres.
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18 The proposal includes, 3,612 sq.m. of retail, of which 2,680 sq.m. will be for the food
store. The majority of the site is within the town centre and is less than 300 metres from the Prime
Retail Frontage, as such the case for a sequential test is not strictly required. Whilst this is the
case, the site is at the edge of the town centre and outside the identified Prime Retail Frontage
identified in the UDP and the Primary Shopping Area identified in the emerging Core Strategy. As
such the applicant has produced a retail study, which considers the requirements of PPS4 and the
sequential test.
19 The proposal site is 270 metres west of the Prime Retail Frontage. The methodology
considers eight sites located either in, or closer to, the Prime Retail Frontage than the proposal
site. This is considered across the boroughs three town centres of Fulham, Hammersmith and
Shepherds Bush. The study discounts all the identified sites. The first two sites are not large
enough to accommodate the required space. Of the remaining six sites, the applicant argues that
three are unlikely to be brought forward in a reasonable period of time, and the other three do not
comply with planning policy for various reasons.
20 Whilst the location of the foodstore is more appropriate within the Prime Retail Frontage,
the retail study confirms there is sufficient capacity to accommodate the proposed increase in retail
floorspace. It also confirms that the sequential test has been satisfied and that the increase in
retail floorspace can be accommodated without having a significant adverse impact on the vitality
and viability on existing town centres; and that any impacts are offset by the regeneration benefits
to the site and the surrounding area.
Office
21 London Plan policy 3B.1 Developing London’s economy seeks to promote and encourage a
range of premises that can accommodate a mix of different types and size sectors of the economy,
to promote London as one of three world cities. This is underpinned by Policy 3B.2 ‘Office
demand and supply’, and paragraph 3.148 which both seek to rejuvenate office activities, the latter
in the Central Activities Zone and town centres based office quarters. The location within the town
centre supports the land use approach. As such the proposed office provision is broadly
supported.
Loss of the cinema and community facilities
22 The site includes an existing Cineworld cinema, which is currently operational and Friends
Meeting House. The Friends Meeting House will be re-provided on an alternative site identified by
the applicant. The applicant has also provided supporting material to justify the loss of the cinema
in this instance. The GLA has not had sufficient time to scrutinise the full detail of the report. The
Council has previously resisted the loss of this particular facility however the introduction of the
new facilities at Westfield will contribute to the impact on viability. The loss remains inconsistent
with the London Plan policy 3D.1, which seeks to enhance access to goods and services including
the provision of leisure and other town centres uses. The GLA will provide further comment on
this matter prior to the Mayor’s final consideration of the case.
Design, heritage and views
23 Good design is central to all objectives of the London Plan and is specifically promoted by
the policies contained within Chapter 4B which address both general design principles and specific
design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for
development in London. Other design polices in this chapter and elsewhere in the London Plan
include specific design requirements relating to maximising the potential of sites, tall and large-
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scale buildings, built heritage and views. The draft replacement plan includes further detailed
design policy in Chapter 7.
Principle of tall building
24 London Plan policy 4B.9 supports tall buildings where they “create attractive landmarks
enhancing London’s character, help to provide a coherent location for economic clusters of related
activities and or act as a catalyst for regeneration and where they are also acceptable in terms of
design and impact on their surroundings”. The policy goes on to steer boroughs to identifying
suitable locations for tall buildings and that these “may include parts of the CAZ and some
Opportunity Areas”. Policy 4B.10 sets out the detailed design aspects of tall buildings.
25 Policy 7.7b and c of the draft replacement London Plan moves away from active
encouragement to careful management and covers various tests for the location and design of tall
and large-scale buildings. The context of the proposal is mostly three, four and five storeys high
with the main town hall extension up to seven storeys. The proposals include a range of building
heights up to 14 and 15 storeys, which is tall in its context. The are a limited number of similar
scale buildings in the wider context, this analysis is shown in section 2.5 of the design an access
statement, specifically figure 2.23 which shows the townscape diagram of building heights in the
wider context. It is evident from this analysis that the larger scale buildings are set to the east, but
that there is no emerging or defined cluster as such.
26 Policy 7.7d notes that tall buildings should “individually or as a group, improve the legibility
of an area, by emphasising a point of civic or visual significance where appropriate, and enhance
the skyline and image of London”. In principle, therefore, a tall building, which meets the civic
landmark function and contributes to legibility, may be appropriate, particularly in the town centre
location where it may facilitate the wider regeneration aspirations for this part of the town centre
by acting as a catalyst for regeneration as set out in policy 4B.9. This is however subject to the
detailed testing regarding impact on views and townscape and also the impact on the setting of
listed buildings and the character and appearance of the conservation area, which is considered
below.
Views and built heritage
27 London Plan policies 4B.11 to 4B.15 set out the strategic approach to the protection and
enhancement of London’s rich built heritage. The applicant provides an analysis of the built
heritage and townscape in chapter 9 and 10 of the Environmental Statement Volume 2. A number
of key views are assessed including the wider strategic views from the river. Although these views
are not part of the London View Management Framework, there are important strategic townscape
implications in the river views particularly from Hammersmith Bridge.
28 The analysis set out in figure 2.23 and 2.24 of the design and access statement seeks to
identify a tall building datum line in the view from Hammersmith Bridge. It helps in clarifying that
the prevailing building height is the lower line shown in the figure, but that there are some breaks
in the skyline from the Premier Inn hotel to the west and the existing town hall extension, central
in the view, with further breaks to the east. A tall building line is not entirely clear, but a break in
the view is established at various points and therefore the development could maintain this
relationship but should ensure that new additions do not overwhelm the surrounding context.
29 Having regard to the river prospect views in particular view 3 in chapter 10 of the
Environmental Statement Volume 2 (ESV2), it would appear that the scale of the 14 storey
residential block closest to the river (the south tower) requires reconsideration and further testing.
The prevailing townscape height along this view and along the river is much lower in scale. The
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space provided by Furnival Gardens emphasises the low rise character and as such would also
emphasise the impacts any new large scale additions. As such the scale of the southern block
needs further testing to ensure it will fit comfortably in the current arrangement of buildings in the
immediate river prospect context. There is a lack of townscape analysis from the south side of the
river, from the river walk, facing the site. These views should be provided in order to further test
the impact of the proposed south tower.
30 Despite being taller, the 15-storey tower to the north appears less prominent in the view
and is set back, and appears more modest in scale, reflecting the other existing townscape
punctuation to the west (Premier Inn hotel). In this case the 15 storey tower can act as the
defining point of civic function without overwhelming the foreground of the river view. Whilst this
is the case other important local views need to be tested in relation to this building, which are
currently excluded in the views analysis. These include the scale relationship between Cromwell
Avenue and the 15 storey tower. Sections are provided in plan, however these are not entirely
clear. A line of mature trees break this relationship however the view in context of Cromwell
Avenue and the new tower should be provided to understand the true impact arising.
31 The impact of the proposal on the listed town hall and on the conservation area is
considered in parallel to the views testing. The impact of the proposals on King Street the north
side will be mostly positive. This is illustrated in view 21 of the (ESV2). The setting of the Town
Hall will be reinstated and the new mixed-use blocks on Kings Street will frame the square. The
view along King Street (View 11 ESV2) will also preserve the character and appearance of the
conservation area. Whilst this is the case the applicant does not provide a closer view showing the
impact of the tower on the conservation area when viewed facing east, a point which is illustrated
from a distance at view 16. The applicant should provide this view to test the impact from, for
example along king street opposite, Weltje Road and Rivercourt Road facing east.
32 The proposals are unlikely to affect the setting of the Salutation Inn, given the proposals
are viewed to the south, rather than in its context, however, this will become clear with additional
testing as requested above of views facing east from King Street.
33 Notwithstanding the above, the most significant views with regard to the setting of the
Town Hall listed building is at the rear in view 5 and 9 of the ESV2. Here, in both cases, the
setting of the listed building is challenged by the 14 storey residential block that sits directly
adjacent. As set out above, it is the southern block in particular that is most prominent in the river
views of the proposal and the analysis in views 5 and 9 add further weight to the approach to
reconsider and further test the scale to this particular element of the scheme.
Bridge
34 The town centre is currently divided from the river by the A4. The new footbridge will
provide an important link across the A4 and is supported in principle. The bridge design is striking
and modern in appearance. There is concern locally regarding the impact on the adjacent property,
and listed building Sussex House. Testing of landing the bridge at an angle across the park taking
it away from the corner pinch point with Sussex House should be considered, if not already
undertaken. Pedestrians have to navigate into the park from an easterly point anyway, due to the
current arrangement, which means the route is not significantly affected by further alterations, but
this may improve the amenity to residents at Sussex House. A view of the town hall (figure 4.28 of
the design and access statement) has been produced. This should also be provided to illustrate
the view across to Sussex House, i.e.facing south from the point shown in figure 4.28. The impact
on the residents of Sussex House should, however, be led by the Council as a local amenity issue.
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Form, architecture and appearance
35 London Plan policy 4B.1 and 4B.2 underpin the Mayor’s aspiration to create world class
architecture that inspires, excites and delights. Notwithstanding the concerns raised above
regarding scale and impact, the architecture is modern and well considered and will create a high
quality environment that will significantly improve this part of the town centre.
Layouts
36 The applicant seeks to achieve exemplary standards regarding layout and quality of
accommodation. At ground floor level, the layout of retail cafe uses facing the new square is
supported, as is the broad layout to the new food store although the location of the lift core at the
store entrance door may cause congestion for those waiting for a lift and those coming in from the
street level. The uses along the Cromwell Avenue boulevard are largely servicing uses. It creates a
back to the building with limited active ground floor uses with the exception of the very southern
end of the road where duplexes are introduced. Views of this elevation should be provided as
already requested above regarding the impact of the tower on Cromwell Avenue.
37 The creation of the new square and the ceremonial steps whilst positive to the
reinstatement of the listed building, creates a new challenge regarding inclusive access to the
western route up to the civic offices and through to Furnival Gardens. It is unfortunate that the
steps opposite the concierge cannot be designed out to allow a gentle slope up to the ‘river walk’
without the need for a kickback ramp to be introduced. This should be discussed further with the
GLA’s Inclusive Access Advisor. Notwithstanding the above, the new link leading to the new
bridge is positive and spaces created below the walkway have been well defined as office amenity
and will be carefully lit to ensure the space is well surveyed and open.
38 The Mayor’s emerging space standards will be met which is supported. There is a single
unit to the northern tower, which appears as north facing. This does however benefit from a small
balcony, which is part east facing allowing some, but very limited, morning sunlight.
Design summary
39 The approach has many positive aspects to the design. Fundamentally, however, the scale
of the southern tower needs further testing as described above in particular further views testing
from south side of the river. The route from King Street to the bridge also needs further
consideration in terms of inclusive access. The route along Cromwell Road also needs testing in
terms of scale and active uses and in views from the west of the site facing east along King Street
into the conservation area.
Inclusive design
40 London Plan Policy 4B.5 ‘creating an inclusive environment’ expects all future development
to meet the highest standard of accessibility and inclusion. This, together with the Supplementary
Planning Guidance ‘Accessible London: achieving an inclusive environment’ underpins the
principles of inclusive design and the aim to achieve an accessible and inclusive environment
consistently across London. Inclusive design principles if embedded into the development and
design process from the outset help to ensure that all of us, including older people, disabled and
deaf people, children and young people, can use the places and spaces proposed comfortably,
safely and with dignity. The aim of Policy 4B.5 is to ensure that proposals achieve the highest
standards of accessibility and inclusion, not just the minimum. Draft replacement London Plan
Policy 7.2 ‘An inclusive environment’ similarly requires all future development to meet the highest
standard of accessibility and inclusion.
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41 The applicant has committed to lifetime homes and 10% wheelchair homes, which is
supported. As described above GLA officers would like to discuss the route from King Street to
the new bridge and consider the options that were tested.
Children’s play space
42 Policy 3D .13 of the London Plan sets out that “the Mayor will and the boroughs should
ensure developments that include housing make provision for play and informal recreation, based
on the expected child population generated by the scheme and an assessment of future needs.”
Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for
Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be
approximately 47 children within the development. The guidance sets a benchmark of 10 sq.m. of
useable child playspace to be provided per child, with under-5 child playspace provided on-site. As
such the development should make provision for 470 sq.m. of playspace.
43 Section 5.3 of the design and access statement identifies provision of 570 sq.m. of play
space. An area is shown on plan (figure 5.7 within the central courtyards of the north and south
blocks. The strategy focuses on threading playspace throughout the scheme, which is supported,
however it is not clear what type of space has been created, who has access and what, if any
specific equipment or art/play will be provided. Some of this is detailed and can be secured by
condition, however the principle of what the space will be like has not been clearly illustrated.
Affordable housing
44 London Plan Policy 3A.10 requires borough councils to seek the maximum reasonable
amount of affordable housing when negotiating on individual private residential and mix-use
schemes. In doing so, each council should have regard to its own overall target for the amount of
affordable housing provision. Policy 3A.9 states that such targets should be based on an
assessment of regional and local housing need and a realistic assessment of supply, and should
take account of the London Plan strategic target that 35% of housing should be social and 15%
intermediate provision, and of the promotion of mixed and balanced communities. In addition,
Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain
residential development, and to the individual circumstances of the site. Targets should be applied
flexibly, taking account of individual site costs, the availability of public subsidy and other scheme
requirements.
45 Policy 3A.10 is supported by paragraph 3.52, which urges borough councils to take account
of economic viability when estimating the appropriate amount of affordable provision. The ‘Three
Dragons’ development control toolkit is recommended for this purpose. The results of a toolkit
appraisal might need to be independently verified.
46 Where borough councils have not yet set overall targets as required by Policy 3A.9, they
should have regard to the overall London Plan targets. It may be appropriate to consider emerging
policies, but the weight that can be attached to these will depend on the extent to which they have
been consulted on or tested by public examination.
47 Housing policy HO5 has not been saved as part of the Hammersmith & Fulham 2003 UDP.
Therefore London Plan policy 3A.10 is the main housing policy test in this instance. The Council’s
emerging Core Strategy policy H1 is also a material consideration but with limited weight.
48 At this stage the application includes zero affordable housing, the housing offer is set out
in table 1. The applicant argues the public benefits arising from the scheme and substantial costs
associated with the regeneration. These include a new civic destination comprising the new public
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square, reinstatement of the Town Hall, new pedestrian footbridge over the A4, new civic offices
and new shopping facilities.
49 The policy test is clear; the applicant must demonstrate through submission of financial
appraisal that the maximum reasonable amount of affordable housing is being provided. At this
stage the applicant has provided a viability submission, albeit not in the form of a three dragons
appraisal. The Council has commissioned an independent valuer to scrutinise the submission.
There is a lack of clear cost information regarding the development, in particular the construction
costs. The Council has agreed to share the findings of the independent review with the GLA.
Whilst the GLA has not been involved in the procurement of the independent valuer, or the brief
and requirements issued to the independent valuer, the findings will be reported to the Mayor as
they become available. The matter of zero affordable housing will therefore require further
consideration and discussion, before the case is considered by the Mayor at the final determination
stage.
Thomas Pocklington Trust units
50 As part of the regeneration a number of buildings require demolition. Part of the strategy
requires the removal of 54 units currently owned by the Thomas Pocklington Trust. The Trust is a
registered charity which helps the visually impaired to find accommodation. The applicant
indicates that the properties on Cromwell Avenue do not fit within the Trusts portfolio of housing
for visually impaired tenants as both are not of a high enough quality to easily accommodate such
tenants. The Trust has however used Cromwell Avenue and Cromwell Mansions as ‘overflow’
capacity to house seven visually impaired tenants who could not be accommodated in more
suitable accommodation elsewhere. A strategy for re-housing is being put forward by the
applicant which sets out a number of support mechanisms.
Regulated Tenants (26 units)
There will be a dedicated property manager as a single point of contact.
Advice will be given of the tenant’s right to legal advice funded by the applicant as
required.
A full packing service will be offered for the packing and moving of the tenants
belongings.
Financial compensation will be given or options for re-housing in an area to be agreed
by them anywhere in the UK.
As a gesture of goodwill an offer has been made to pay the cost of new carpets and
curtains in the tenant’s new accommodation.
Assured Short Hold Tenants (Open Market Rented 24 units)
There will be a dedicated property manager as a single point of contact.
Letting department will be used to assist in finding suitable alternative accommodation.
The tenants will be allowed to give one week’s notice of termination of their contract
rather than two months, conversely 12 months rather than the two months notice will be
given to tenants to end the tenancy agreement
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51 There are also three Assured Periodic Tenancies and one vacant unit. Whilst the above are
welcome measures, the re-provision of new accommodation to meet the Trusts requirements
should be considered at this design stage. The applicant has provided details of the tenure
breakdown, however it is unclear if any of these are subsidised in the form of an affordable
housing product and therefore meet the definition of affordable housing as set out in the London
Plan and PPS3. In such a case London Plan policy 3A.15 Loss of housing and affordable housing
applies. The London Plan requires no net loss of affordable housing. The status of these units
requires clarification. Whilst retention of the units during construction to fit within the phasing
plan appears to be limited, the future provision should be considered as part of the regeneration
and in line with London Plan policy 3A.13, 3A.15, 3A.5 and having regard to policy 3A.10. Further
discussion between the applicant, the Council, the Trust and the GLA is required before this is
reported back to the Mayor for final determination.
Density
52 London Plan Policy 3A.3 outlines the need for development proposals to achieve the
highest possible intensity of use compatible with the local context, the design principles within
Policy 4B.1 and public transport capacity. Table 3A.2 of the London Plan provides guidelines on
density in support of policies 3A.3 and 4B.1. The draft replacement plan moves away from
maximising site capacity to optimising development potential with a stronger focus on local
context in particular.
53 The residential density has been re-calculated further to discussions with the applicant. It
is based on 841 habitable rooms on an area of the site less some of the commercial uses. The
calculation includes the total site area of 2.4 hectares (20,415 sq.m.) less the following areas:
1,650 sq.m. for the civic office space
3,750 sq.m. for the bridge link and Furnival Gardens
3,000 sq.m. for the public square
54 This provides a site area of 1.2 hectares (12,015 sq.m.). The density on this basis is 701
habitable rooms per hectare. The applicant should also account for the non-residential uses in the
vertically mixed used buildings (i.e. those with ground floor commercial uses). This should be
calculated as a proportion of the building, which should then apply to the proportion of land take
area. This is unlikely to significantly affect the overall density calculation but should be
undertaken to reflect the true residential density of the site. Notwithstanding this point, the site is
in a central location and has a public transport accessibly level of 5. The London Plan guides a
density range in this type of location between 650-1100 habitable rooms per hectare. The
proposed density of 701 is therefore within the guidance set out within the London Plan.
Housing mix
55 The housing mix caters for market accommodation only. Both the quantum of affordable
housing and the re-provision of the Thomas Pocklington Trust accommodation require further
discussion. The housing mix discussion should run in parallel with these matters.
Climate change mitigation
Energy efficiency
56 A range of passive design features and demand reduction measures are proposed to reduce
the carbon emissions of the proposed development. Both air permeability and heat loss
parameters will be improved beyond the minimum backstop values required by building
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egulations. Other features include energy efficient lighting, enhanced controls and variable speed
pumps.
57 Based on the information provided, the proposed development does not appear to achieve
any carbon savings from energy efficiency alone compared to a 2010 Building Regulations
compliant development.
58 Using 2010 Building Regulations compliance software, the applicant should model, and
commit to, additional measures that can be adopted to enable the development to exceed 2010
Building Regulations compliance through energy efficiency alone.
District heating
59 A single site wide heat network providing heating to all new uses in the development is
proposed. This will be fed from a single energy centre. A schematic showing the route of the heat
network should be provided. Information on the location, floor area and layout of the energy
centre should also be provided.
60 It is not proposed to connect the existing town hall to the district heating network. The
applicant should actively pursue connecting the existing town hall into the proposed development.
Further details should be provided in this regard
Combined heat and power
61 Gas fired combined heat and power plant with an electrical capacity around 220kwe,
operating in conjunction with thermal storage, is proposed as the lead heat source for the heat
network. Heat load profiles have been provided indicating that the sizing of the unit has been
optimised in relation to the new buildings. A reduction in carbon dioxide emissions of 265 tonnes
per annum (25%) will be achieved through this second part of the energy hierarchy.
62 The sizing of the combined heat and power unit should be revisited, taking into account
connection of the existing town hall building if feasible.
Cooling
63 Passive design techniques including solar control glazing and shading measures have been
adopted so that the need for active cooling is minimised. Penthouse apartments and commercial
areas of the development will be provided with mechanical cooling but high efficiency electric
chilling plant will be adopted.
Renewable energy technologies
64 A 240 sq.m. photovoltaic panel array is proposed to provide a contribution from renewable
energy. A drawing has been provided indicating that the roof area allocated for the panels has
been maximised, taking into account overshadowing and use of roof space for other requirements
e.g. green roofs. A reduction in regulated carbon dioxide emissions of 10 tonnes per annum (1%)
will be achieved through this third element of the energy hierarchy. On a whole energy basis, a
reduction of 0.5% from renewable energy is proposed.
Overview
65 The estimated regulated carbon emissions of the development are 799 tonnes of carbon
dioxide per year after the cumulative effect of energy efficiency measures, combined heat and
power and renewable energy has been taken into account.
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66 The applicant should provide an estimate of the overall carbon dioxide savings, expressed
in tonnes of carbon dioxide per annum and percentages, relative to a 2010 Building Regulations
compliant development.
Climate change adaptation
67 The London Plan promotes five principles in policy 4A.9 to promote and support the most
effective adaptation to climate change. These are to minimise overheating and contribution to
heat island effects, minimise solar gain in summer, contribute to flood risk reductions, including
applying sustainable drainage principles, minimise water use and protect and enhance green
infrastructure. Specific policies cover overheating, living roofs and walls and water. Chapter 5 of
the draft replacement London Plan considers climate change adaptation, specifically policies 5.9
through to policy 5.15.
68 The proposals have been designed to reduce carbon dioxide emissions beyond building
regulations through energy efficiency measures alone. This includes the use of natural ventilation
and techniques to minimise the risks of overheating. Green roofs will be including within the
proposals and should be conditioned by Hammersmith & Fulham Council. A commitment to
minimising the use of water will should also be conditioned by the Council, in accordance with
London Plan policy 4A.16.
69 Regarding water, a rainwater collection and recycling system will be included through the
sustainable urban drainage system. Overall the site impermeable surfaces have been reduced. The
site is within flood risk zone 3. The flood risk assessment concludes a negligible risk of flooding.
The Environment Agency has, however, been consulted.
70 Microclimate matters, biodiversity, air quality and noise impacts will be considered further
in discussion with the Council.
Transport for London’s comments
71 A series of pre-application meetings regarding various aspects of this application have
taken place with Transport for London over the last year.
Impact on public transport
72 TfL is satisfied with the trip generation and modal split calculations provided within the
transport assessment. Given that the proposals include an additional 320 residential units and
almost double the number of employees from 622 to 1,142, there will be a resultant substantial
increase in trips on the public transport network.
73 The Hammersmith and City line London Underground station at Hammersmith is already
operating at capacity. The transport assessment predicts that there will be over 100 new trips on
the London Underground in the AM peak, plus a considerable number across the rest of the day.
Therefore in order to mitigate the impact of this development, TfL requests a contribution of
£200,000 towards the upgrade of the Hammersmith and City line station including a new ticket
office and/or the line upgrades which will increase capacity. This will ensure compliance with
London Plan policies 3C.2 Matching development to transport capacity and 3C.13 Improved
Underground and DLR services and draft replacement London Plan policies 6.3 Assessing transport
capacity and 6.5 Funding Crossrail and other strategically important transport infrastructure.
74 Given the density of the bus network at this point TfL considers that the increase in bus
passengers can be catered for on the existing network. However, in order to encourage the use of
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uses to and from the site, and to promote inclusive accessibility to all users of the proposed
development, TfL considers that the nearby bus stops should be upgraded, and accordingly,
requests a contribution of £50,000. This will ensure consistency with London Plan Policy 3C.20
Improving conditions for buses and draft replacement London Plan policy 6.7 Buses, bus transits,
trams.
Car parking
75 100 car parking spaces are proposed for the 320 residential units. This equates to a ratio of
0.3 spaces per unit which is both within London Plan and draft replacement London Plan standards
and acceptable to TfL. However, TfL recommends that the number of disabled bays be increased
to 32 to correlate to 10% of homes.
76 120 short stay car parking spaces (including 7 disabled bays) will be provided for all the
retail elements. This equates to an overall ratio of one space per 30 sq.m. While this is within
London Plan standards for retail developments, TfL considers that there is scope to reduce this
level of parking to deliver a more sustainable development in line with the objectives set out in the
London Plan policy to ensure that car parking is the minimum necessary and that there is no-over
provision that could undermine use of more sustainable non-car modes.
77 A total of 25 spaces for non-operational uses of the civic centre will be located at ground
level plus five spaces for operational needs. As stated in TfL’s pre-application advice letter, this is
in excess of maximum standards set out in the London Plan of one space per 600 sq.m. equivalent
to 25 spaces. No justification has been given for this higher level of parking. In a highly accessible
location such as this TfL expects offices to provide simply for operational needs and disabled users.
78 Five car club bays are proposed on Nigel Playfair Avenue which is welcomed by TfL. Two
taxi drop-off bays to be located outside the town hall are also welcomed by TfL.
79 Electric vehicle charging points should be provided in line with standards set out in the
draft replacement London Plan.
80 The civic centre and retail car parking should be reduced and electric vehicle charging
points secured to ensure this application complies with London Plan policy 3C.23 Parking strategy
and draft replacement London Plan policy 6.13 Parking.
Cycling
81 A total of 417 cycle parking spaces are proposed on-site. 322 spaces are proposed for the
320 new residential units. This falls short of the draft replacement London Plan Cycle Parking
Standards, which stipulate that larger units, three or more bed, should have two spaces per unit.
The total amount of residential cycle parking required for the application to conform to the
standards is 329 spaces.
82 45 cycle parking spaces are proposed for the civic offices in addition to those already
provided by the Town Hall, which will be retained as part of the scheme. In addition, staff will be
provided with storage and changing facilities which TfL welcomes. The proposed 50 public spaces
at ground level are also welcomed by TfL. The transport assessment demonstrates that the site is
well connected to existing cycle routes to a variety of destinations.
83 TfL understands that the proposed bridge over the A4 will primarily be for pedestrians and
that cyclists will be asked to dismount before crossing or continue to use the existing subway. TfL
requests that an agreement is put in place to ensure safe cycling routes around the site and
between King Street and the river are maintained during construction. This agreement, plus the
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addition of extra residential cycle parking spaces will ensure the proposals are in line with London
Plan policy 3C.22 Improving conditions for cycling and draft replacement London Plan policy 6.9
Cycling.
Pedestrians
84 The proposed footbridge is accepted in principle as the preferable option compared to an at
grade crossing, which would be inappropriate in this location as explained in TfL’s letter dated 29
July 2010. Implementation of the footbridge would be subject to a legal/highway agreement with
TfL and will require full technical approval of the structural design which should be in accordance
with the Highways Agency Design Manual for Roads and Bridges, design advice from a
walking/cycling perspective and full approval under the Traffic Management Act. These
requirements should be secured through planning obligation or condition. TfL will not adopt the
bridge as an asset but strongly recommends that the Council adopt the bridge in perpetuity for
ease and security of maintenance. Maintenance of the bridge will need to be secured through the
section 106 agreement.
85 The creation of a town square on the site of the existing Town Hall Extension will bring
significant improvements to the public realm and pedestrian environment. Furthermore, the
proposed footbridge over the A4 will increase permeability, providing a more direct, attractive
route to Furnival Gardens and the river.
86 As the site fronts the A4 and will involve the creation of a link across the A4. TfL
recommends that either as part of the footway re-instatement works or as a pre-requisite for the
footbridge, that the area in front of the site should be reviewed and upgrades to the footways and
existing subway be agreed with TfL. This will benefit cyclists who it is envisaged by the developer
will continue to use the subway rather than the new footbridge. This will ensure compliance with
London Plan policy 3C.21 Improving conditions for walking and draft replacement London Plan
policy 6.10 Walking.
Travel Plan
87 A draft framework travel plan has been prepared in support of this development, which
outlines a good range of site-wide objectives, targets and measures. The full travel plans for each
land use should be secured, monitored, enforced, reviewed and funded through the section 106
agreement. They should be produced in line with TfL Guidance and TfL would welcome the
opportunity to review the individual travel plans before they are finalised. This will ensure the
application complies with the relevant elements of London Plan policy 3C.2 Matching development
to transport capacity and draft replacement London Plan policy 6.3 Assessing transport capacity.
Temporary access from the A4
88 In addition to the three routes proposed within the transport assessment for construction
vehicles approaching the site, the developer is proposing a temporary access from the A4 directly
into the site. This would be subject to agreement with TfL as highway authority, subject to a full
Road Safety Audit and Traffic Management Act Approval. The temporary access must comply with
TfL’s policy on retention of trees, appropriate Traffic Management during construction, and
comply with TfL Streetscape Guidance for the re-instatement works. However, TfL agrees in
principle that a temporary access for large construction vehicles may be the best option in traffic
management terms. Plans for this temporary access should also include maintenance of safe,
convenient pedestrian and cycle routes.
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Construction/servicing
89 TfL understands that it is now unlikely that construction of the proposed development will
coincide with the London 2012 Olympic and Paralymic Games. However, TfL reiterates its previous
direction that the A4 forms part of the Olympic Route Network (ORN) and during 2012 there will
be embargos on construction and associated traffic along the ORN.
90 TfL requests submission of a construction logistics plan, which should seek to minimise
highway and traffic impact on the highway network during the course of construction. These plans
should be agreed by the Council and TfL. TfL also requests that delivery and servicing plan is
produced to rationalise servicing vehicle movements to and from the site, this would help to
minimise highway and traffic impact to the strategic road network in the vicinity of the site.
91 It is satisfactory for both the construction logistics plan and delivery and servicing plan to
be secured by condition. TfL would welcome further discussion on construction accesses and
routes in order to ensure the application complies with London plan policy 3C.25 Freight strategy
and draft replacement London Plan policy 6.14 Freight.
Traffic Management Act
92 Should this application be granted planning permission, the developer and their
representatives are reminded that this does not discharge the requirements under the Traffic
Management Act 2004. Formal notifications and approval may be needed for both the permanent
highway scheme and any temporary highway works required during the construction phase of the
development.
Summary
93 The application does not currently comply with the London Plan on transport grounds.
There are a number of issues that should be addressed including: contributions towards LU
capacity; bus stop accessibility improvements; a construction and logistics plan and delivery and
servicing plan to be secured by condition; car parking and electric vehicle charging points; and a
separate application and approval will be required for the footbridge over the A4.
94 These issues should be addressed before TfL is in a position to provide a positive
recommendation on the development proposals. TfL will also need to be involved at an early stage
in the drafting of relevant planning conditions and section 106 obligations.
Local planning authority’s position
95 The officer recommendation is unknown.
Legal considerations
96 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of
London) Order 2008 the Mayor is required to provide the local planning authority with a statement
setting out whether he considers that the application complies with the London Plan, and his
reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the
Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the
application, in order that the Mayor may decide whether to allow the draft decision to proceed
unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a
direction under Article 7 of the Order that he is to act as the local planning authority for the
purpose of determining the application and any connected application. There is no obligation at
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this present stage for the Mayor to indicate his intentions regarding a possible direction, and no
such decision should be inferred from the Mayor’s statement and comments.
Financial considerations
97 There are no financial considerations at this stage.
Conclusion
98 London Plan policies on town centres, office, leisure uses, housing, urban design, climate
change and transport are relevant to this application. The application complies with some of these
policies but not with others, for the following reasons
Principle of development: (non compliant) the loss of the cinema requires further
consideration.
Urban design and inclusive access: (non compliant) the scale of the southern tower needs
further testing regarding the impact on the river views and on the setting of the listed
building. The route from King Street to the bridge also needs further consideration in
terms of inclusive access. The route along Cromwell Road also needs testing in terms of
scale and active uses and in views from the west of the site facing east along King Street
into the conservation area.
Play space: (non compliant) the strategy for play is broadly supported, however there is a
lack of detail regarding the provision of specific spaces and equipment.
Affordable housing (non compliant) the viability submission requires further testing. The
strategy for re-housing or provision of new Thomas Pocklington Trust accommodation
requires further discussion. The status of these units as affordable housing units requires
confirmation. The density and housing mix also requires further work.
Climate change mitigation (non compliant) Energy efficiency savings compared to 2010
building regulations. Schematic showing the energy network. The heat network links to
the town hall should be fully explored. The applicant should provide an estimate of the
overall carbon dioxide savings, expressed in tonnes of carbon dioxide per annum and
percentages, relative to a 2010 Building Regulations compliant development.
Transport: (non compliant) Contributions towards London Underground capacity are
required. There is a need for bus stop accessibility improvements. A construction logistics
plan and delivery and servicing plan should be secured by condition. Electric vehicle
charging points should also be secured by condition. A separate application and approval
will be required for the footbridge over the A4.
99 On balance, the application does not comply with the London Plan:
100 The following changes might, however, remedy the above-mentioned deficiencies, and
could possibly lead to the application becoming compliant with the London Plan
Principle of development: the GLA has not had sufficient time to scrutinise the supporting
reported regarding the loss of the cinema.
Urban design and inclusive access: the scale of the southern tower should be further tested
having regard to the prevailing scale along the river, from the bridge and from the south
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side of the river, and regarding the impact on the setting of the listed building. The
applicant should test whether the steps along the route from King Street to the bridge can
be designed out. Further views testing showing the relationship between the northern
tower and Cromwell Road should be provided, including the view showing ground floor
uses along Cromwell Road (to illustrate the extent of active uses) and in views from king
street west, facing east, illustrating the impact of the northern tower in the context of the
conservation area.
Play space: The strategy for play requires further detail or should be secured through
detailed condition regarding quantum and mix of equipment.
Affordable housing: The zero affordable housing offer is currently not justified. Further
discussion will be required following outcome regarding the viability testing. The strategy
for re-housing or provision of new Thomas Pocklington Trust accommodation needs to be
secured in detail. The status of these units as affordable housing units needs to be
confirmed, as the London Plan seeks no net loss of affordable housing units. The density
calculation should be amended and housing mix discussed as appropriate on the findings of
the viability testing.
Climate change: The applicant should maximise energy efficiency savings and express
these compared to 2010 building regulations. The applicant should provide a schematic
showing the energy network across the site. The heat network links to the town hall
should be fully explored. The applicant should provide an estimate of the overall carbon
dioxide savings, expressed in tonnes of carbon dioxide per annum and percentages, relative
to a 2010 Building Regulations compliant development.
Transport: Contributions towards London Underground capacity are required. There is a
need for bus stop accessibility improvements. A construction logistics plan and delivery
and servicing plan should be secured by condition. Electric vehicle charging points should
also be secured by condition. A separate application and approval will be required for the
footbridge over the A4.
for further information, contact Planning Decisions Unit:
Colin Wilson, Senior Manager - Planning Decisions
020 7983 4783 email colin.wilson@london.gov.uk
Justin Carr, Strategic Planning Manager (Development Decisions)
020 7983 4895 email justin.carr@london.gov.uk
Matthew Carpen, Case Officer
020 7983 4272 email matthew.carpen@london.gov.uk
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