Land between West Street, Bath Street, Royal Pier Road and Queen ...

Application no: 20120931Location:Description:Land between West Street, Bath Street, Royal Pier Road and Queen Street,excluding the High Street, Gravesend, Kent.Hybrid planning application (part outline and part detailed) for the demolitionof buildings and redevelopment of land in Gravesend Town Centre known asthe Heritage Quarter comprising the Western Quarter and Eastern Quarter.The Western Quarter comprising the West Street and St. George's Centrecar parks, St. George's Church and Gardens, part of the existing St.George's Centre, the Blockbuster site and the river walkway betweenElizabeth Gardens and Town Pier. The Eastern Quarter comprising HornYard and Market Square car parks and St. Andrews Gardens. The proposalcomprises:Western Quarter - Outline proposal (including details of access only with allother matters reserved) for a mix of uses including retail and food & drink(Use Classes A1, A2, A3, A4 and A5), offices (Use Class B1), between 164no. and 187 no. residential units (Use Class C3), community space (UseClass D1), public and private car parking, public realm and amenity space aswell as associated servicing, landscaping and highway works.Eastern Quarter - Detailed proposal for the erection of 3 no. buildings toprovide 141 no. residential units (Use Class C3), restaurant space (UseClass A3), a 50 no. bedroom hotel (Use Class C1) as well as public andprivate car parking and associated servicing, landscaping and highwayworks.Applicant:Decision Level:RecommendationEdinburgh House Estates Limited (EHEL)Planning Regulatory BoardTo be provided in the supplementary report.PROPOSALThis application relates to the comprehensive redevelopment of that area of Gravesend TownCentre between West Street, Bath Street, Royal Pier Road and Queen Street and incorporatesa mix of uses including shops, restaurants, offices, community space, a hotel and apartments,including the provision and upgrading of existing public spaces. The application is submitted inhybrid form, such that the Eastern Quarter proposals are fully detailed whilst the WesternQuarter and all associated landscaping and highway works are in outline form.The Eastern Quarter is the detailed element of the application and consists of residential flats inthree blocks, a hotel and a new vibrant market square with restaurants and landscaping as well asunderground car parking. The Western Quarter is the outline element of this application andcontains the main retail provision, residential flats within four separate blocks, flexible spaces foroffice, community and/or retail use as well as public and private car parking and associated publicrealm focussing on the area around the Grade II* Listed St Georges Church.

As a broad overview, the proposed development will provide the following:• Between 305 and 328 residential apartments, including 50no. on-site affordable units;• A 50-bedroom hotel;• c. 12,000 sqm (GEA) of A1 retail space;• 1,427 sqm of restaurant space – envisaged as four/five separate units;• c. 400 sqm of community/church hall space;• between 142 and 1,297sqm of B1 office space;• further flexible provision for community/retail/office space;• 650 on-site car parking spaces – 264 public and 386 private;• Pedestrian friendly approach to West Street and Crooked Lane through physical works;• three principal areas of public open space – Church Gardens, Market Square and St Andrew’sGardens – and secondary connection spaces.The applicant anticipates a 4 year development programme to be completed in 2018, with theEastern Quarter works preceding the Western Quarter.The application has been accompanied by a number of drawings and supporting documents,as listed in Appendix 1.RELEVANT PLANNING HISTORYA planning application (reference 20080696) for a similar form of mixed-use development onthe same site was submitted by EHEL in 2008. The application was initially reported to theRegulatory Board on 19 April 2010. However determination was deferred for concernsexpressed by the Board to be addressed by the applicant, which included the height and designof the buildings, its impact upon the High Street Conservation Area and listed St GeorgesChurch, impacts on views from the River Thames and its impact upon adjoining properties.Members also expressed concerns regarding the size and number of small flats, the spaceavailable for small businesses and the need for links to existing shops and businesses.The applicant responded by making some alterations to the scheme, including a reduction inheight of one building in the Eastern Quarter, consolidating internal flat arrangement to removeall studio flats and placing a restriction on the height of development in the Western Quarter.The application was reported back to the Regulatory Board on 20 September 2010.However, Members did not consider that the reduction in height on the Eastern Quarter, or theassurances of workshops and a planning condition to secure reductions to the parameters ofthe Western Quarter, were sufficient to over-ride on-going concerns over the massing of thebuilt form, its effect on the High Street Conservation Area and St Georges Church, lack of openspace in the Western Quarter and the preponderance of small flats. As such, Membersresolved to refuse the application on the following grounds, as set out in the formal decisionnotice dated 29 September 2010:1. The height, bulk and massing of the outline proposals for the Western Quarter wouldadversely affect the setting of the Grade II* Listed St George’s Church, and would be out ofscale with existing development.2. The height, bulk and massing of the proposed development would have an adverse impacton the character of the adjoining High Street Conservation Area, as well as on residentialand non-residential properties, such as Gravesend Medical Centre.

3. The preponderance of 1 bedroom flats in the Eastern Quarter of the proposed schemewould fail to provide an adequate mixture of accommodation in the context of guidance inPPS3: Housing.4. The application fails to provide for an appropriate quantity of open space in the WesternQuarter of the proposed scheme.Following this decision, the applicant submitted a planning appeal in December 2010 and aPublic Inquiry date was set for September 2011. However, in July 2011 EHEL took the decisionto withdraw the appeal in favour of revisiting the proposal through discussion with relevantparties in an attempt to address the Council’s reasons for refusal.Following withdrawal of the appeal the applicant entered into regular pre-application meetingswith the Local Planning Authority (LPA) and relevant external bodies such as Kent CountyCouncil, English Heritage and the Environment Agency, leading up until application submissionin early November 2012. To contribute further towards developing the emerging scheme aForum was formed in July 2012 that comprised a cross section of the community includingCouncil Members, representatives of local businesses, Urban Gravesham, Council officers andthe applicant’s design team. EHEL also held a public exhibition within the St George’s Centre inFebruary 2012 and September 2012 to invite comment prior to application submission. Thecurrent application (20120931) was formally submitted to the Council on 06 November 2012and validated on 22 November 2012.Aside from the previous unsuccessful application, the most recent developments of interestinclude the setting out of St Andrew’s Gardens in 1954 and the laying out of PrincessPocahontas Gardens in 1965. The Church Hall was constructed by 1978, with an adjacentRectory. The St George’s Shopping Centre was constructed in 1983.PLANNING POLICYDevelopment PlanUnder s.38(6) of the Planning and Compulsory Purchase Act 2004 this application stands to bedetermined in accordance with the Development Plan, unless material planning considerationsindicate otherwise.In this instance, the Development Plan currently comprises ‘saved’ policies from the GraveshamLocal Plan First Review (1994) and ‘saved’ policies from the Kent Minerals and Waste LocalPlans. By forming part of the Development Plan, saved policies contained in the Gravesham LocalPlan First Review should be accorded significant weight, albeit that the weight accorded should begreater where policies have are consistent with the National Planning Policy Framework (NPPF,paragraph 215).In addition, weight should also be afforded to the Proposed Submission Local Plan Core Strategywhich was published on 18 December 2012 and representations invited until 12 February 2013.The NPPF advises in paragraph 216 that from the day of publication, decision-takers may alsogive weight to relevant policies in emerging plans according to the stage of preparation of theemerging plan, the extent to which there are unresolved objections to relevant policies and thedegree of consistency of the relevant policies in the emerging plan to the policies in theFramework.Conversely, policies contained within the Gravesham Local Plan Second Review Deposit Version(May 2000) should now be afforded very limited weight.It is relevant to note that the South East Plan (2009) was revoked on 25 March 2013.

Policy OverviewThe Gravesham Local Plan First Review 1994 sets out three major development sites which areincluded in the proposal site. Specific policies are set out relating to each site. PM1 (Horn Yard,Bull Yard and Open Market) is allocated for a mixed use scheme which incorporates offices,residential, shopping and public car parking. PM2 (Land between Church Street and West Street)is allocated for redevelopment due to its prominent location, and may be promoted as a majorlandscaped public space. PM13 (Ferry Motors Site) is allocated for office use.At this stage it is worthy of note that the Gravesham Local Plan Second Review (Deposit Draft)2000 marked a shift in the Council’s approach to the general development of the area morerecently referred to as the ‘Heritage Quarter’. Policies within this plan generally sought to promotethe comprehensive high quality mixed use redevelopment of this area to include a mix ofresidential, community and employment uses. This is a similar approach promoted through theHeritage Quarter Development Brief (2005) which sets out the Council’s overall vision andobjectives for a comprehensive mixed use development. Whilst it is though important to note thatthese are not adopted documents and that limited weight should be afforded to them, this generalapproach is carried forward in the Proposed Submission Core Strategy using an up to dateinformation base.It is evident therefore that the scheme presently being proposed is not consistent with that beingpromoted through the adopted Gravesham Local Plan First Review 1994. Whilst this is perhapsunderstandable given the change in circumstances over the past two decades, this does notnegate procedural requirements and thus this application has been treated as a departure fromthe Development Plan. This ‘departure’ is also due to the retail proposals extending significantlybeyond the identified Town Centre boundary, which is an approach not normally permissible undersaved Policy S2 of the 1994 Plan. The application has been advertised accordingly.The Gravesham Proposed Submission Core Strategy recognises the need for improvedarticulation of the role of the Town Centre and identifies a need to secure a mix of uses which arerelevant, up-to-date and vibrant. The Proposed Submission Core Strategy sets out a number ofprinciples which aim to strengthen Gravesend Town Centre, including the prioritisation of the TownCentre for retail, leisure, cultural and other service provision. The Heritage Quarter is identified asa ‘key site’ within the plan, being earmarked for comprehensive mixed-use redevelopment. Theplan further identifies the Western Quarter for an extension to the Primary Shopping Area toaccommodate some of the town’s future comparison shopping demands.The Proposed Submission Core Strategy recognises that it will be important that proposals for thiskey site are appropriate to context, fully integrate with the existing townscape, preserve key viewsto and from the river, improve the public realm and enhance the setting of the key heritage assetsincluding the Grade II* listed St George's Church. It highlights further that it is also important thatdevelopment improves pedestrian connections with the historic High Street and the riverside andImperial Retail Park and ASDA superstore to the west and that there should be a requirement forthis development to improve the open space at St Andrews Gardens for existing and newresidents and visitors as well as improve Market Square and the open space around St George'sChurch.Furthermore, the NPPF, which sets out national planning policy, is based on a presumption infavour of sustainable development and recognises town centres as the heart of their communities.It sets out several policies and principles to ensure the long term vitality of town centres and toencourage the promotion of competitive town centres, and emphasise that where town centres arein decline, local planning authorities should plan positively for their future to encourage economicactivity.The following provides a comprehensive list of relevant planning policies:

Gravesham Local Plan First Review 1994The following saved policies in the adopted Gravesham Local Plan First Review 1994 are relevantto the consideration of this application:Proposal PM1 - Horn Yard, Bull Yard and the Open MarketProposal PM2 - Land between Church Street and West StreetProposal PM13 – Ferry Motors SitePolicy AP3 - Northern End of High StreetPolicy AP4 – Queen StreetPolicy H0 - General Housing PolicyPolicy H2 - Application of Residential Design GuidancePolicy H6 - Provision to Meet Special Housing NeedsPolicy E0 - General Employment PolicyPolicy S0 - General Policies for ShoppingPolicy S1 - Location of New Shopping Development (1)Policy S2 - Location of New Shopping Development (2)Policy TC0 - General Townscape, Conservation and Design PolicyPolicy TC1 - Design of New DevelopmentsPolicy TC2 - Policy for Listed BuildingsPolicy TC3 - Development Affecting Conservation AreasPolicy TC5 - Archaeological SitesPolicy TC10 - LandscapingPolicy LT1 - General Policy for Leisure ProvisionPolicy LT2 - Policy for Existing Open SpacePolicy LT6 - Additional Open Space in New Housing DevelopmentPolicy T0 - General Policy for TransportPolicy T1 - Impact of Development on Highway NetworkPolicy T5 - Access to the Identified Highway NetworkPolicy T11 - CyclingPolicy P1 - Public Car Parking in Central GravesendProposal PP1Policy P3 - Policy for Vehicle Parking StandardsPolicy U1 - Southern Water ServicesGravesham Local Plan Core Strategy December 2012 – Proposed SubmissionThe following policies in the Gravesham Local Plan Core Strategy (Proposed Submission)December 2012 are relevant to the consideration of this application:Policy CS05: Gravesend Town Centre Opportunity AreaPolicy CS08: Retail, Leisure and the Hierarchy of CentresPolicy CS10: Physical and Social InfrastructurePolicy CS11: TransportPolicy CS13: Green Space, Sport and RecreationPolicy CS14: Housing Type and SizePolicy CS15: Housing DensityPolicy CS16: Affordable HousingPolicy CS18: Climate ChangePolicy CS19: Development and Design PrinciplesPolicy CS20: Heritage and the Historic Environment

OTHER MATERIAL CONSIDERATIONSNational Planning Policy GuidanceThe National Planning Policy Framework is a material consideration. The weight to be given topolicies in existing local plans will depend on their consistency with the Framework.Planning for GrowthIn March 2011 the Government’s statement ‘Planning for Growth’ instructs planning authorities tosupport enterprise and facilitate housing, economic and other forms of sustainable development.Heritage Quarter Development Brief (2005)The Heritage Quarter Development Brief sets out the Council’s overall vision and objectives for acomprehensive mixed use development, although this is not part of the development plan. Thisdocument proposes a more comprehensive approach to the Heritage Quarter site in comparisonto that proposed in the Gravesham Local Plan First Review 1994, and this approach is carriedforward in the Proposed Submission Core Strategy.Supplementary Planning GuidanceThe following supplementary planning guidance documents are relevant to the consideration ofthis application:GBC Residential Layout Guidelines 1996KCC Vehicle Parking Standards 2006REASON FOR REPORT TO PLANNING REGULATORY BOARDThis is a major development and much of the application site is owned by the Council.The applicant (EHEL) is the development partner of the Borough Council, but this is irrelevant forthe purposes of determining the planning application and must not fetter the assessment it.CONSULTATIONS, PUBLICITY AND REPRESENTATIONSConsultationsThe following section provides a broad overview of the comments received from variousstatutory and non-statutory consultees. The full consultation responses are included inAppendix 2.GBC Planning PolicyThe general principle that Gravesend Town Centre should be the focus of retail, commercialand other town centre type uses accords with planning policy at a national, regional and locallevel. Work undertaken in relation to the emerging Core Strategy highlights the importance ofproviding a range of larger modern high quality shop units to attract national retailers intendedto complement the existing shops. A key message from the Gravesham Retail Update (2012) isthat without such investment the town Centre is likely to continue a gradual spiral of decline.Policy CS05 of the Proposed Submission Core Strategy requires that this should form part of awider high quality mixed-use development that is appropriate to context; that assists inreconnecting the Town Centre and High Street with the surrounding area; and reinforcesGravesend’s character as a riverside heritage town. The inclusion of hotel, residential, office andcommunity uses as part of the mix is also consistent with policy at a national, regional and locallevel. The current application for mixed-use redevelopment in both the Eastern and WesternQuarters is therefore supported in principle as reflecting the approach set out in the emerging

Local Plan Core Strategy. Other aspects of Policy CS05 including access, traffic, and townscapewill be dealt with in the Development Management analysis.In order that the retail component in the scheme complements the existing town centre offer asintended, it is considered important that appropriate conditions be imposed on any permissionso that outcomes properly reflect what is set out in the application – i.e. controlling the mix ofcomparison and convenience floorspace.In considering displacing existing public car parking off-site, the planning policy test on thisapproach is to ask whether the displaced car parking can be accommodated adequatelyelsewhere in the town centre, or by other means, and still maintain the attractiveness ofGravesend as a place to shop, visit etc. Whilst an analysis of existing car park usage suggeststhere is current spare capacity to absorb the lost spaces, the wider consideration should haveregard to factors such as the current low levels of economic activity, demand from small scaledevelopment, the location of car parks in relation to users’ destinations and an operational bufferin a car park due to the ease in finding a space. On this basis there is no objection to the approachof displacing existing parking, which has benefits by reducing traffic flows in the north of the town,provided there is the necessary means of implementing whatever approach is selected as the bestoverall.GBC Economic DevelopmentThe principle of attracting new investment into the town has been a long held objective and thisproposal is particularly welcomed as an opportunity to maintain Gravesend’s position in theretail hierarchy, to increase the benefit from high speed train services to London and givepeople more reasons to visit, including stimulating the evening economy.The inclusion of some start up office space is welcomed as is provision of a hotel as localstudies suggest there is demand for one, particularly if the Swanscombe theme park proposalgoes ahead.The development will create significant new employment opportunities, both during theconstruction period and upon completion, and the Council is supportive of the applicant’sinitiatives to provide local training opportunities and encourage local businesses to bid forcontracts.It is highlighted, however, that the sensitive phasing and management of the constructionproject is required to mitigate local impacts on businesses, such as through temporary loss ofpublic car parking and access to Towncentric. The development does though represent a majoropportunity to support the installation of new high speed broadband services in the TownCentre that will give the residential and retail development an added competitive edge.GBC Regulatory ServicesNoise – In assessing the applicant’s noise report the findings are accepted that other than asmall increase in noise rated as being of minor significance due to the road access into thedevelopment on the West Street/Bath Street roundabout, the proposed development will notintroduce disturbance from traffic noise to existing properties due in part to a slight reduction invehicle flows along West Street and by controlling construction impacts and noise break outfrom new commercial/community uses and plant. The internal standards for the newapartments will ensure ‘good’ conditions for the future residents through construction of thedevelopment, specifically by the glazing and acoustic ventilation specification.Air Quality – Following an air quality assessment measures to collectively mitigate air qualityinclude setting back the new buildings from the kerbside to lessen the canyon effect and

elevating residential units above street level, as well as promoting a Travel Plan and installinginfrastructure for electric charging points. The reduction in traffic flows along West Street isalso considered to be of benefit. A ventilation system will be required to mitigate impacts onsome new apartments in Buildings W01 and W02 and those apartments directly above the carpark entrance off the Bath Street roundabout. The location of public car park barriers well insidethe entrance will help reduce the risk of congestion beneath the flats.Contaminated Land – The initial desk work undertaken covers the points raised in earlierstudies and potential areas and therefore offers no objection subject to imposition of a planningcondition requiring further intrusive investigations to fully inform any necessary remediation.GBC Housing Strategy and Development ManagerThe proposed deviation from standard affordable housing policy comprising an equal split acrossthe development of on-site provision (25no. shared ownership and 25no. ‘active elderly’ units) anda commuted sum is acceptable in principle, subject to further discussions with the applicantregarding the value of the commuted sum, calculated as £3,225,900 using the Council’s adoptedformula.GBC Conservation OfficerComment focusses on the impact the proposals will have on the setting of heritage assets,including listed buildings and conservation areas and takes the view that the applicant correctlyconcludes that the setting of Gravesend’s heritage assets located within and adjoining theproposals area will benefit from the replacement of the open car parks with the reinstatement ofthe urban form that they were once associated with. Further detail included in the ‘heritage’section.GBC Leisure ServicesIn general support the proposals for improvements to the existing facilities within the proposalsarea and appreciate the provision of additional open space in a town centre location would bedifficult. It is recognised however much of the new space created may only be classified asincidental public realm whilst comment on the new spaces identified by the applicant isprovided. It is highlighted that the scheme should contribute to formal off-site recreationalprovision and a list of some local leisure projects are highlighted to which enhancement andupgrading of existing facilities would benefit the new population.GBC Operational ServicesThe information contained in the submitted Servicing Plan appears acceptable, andencouragement given to the provision of facilities for recycling waste. Particularly interested inthe stone gabion features including who will be responsible for maintaining them. Considerationalso needs to be given to the maintenance/revenue requirements for the enhanced St AndrewsGardens, and query who will be responsible – assumes it will remain GBC.A little concerned with the number of trees being lost, but commendable that more trees arebeing replaced than felled - would seek confirmation that semi-mature trees to be planted canbe sourced. Encouragement is given to the retention of the group of Horse Chestnut trees inthe upper St Andrews Gardens and the two London Planes in West Street, all of which offergood amenity value.

GBC Parking ServicesFollowing discussions with GBC Planning Policy corroborate their response in respect ofdisplacing existing public car parking from the application sites.GBC Private HousingComments raise awareness to the potential for detrimental impacts to living conditions that maybe caused by excessive heat in residential apartments, particularly along West Street wherethe units are likely to comprise sealed units due to noise/air quality. ‘Excess heat’ is a hazardidentified under housing rating standards.Highways AgencyNo objection.KCC HighwaysFollowing receipt of a safety audit and the designer’s response consider the general principle ofthe physical highway works to be acceptable and satisfied that any issues can be dealt with atthe detailed design stage. They acknowledge the applicants approach to displacing existingpublic car parking, but raise awareness to the need to update the existing real time car parkingsignage to reflect the new arrangements. They also highlight the need for further discussionsregarding the management of private residents’ car parking to ensure the most efficient use,and that the Travel Plan will include a travel pack to new residents to promote options forsustainable travel.In respect to traffic modelling, following discussions with the applicant’s transport consultant,KCC Highways verify that the pattern of vehicular movements predicted seem generallyconsistent with the scale of development proposed, and also that West Street will experience areduction in traffic flows during the evening peak hour as a result of displacing existing publiccar parking. Whilst this will increase flows elsewhere on the one-way system this would not besufficient to cause serious congestion problems.Finally, a request for a financial contribution in the order of £1,000,000 has been soughttowards the proposed Rathmore Road link which is part of the Kent Thameside StrategicTransport Infrastructure Programme.KCC Highways conclude that, subject to further detailed work identified by the safety audit andan appropriate financial contribution, they do not object to the application.English HeritageThe design proposals have now reached a point where support can be given to the schemeinsofar as it relates to their remit – namely the height of buildings adjacent to the High StreetConservation Area and the layout and scale of buildings affecting the setting of the Grade II*Listed St Georges Church. The current plans show a degree of responsiveness to earlierconcerns and provide confidence that the final scheme will sufficiently safeguard the majorheritage assets.The form of development proposed for the EQ is broadly appropriate for this location and thereduction in height of E03 will help resolve the change in scale between the old town and thenew build development. In particular it will enhance the framing of views of the Church spirefrom the east.

The WQ buildings now have greater separation from St George’s Church and will provide it witha more respectful space to be seen and appreciated, particularly W03 that also steps back atupper levels and utilises a colonnade treatment at ground floor level that will provide a morecomfortable relationship. Furthermore, the changes in massing and design of the WQ buildingsbetter protect views of the Church spire including in views from the River Thames wherevisibility is not diminished for virtually the whole panorama as one passes the Town. It is alsocommented the proposed scheme will visually and functionally reconnect the Church at theheart of the Town with the River.Landscaping proposals have been greatly improved and the principle of a consistent languageof materials and furnishings through the two quarters that are modern but have resonance withthe traditional materials of the Town is appropriate. However, it is suggested that where historicsurfaces and street furniture exist that they are retained and enhanced if possible, such asextending the setted surface of the alleys linking to High Street.KCC ArchaeologyWhilst the carrying out of pre-determination field evaluation has been encouraged, it has beenaccepted that archaeological issues can be suitably addressed through a planning conditionthat would require adequate investigation prior to any works on site commencing.Environment AgencyNo objection to the proposal subject to imposition of planning conditions relating to flood riskand surface water drainage, contamination and protection of groundwater. They do offercomment however to confirm that the raised levels of residential accommodation providesuitable protection from possible flooding and that the sustainable drainage solution willimprove the cleanness of discharged water.Natural EnglandSatisfied that the proposal will not have an adverse impact upon the South Thames Estuaryand Marshes SSSI. Natural England direct the LPA to adopted national standing advice forassessing potential impacts on protected species such as bats, barn owls and breeding birds.KCC Communities, Education and Adult Social ServicesOn behalf of KCC, Mouchel have assessed the implications of the additional residentpopulation anticipated through the development on its community services and requestfinancial contributions towards education, local libraries, youth facilities, community learningand adult social services – amounting to approximately £450,000.Kent PoliceProvide detailed comments regarding measures for designing out potential crime and antisocialbehaviour problems, including recommending the develop achieves Secured by Designstandards, ensuring that access to private areas is adequately controlled, putting in placeappropriate management processes, ensuring appropriate lighting schemes for all spaces andfor counter-terrorist purposes avoiding access by vehicles to public spaces.Having reviewed the implications of this proposal on its infrastructure Kent Police hasdetermined that, in order to maintain effective and efficient policing services to Gravesham,additional infrastructure will be required. To offset the impacts of the proposed developmentthey request a financial contribution towards provision of additional police officers, staffaccommodation and custody space - amounting to approximately £140,000.

of small and undersized flats; fail to promote a mixed community; fail to provide sufficient onsiteaffordable housing; cause serious harm to residents of existing properties; cause seriousharm to amenity of public spaces and buildings; cause blight and sterilise land around the site;either draw trade away from the existing Town Centre or echo existing retail unit vacancy rates;and reduce the net quantity of public car parking in this part of the Town. It is also suggestedthat the scheme is premature in the context of the emerging Core Strategy and that theabsence of a viability assessment and heads of terms for a s.106 Agreement means it is notpossible to be satisfied that the scheme will deliver appropriate contributions to infrastructure.The Victorian SocietyThe Society welcomes the re-animation and re-densification of this area and thus supports theprinciple, but have serious reservations about the quality and suitability of the current designwhich it feels are not of a quality to make the prominence of the buildings acceptable.Dartford Borough CouncilNo objections.No responses were received from the following notified consultees:SE Coast Ambulance ServiceThames Watermen AssociationArriva Southern CountySUSTRANSNetwork RailSouth Eastern TrainsRSPBKent Wildlife TrustNW Kent Racial Equality CouncilRamblers AssociationOpen Spaces SocietyMedway CouncilThurrock CouncilThames Defence HeritageGeorgian GroupGravesend Historical SocietyWindmill Hill AssociationRochester Diocesan OfficeShorne Parish CouncilCobham Parish CouncilHigham Parish CouncilVigo Parish CouncilMeopham Parish CouncilSouthfleet Parish CouncilLocal RepresentationsThis planning application was publicised locally by a press notice as well as numerous sitenotices on and around the site, and in accordance with the Town and Country Planning(Development Management Procedure)(England) Order 2010 advertised as the following:• EIA development – accompanied by an Environmental Statement;• Major development proposal;• Development not in accordance with the Development Plan;• Development affecting the setting of Listed Buildings;• Development affecting Public Rights of Way; and• Development affecting the character or appearance of two Conservation Areas.In addition to the above, the application was publicised to local residents and businesses byneighbour notification letters to households and businesses within an approximate 100 metreboundary of the site – this amounted to a total of 1,147no. letters being sent.

At the time of writing this report a total of 728no. written representations had been received,comprising:195no. in support;528no. objecting; and5no. neutral.Appendix 3 includes an overview of the comments received from local residents and businesses,as summarised by the case officer. The originals are a matter of public record and are available forinspection in the Civic Centre.In summary, the principal comments in support of the application relate to the current schemerepresenting an improvement to the original unsuccessful scheme, providing much neededinvestment into the Town to provide employment and training opportunities for local people andbenefitting existing Town Centre traders. The principal comments in opposition to the proposalrelate to questioning the need for new shops when many existing units are vacant, thedetrimental impact upon living conditions of the adjoining residents, impacts on Town centre carparking, the scale and massing of the proposed buildings, the provision of small flats and thedesign failing to reflect the unique character of Gravesend. Many of the objections are howevermade on the belief that regeneration is needed for the Town, but just that the current proposalsare unsympathetic to its riverside heritage location. There have also been questions askedabout the viability of the development and whether it would actually be built if approved.In addition to the above representations, details of the responses following an exhibitionpresented by EHEL at the Gurdwara in Gravesend were submitted by the applicant in supportof the proposals.Revised PlansIn response to concerns raised by officers and members of the public the applicant submittedrevised plans on 11 April 2013 comprising the following:• Amended internal arrangement to some of the residential units within the Eastern Quarter;• Updating the layout of the entrance level car park off Crooked Lane to avoid obstruction ofspaces by structural columns;Upon receipt of these amended plans the LPA considered whether it was necessary to republicisethe application and resolved that - owing to the nature of the changes relating only tothe internal arrangement of individual flats and one level of the residential car parking (neitherof which affect the quantum of apartments or parking spaces) – additional public consultationwas not required.It is necessary to note that a submitted change to reduce the height of the southernmost bay ofBuilding W03 by one storey has since been withdrawn by the applicant due to their concernsthat it may have legal implications with the submitted Environmental Statement and wouldtherefore introduce excessive ‘risk’ to the validity of any permission that may be granted.PLANNING ANALYSISAs a starting point for assessment of this development proposal, and to appreciate the originalobjectives of the development, it is appropriate to refer to the Heritage Quarter Development Briefprepared by the Council in 2005. The Brief sought a comprehensive and integrated developmentto “deliver a step change in the retail, business, residential and leisure offer of Gravesend,ensuring that the proposal is fully integrated into the urban design philosophy of the town”, and

stated further that the development is expected to:• Deliver a dynamic and commercially viable mixed use development which addresses the keycomponent parts of the Heritage Quarter;• Provide high quality urban living opportunities;• Provide improved accessibility through a framework of routes and spaces;• Enhancing the ‘urban grain’ of the Town and at the same time respecting the scale, massingand height of the existing buildings where appropriate;• Making new connections between the commercial areas and the riverside;• Meeting modern sustainability requirements, including being fully DDA compliant andincorporating ‘Secured by Design’ principles.Further to the above, the Proposed Submission Core Strategy recognises that it will be importantthat proposals for the Heritage Quarter key site are appropriate to context, fully integrate with theexisting townscape, preserve key views to and from the river, improve the public realm andenhance the setting of the key heritage assets including the Grade II* listed St George's Church. Ithighlights further that it is also important that development improves pedestrian connections withthe historic High Street and the riverside and Imperial Retail Park and ASDA superstore to thewest and that there should be a requirement for this development to improve the open space at StAndrews Gardens for existing and new residents and visitors as well as improve Market Squareand the open space around St George's Church.Therefore in considering the current application it is appropriate to cross-refer to the aboveidentified principal objectives of the development. In respect of resolving a stance on theacceptability, or otherwise, of the present application it is indicated by officers that the key issuesfor consideration in assessing the proposals are considered to be the following:• Principle of development and mix of uses;• Impacts upon the townscape and historic core of the Town;• Impacts on existing and proposed residents;• Provision of adequate open space and public realm;• Impacts upon the highway network and highway safety;• Viability and s.106 obligations.Principle of DevelopmentThe general principle that Gravesend Town Centre should be the focus of retail, commercialand other town centre type uses accords with planning policy at a national, regional and locallevel. Town centres are multi-functional places at the heart of their local communities where arange of commercial, social, cultural, leisure and residential uses come together to createdistinctive places. Whilst they are often cherished places endowed with historic significance,they cannot stand still if they are to remain relevant to the needs of people and business, and arecent local retail study sent a clear message that without investment Gravesend town centre islikely to continue a gradual spiral of decline.The Proposed Submission Core Strategy advises that the Heritage Quarter site, particularly thearea adjacent to the existing shopping centre, is the Council’s preferred location for new largerscale modern retail units as it will provide a logical extension to the primary shopping area. Theintention being that it will attract major retailers to complement rather than compete with theexisting retail offer, whilst also recognising the role of small independent traders in the town. Whilstthis is not in step with the currently adopted Development Plan, as previously mentioned this isperhaps not surprising given the change in circumstances since these policies were adoptedalmost two decades ago.

It is therefore encouraging that significant investment into the town is proposed and the challengeis ensuring that the necessary change, to maintain its place in the retail hierarchy of North Kent,can be accommodated whilst preserving or enhancing local character and sense of place.The inclusion of hotel, residential, office and community uses as part of the mix is also consistentwith policy at a national, regional and local level. In particular it is considered wholly appropriatefor development in this location to include a high density residential component to provide for anincreased resident population in the Town Centre with benefits such as an improved sense ofpublic safety due to natural surveillance and enhanced activity.Mixed-Use Development ApproachA core principle of the planning system is to proactively drive and support sustainable economicdevelopment to deliver the homes, business and industry, infrastructure and thriving local placesthat the country needs. The NPPF states that LPAs should recognise town centres as the heart oftheir communities and ensure they meet all recognised needs including retail, leisure, office andother main town centre uses.It is also recognised that residential development can bring a range of benefits to a town centre,such as enhancing its life and vibrancy and improving security, as well as bringing economicbenefits, encourage investment and contribute to regeneration. The inclusion of an element ofresidential development in the scheme is therefore wholly encouraged for the above reasons butalso to contribute towards meeting the Borough’s housing need.In addition, as stated by the NPPF, “planning decisions should aim to achieve places whichpromote safe and accessible environments where crime and disorder, and the fear of crime, donot undermine quality of life or community cohesion”. The principle of focusing a vibrant mix ofdevelopment within an existing centre, particularly encompassing a significant residential element,is conducive to improving the sense of security due in part to natural surveillance afforded by a 24hour presence of people. Section 17 of the Crime and Disorder Act 1998 is also relevant andplaces a duty on all authorities to do all it reasonable can in its various functions to prevent crimeand disorder in its area.In order to better understand the impacts and relationship of the individual uses proposed, thefollowing sections focus on the broad approach to the mix of uses proposed.ShoppingA key principle of what the application delivers in regeneration benefits is considered to be theneed to enable the improvement to the quality, quantity and specification of retail units to attractthe type of retailer that will enhance the attractiveness of Gravesend Town Centre and persuaderesidents to use it rather than to travel to other centres such as Bluewater or Maidstone. A recentretail assessment commissioned by the Council in response to the plans to expand Bluewater(undertaken by WYG dated January 2013) identifies that development of the Heritage Quarter isessential to halt the existing decline of Gravesend Town Centre.It is also considered that this will have the effect of benefiting smaller speciality shops that are orcould potentially locate in the existing shopping centre and the High Street, not just by potentiallyincreasing the critical mass of shoppers but by creating increased vitality and vibrancy nearer tothe riverside and expanding the town centre. Many objectors have commented that there is littlepoint in building more shops because of the current vacancy rate in the town. However, asadvocated by the applicant and corroborated in the above referred retail assessment, the provisionof currently under-provided larger retail units would increase the attractiveness of GravesendTown Centre generally and consequently reduce vacancies. As commented upon by the BoroughCouncil’s Economic Development Officer, local people regularly state that extending the range and

quality of consumer choice is a priority for the town. Therefore the aim is not simply to increase thequantity of shopping opportunities but the quality, and this approach is accepted by a notableproportion of existing retailers in the town centre through representations received.In terms of quantity of retail space, based on maximum parameters and taking into accountdemolished retail space, the scheme would deliver up to 7,310sqm of trading floorspace. Forcomparison this total is roughly equivalent to the total trading floorspace at the extendedSainsbury’s store at Pepper Hill in Northfleet (7,566sqm).Whilst a recent retail study (GBC Retail Study Update 2012, Roger Tym and Partners) highlightsthat the Borough has a greater need for comparison floorspace, it does not discount the provisionof some additional convenience floorspace if it is centrally located, since this will promote moresustainable shopping patterns, maximise linked trips and thus enhance the vitality of the towncentre. As such, whilst the intention is to provide the majority of the floorspace in the applicationsite for comparison shopping, it is proposed that up to 3,160sqm could provide for convenienceshopping. However, in order that the retail component complements the existing town centre offeras intended, it is considered important that appropriate conditions be imposed on any permissionso that outcomes properly reflect what is set out in the application.In addition to the appropriateness of the retail component, subject to safeguard through conditionregarding the split of comparison and convenience floorspace, the physical connection from theexisting shopping centre appears to be successfully worked and the opening up of views of theChurch in longer vistas will aid legibility and encourage people to the area as well as provide anattractive circulation area and shopping experience.An issue has been raised concerning the possibility of retailers vacating existing premises withinthe town centre to occupy new units within the Heritage Quarter development. Ultimately, theCouncil cannot prevent the operation of the free market but it is worth noting that businesses willonly tend to move where they need larger or improved premises linked to an improvement in theirretail offer. This is something the Council would not wish to discourage because it would representan investment in the future of Gravesend as a modern retail centre. Any premises vacated wouldthen be available for others wishing to trade within an improved town centre. The alternative to notproviding larger and more modern premises also needs to be considered because this could leadto increased pressure for competing out-of-centre retail development or retailers withdrawing fromGravesend altogether, reinforcing the cycle of decline the current proposals seek to address.RestaurantsThe applicant has corrected anomalies contained within the various application documents andconfirmed that the proposed commercial floorspace at the Market Square level within building E01will comprise solely restaurant uses, therefore excluding the potential for its partial use to providepubs or takeaways. Given the quantum of takeaways and pubs in the Town Centre generally, andhaving regard to the potential impacts upon residential amenity often attributed to such uses, it iswelcomed that this clarification has confirmed that the application only proposes restaurants, albeitthat they will likely include some ancillary takeaway and bar facilities.It is envisaged that the floorspace will provide four or five restaurants in order to provide sufficientchoice to the consumer so as to become an active destination. A town centre ‘health check’ (May2011) identified that restaurant provision within Gravesend Town Centre is below the nationalaverage and it is hoped that the provision of a hub of new restaurants, set within the context of acontained and active public space, will meet a demand not presently catered for in the town.Office SpaceThe proposed scheme would deliver some new office floorspace, with the intention being to

provide for small businesses and start-up firms. However due to the demand for office spaceconstantly changing, some flexibility has been incorporated into the submitted scheme whichprovides for a wide range of between 142 and 1,297 sqm of B1 office space. Building W02includes some space that will be dedicated to an office use whereas some flexible space isprovided in the dual level ‘kiosk’ units within Building W03, where alternative options for usesincludes cafes, shops or community uses.Whilst the inclusion of some office space is welcomed, a view shared by the Borough Council’sService Manager (Economic Development), it is understood that to provide serviced businessspace a critical mass of floorspace is required. For example, discussions with Basepoint haveconfirmed they would need at least 1,200 sqm of lettable floorspace to be interested in managingthe new office space. It is therefore unfortunate that the application does not commit to providing agreater amount of office space as it cannot be reported with any certainty that sufficient floorspaceto cater for serviced business space will be provided. It remains positive however that some officespace will definitely be provided and it will add to the mix of uses and overall vitality of the area.HotelHotel studies for the Kent Thameside area (i.e. those areas of Gravesham and Dartford north ofthe A2) suggest that there is demand for a good three-star rated hotel provision in the Town. Thedemand for hotel accommodation in the area will also grow significantly should the Paramounttheme park in nearby Swanscombe be realised.The current application, albeit being detailed for the Eastern Quarter buildings, retains flexibility forthe hotel element of the scheme as the internal fit out will depend on the operator that occupiesthe building. As submitted however the hotel element incorporates 50 bedrooms with a modestrange of sizes, with the smallest being some 21 sqm which compares equally to other local hotelssuch as the Woodlands Premier Inn and the Manor Hotel at Hever Court. It has been highlightedthat a higher quality of hotel could help reinforce the town and river as a destination to drawadditional visits and overnight stays, although the market will dictate on this issue. The applicanthas, though, reiterated an aspiration to attract a four star operator.In summary the provision of some hotel accommodation within the development is positive as itwill add to the mix and vibrancy of the uses on offer as well as provide for visitors to the town andgenerate some new longer term local employment opportunities.Community Use/Church HallRedevelopment of the Western Quarter would involve the loss of some existing community typebuildings, notably the Church hall and the Waterside Centre. However, an integral requirement ofthe scheme is to re-provide a community facility which comprises a purpose built and moderncommunity facility to be included within Building W02, over which the Church will benefit from firstrefusal. Although physically detached from the Church, which is comparable with the existingsituation, the location of the new facility is within close proximity such that it may still adequatelymeet its needs. Furthermore the new facility will benefit from improved access, including beingfully accessible to disabled users, as well as benefitting from enhanced surrounding public realm.It is understood that the Church is pursuing an alternative option for a stand-alone hall within itsown grounds and, if successful, the community facility to be provided as part of the proposeddevelopment would be available as a generic community use space.HousingResidential development can bring a range of benefits to a town centre, such as enhancing its lifeand vibrancy and improving security. Increased uses in a town centre can bring economicbenefits, encourage investment and contribute to regeneration.

The Proposed Submission Core Strategy identifies how the Borough will meet its own identifiedhousing needs during the Plan period (2011 to 2028) and finds that there is a need for 4,600 newdwellings. The incorporation of over 300 residential units as part of any development of this keysite is recognised as being important in meeting the Borough’s identified housing need andavoiding either an under-provision of housing or indeed pressure for encroachment on the GreenBelt and/or development of less sustainably located sites. The interim update to the StrategicHousing Market Assessment (December 2012) shows a current need for smaller units in theBorough, with the need for one and two bedroom market housing amounting to well over 50%% ofthe identified housing requirement.The current application provides for a range of between 305 and 328 apartments, not fixed due tothe outline nature of the WQ proposals, with the majority comprising one (42%) and two (52%)bedroom units but with some three (6%) bedroom units as well.Some concerns have been raised by local residents regarding the number of flats within theBorough and the local area, inferring that there is no need for more flats. In the context of theapplication site - comprising the Pelham, Central and Riverside wards - the proportion of existingflat or maisonette accommodation amounts to approximately 44% of the housing stock, althoughthe overall proportion of flats in the Borough is notably below national and regional averages. It isrecognised though that having regard to existing planning permissions or other planneddevelopments in these wards over the Plan period (2012-2028) there could be almost 1,500additional dwellings, a significant proportion of which would be flats.In respect of density however, as identified within the Proposed Submission Core Strategy (PolicyCS15), new residential development in suitable locations close to the transport hubs of Gravesendtown centre will be encouraged to achieve a density higher that 40 dwellings per hectare (dph). Itis recognised that high density does not necessarily mean flats but, in locations where activeground floors, mixed-use, car parking and flooding are issues, such as the town centre, flats arenormally the best option.The current application achieves a density of 52 dph and, given the aspirations of the scheme todeliver a mixed use development that will halt the economic decline of the town centre and createan attractive and inclusive environment for residents, shoppers and visitors alike, the option ofproviding flatted accommodation is considered to be the most appropriate to ensure efficient useof the land available. This also responds to concerns by many local residents who cite apreference for the inclusion of traditional family houses on the site, albeit the point is made thatalmost 60% of the apartments proposed will comprise two or more bedrooms that may cater forfamilies. Furthermore, as detailed below, the receipt of a commuted sum in lieu of some on-siteaffordable housing in the Eastern Quarter is justified partly on the basis that it will allow theCouncil to deliver alternative accommodation elsewhere in the Borough.Turning to affordable housing, and in accordance with the NPPF, where LPAs have identified thataffordable housing is needed they should set policies for meeting this need on site, unless off-siteprovision or a financial contribution of broadly equivalent value can be robustly justified and theagreed approach contributes to the objective of creating mixed and balanced communities. TheCouncil’s current affordable housing policy is for 30% on-site provision of affordable housing forschemes proposing 15 or more residential units. This policy does however allow consideration tobe given in certain circumstances to alternative delivery options, such as provision of a commutedsum in lieu of on-site provision of affordable housing.The affordable housing offer provided by EHEL through this application is for 50no. affordableunits on site within the Western Quarter (which equates to 15% of the maximum total numberacross the development) with the remaining 15% will be provided as a commuted sum in lieu ofprovision on the Eastern Quarter. It is proposed that the on-site provision be a mix of shared-

ownership and ‘active elderly’ rented units for over 55’s and firm interest from established and wellknown Housing Associations, in the form of actual offers for the units, provides confidence thatthey will be delivered on site. The proportion of affordable units to be provided on site has alsoincreased from the previously supported approach under the previous application (10%), which ispositive in the drive to promote mixed and balanced communities.The inclusion of some ‘active elderly’ apartments is to meet the needs of the aging localdemographic and so this will provide for those elderly residents looking to downsize from largerunits elsewhere in the Borough, which will have the effect of releasing under-occupied familyhousing.In summary it is the view of officers that this split approach to providing affordable housing isappropriate and thus acceptable in principle due to the on-site provision of mainly one and twobedroom flats and the ability of a commuted sum to fund delivery of alternative types of housing inthe Borough. This accords with the approach to delivering affordable housing, as set out in theProposed Submission Core Strategy. Furthermore, at present there are a number of whollyaffordable housing schemes in the vicinity of the Eastern Quarter - such as Chantry Court,Longferry Court and The Terrace - and additional provision in this immediate area would notsupport the desire to achieve a balanced community.Plainly, however, an important consideration will be the value of commuted sum to be agreed withthe applicant and, based on the Council’s adopted formula, the contribution to be sought isapproximately £3.2 million. Subject to caveats such as land costs, this contribution could deliver inthe region of 20-25 new Council homes. However, in considering this financial contribution it isnecessary to have regard to scheme viability as the Government is encouraging LPAs to negotiatewith developers to avoid such requests preventing delivery of otherwise acceptable developments,particularly concerning affordable housing.Design and TownscapeThe NPPF recognises that the Government attaches great importance to the design of the builtenvironment and states that good design should contribute to making places better for people. Inparticular it promotes high quality and inclusive design for all development, including individualbuildings and public/private spaces, which should respond to local character and be visuallyattractive. It also states new development should address connections between people and placesand the integration of new development into the built and historic environment.In considering the design and townscape impacts of the proposed development, it is relevant tohave regard to both the overall design approach - which will include siting of buildings and theirrelationship with surrounding buildings and spaces - as well as the detailed architectural approachto the individual buildings. Members are reminded at this juncture that the proposals for theEastern Quarter are fully detailed whilst those for the Western Quarter are in outline form.Eastern QuarterThe Eastern Quarter comprises the erection of three new buildings (E01, E02 and E03) laid outwith the rationale of providing a lively public space and focussed on pedestrian movements to andfrom the River and the High Street.In terms of integrating with the existing townscape, which includes the High Street and QueenStreet buildings that lie within a Conservation Area, the broad design concept is consideredappropriate in that it maintains and enhances pedestrian permeability in the area and encouragesconnection to the river and to the High Street, whilst improving the setting and vitality of theBorough Market and the Old Town Hall. Whilst the overall scale of the buildings have been thesubject of previous concern, including a previous reason for refusal, this proposal incorporates

modest alteration to reduce both the height and massing of Building E03 to lessen its dominanceand emphasise the building as stepping down towards the River, which is a distinct characteristicof the adjacent High Street. The roof profiles of Buildings E02 and E03 have also been simplifiedby deleting the ‘gull wing’ features which previously seemed to compete for attention. Therelationship between Building E03 and the historic High Street buildings is particularly sensitiveand despite some local concerns English Heritage have commented that these alterations “willhelp resolve the change in scale between the old town and the new build development” and“facilitate a better townscape relationship in longer views towards the town from the river and willenhance the framing of views of the spire of St George’s church from the east”.It appears that Building E01 does not sit completely comfortably alongside the Gravesend MedicalCentre, as in section form it appears approximately twice the height. However, the juxtaposition ofthe buildings, coupled with the separation distance (c.12.5 metres) and top floor roof design of thenew building (mansard behind a parapet) the impact of dominance is somewhat reduced. Aphotomontage of the proposed view along Bank Street has been provided by the applicant andthis, by having regard to perspective rather than a flat elevational plan, appears to support a viewthat the relationship between them is not as overpowering as the section implies.The proposed Market Square is formed by the three elevations of Building EO1 and the BoroughMarket building to complete the square, yet retain good pedestrian permeability. This layout isintended to form a vibrant urban space through the inclusion of a cluster of restaurants at groundfloor and apartments on the upper floors to further define the square and provide added activityand natural surveillance. The degree of enclosure will afford the area some protection frominclement weather whilst maintaining and channelling some views to the River through a doubleheight (6.5m) opening.Building E01 rises in height to five storeys but by utilising the natural slope of the land a semibasementlevel car park is provided which gives rise to a six storey element along the Bank Streetelevation. The top floor of the building comprises a mansard roof that should read as beingsubservient and thus reduce its apparent massing and therefore, in townscape terms, itsrelationship with the adjacent four storey high St Andrew’s Court is not unacceptable. The groundfloor level of the building will comprise glazed ‘shop fronts’ serving the new dual aspectrestaurants and at the lower street level along Bank Street activity will be provided by acombination of residential entrance cores and corner restaurants as well as cycle and bin stores.The design approach to the building, which comprises a ‘u-shaped’ footprint, is such that it isdivided into vertical sections achieved through projecting brick frames that also ‘ground’ thebuilding and provide supporting columns to create a colonnade. The use of materials such astreated timber panels and glazing will provide a contemporary feel and the inward facing facadesare further articulated through the inclusion of modest projecting glazed balconies.Bank Street will also be realigned and resurfaced which will contribute to creating a more pleasantpedestrian environment and provide connections to the High Street. There are no flood riskconstraints in this immediate area which allows the inclusion of some active street level uses suchas restaurants, a hotel, residential apartments and entrances to provide vibrancy and activity.Buildings E02 and E03 respond to the topography of the site and gently step down in height fromsix storeys on Bank Street to four storeys closer to Crooked Lane. These buildings sit either sideof the stepped pedestrian access route running through the site and connecting the new MarketSquare space to the riverside, and the scale and separation of these buildings contributes todefining this new route. The architectural approach to these buildings utilises the stepped form toapply different elevational treatments including a predominance of brick but also some timbercladding and render. The incorporation of modestly projecting frames provides further articulationto the building facades and breaking up the massing.

In order to achieve the high quality development envisaged and promoted by the applicant acrossthe Eastern Quarter, which comprises a fundamental aspect of the proposal enshrined within theDesign and Access Statement, it is important that high quality materials are used and that anypressures of viability are not reasons to dilute that quality. As is standard procedure, if approvedthis matter will be conditioned to require approval of materials, including samples, prior to thecommencement of any works.Western QuarterThe buildings within the Western Quarter are submitted for outline approval, and consequently thearchitectural approach illustrated in the submitted plans is indicative only. Principally at thisjuncture the requirement in assessing this element of the scheme is to consider the scale, massingand siting of the proposed buildings – the submission of upper and lower parameter plansestablish the broad building envelopes and this is helpful in considering these matters.Furthermore, in response to Members concerns with the previous application where it wasconsidered that insufficient information was available through outline applications to aid a fullyinformed decision, the applicant has this time provided a greater level of information and theparameter plans now comprise reduced tolerances such that there would exist only minimal scopefor flexibility in the detailed design. This also negates the need for the previously discussed‘Bracknell condition’ which is regarded by officers as being positive.The Western Quarter proposals comprise four new buildings (W01, W02, W03 and W04).Principally these buildings line West Street and wrap around into Bath Street with spaces inbetween to create new pedestrian linkages and areas of public realm. Building W01 is locatedclosest to West Street opposite Melbourne Quay whilst the northern elevations of Buildings W02and W03 are staggered back to increase separation between the apartment blocks opposite -Regents Court and Marriott’s Wharf. The existing buildings on the north side of West Street rangein heights from three storeys up to seven storeys, albeit that much of the higher levels are set backalong the riverside – the immediate West Street frontages are generally three to four storeys and,from a pedestrian or motorists perspective, it is these frontage buildings that define the streetscene. By comparison, the heights of the proposed buildings along West Street range frombetween four and six storeys and the illustrative design suggests scope for subservient top floors,i.e. double mansard roofs on Building W03. It is the view of officers that the new buildings wouldsit comfortably within the street scene and, by introducing an appropriate relationship betweenbuilding heights and street width, are acceptable in townscape terms. The transformed WestStreet environment will also be characterised and improved by the incorporation of widerexpanses of pedestrian spaces that will be animated by high quality surface treatments as well asbeing visually softened through tree planting.The NPPF promotes active frontages and the use of streetscapes and buildings to createattractive and comfortable places to live, work and visit. Due primarily to flood risks the scope foractive uses at street level along West Street is limited and the suggested design approach isfurther constrained by the requirement to provide adequate car parking – the applicants illustrativeproposals suggest the extensive use of stone gabion walls (typically a retaining wall made ofstacked natural stone-filled wire cages) as a means of providing some interest at street level whilstalso comprising practical benefits such as ventilation to the car park. Such features are notcharacteristic of Gravesend and further to some concerns regarding their maintenance officers arenot entirely convinced by this possible approach. It is recognised though that some ‘active’elements have been incorporated at street level such as elongated residential entrance cores andsome service uses such as cycle stores, whilst the spaces and connections between buildings willprovide some visual relief from the buildings. If approved however this is an element of thedetailed design that officers consider would require further consideration by imposing a planningcondition.Setting aside Building W03 for the moment, the suggested design approach to the buildings

appears to be acceptable, and along West Street they incorporate a sense of transition from theold buildings in the High Street to a more contemporary approach further along, whilst retaining arelatively limited palette of materials formed primarily around a stock brick that is representative ofthe local vernacular. The use of timber cladding is also included to provide reference to many ofthe High Street buildings.The provision of an ‘elaborate’ stepped access to the new development from the western end ofWest Street will comprise a prominent element of the scheme and will provide a sense of arrival tothe town centre from the north-west as well as provide a degree of animation and activity. Aglazed entrance to the shopping centre is provided at the top of the steps connecting BuildingsW02 and W03.The height of Building W03 does not exceed six storeys along the West Street elevation but, at thepoint of the roundabout, it begins stepping up to its maximum point opposite Clifton Road where itrises to nine storeys. This element of the scheme has raised concern since the initial preapplicationstage and there is substantial local objection to its height. An amendment to remove anupper section of the building as it adjoins the existing shopping centre has been withdrawn.The applicant has stated that they consider this higher element of the scheme to be acceptable toprovide articulation to the ‘less sensitive’ Bath Street frontage as well as providing a long distanceframe for the Church. They also reference the height of the former hospital building (M Block)opposite and a precedent through the Clifton Slipways scheme nearby which has a resolution toapprove and rises up to ten storeys. The applicant also states that this height is required topreserve the financial viability of the project. Whilst it is not considered entirely appropriate to usethe un-attractive redundant hospital building opposite as a precedent, it is acknowledged that thescheme at Clifton Slipways rises to 10 storeys in height.In townscape terms the relatively expansive nature of Bath Street is such that it may suitablyaccommodate a building with significant height. In considering this issue it is felt that the indicativearchitectural treatment proposed does not provide the best elevational treatment. This view isshared by the South East Regional Design Panel (SERDP) who suggest that the elevationaltreatment emphasises rather than reduces the mass and bulk - particularly due to the glazedstairwell, vertical emphasis and double storey mansard roof – albeit that they state no objection inprinciple to the overall height in this part of the development.As well as the West Street and Bath Street street scenes, a principal objective of the presentscheme is to mark St George’s Church as the heart of the development and as such the characterof the ‘inside’ of the scheme is equally important to the ‘outside’. The following section coveringheritage considers the setting of the listed Church and the space that will be created by the newbuildings and, in short, recognises that increasing the separation between the Church and the newbuildings is successful in protecting its setting. It is the view of officers that a combination of newbuilt form to define this area and the incorporation of high quality public realm and active uses willcompletely transform the area in a wholly positive manner.Finally, Building W04 will provide a modest skin of residential development (15no. apartments) onthe rear of the existing shopping centre above the retained pedestrian ramp. This is regarded asan enhancement to the townscape of this area and will provide some interest and activity along apresently dull and unattractive façade, as well as introducing some natural surveillance byoverlooking the public space.HeritageThe application sites lie partly within the High Street Conservation Area and partly within theRiverside Conservation Area. Much of the application site, which primarily comprises open car

parking, is outside the designated boundaries but, due to their proximity, any redevelopmentshould be assessed against its impact upon the character and appearance of the ConservationAreas. In addition there are a number of listed buildings both within and adjacent to the applicationsites, including the Grade II* St George’s Church. The legislative basis for these assessments isset out in sections 66 and 72 of the Town and Country Planning (Listed Buildings andConservation Areas) Act 1990. These comments are informed by input from English Heritage andthe Borough Council’s Conservation Officer.Whilst applications that would affect listed buildings and conservation areas are not generallyconsidered in outline form, in this case the applicant has provided a sufficient level of detail onmatters such as scale and massing, as well as indicative public realm and suggested architecturaltreatments, to provide the decision maker with adequate information on which to base an informeddecision.The most significant heritage assets within the proposal areas are St George’s Church, the OldTown Hall and Town Pier, all being Grade II* Listed. There are also two further Grade II* Listedbuildings in the High Street (79 and 80), and a number of Grade II Listed buildings also in the HighStreet, as well as along West Street and Royal Pier Road. There are a number of locally listedbuildings and nineteenth century unlisted buildings that all make a contribution to the significanceof the area. The applicant’s heritage assessment has grouped the individual heritage assets forthe purposes of assessing their combined setting, informed by a consideration of the asset’ssignificance. This has also considered the setting on more distant Scheduled Ancient Monumentsat New Tavern Fort and Tilbury Fort. The application was advertised as having the potential toaffect the following listed buildings:Church of St George – Grade II*Statue of Princess Pocahontas – Grade II3 and 3a High Street – Grade IIThe Old Town Hall, High Street – Grade II*K6 Telephone Kiosks adjacent Old Town Hall, High Street – Grade II4 & 5 High Street – Grade II20 High Street – Grade II55 & 55a High Street – Grade II56 High Street – Grade II57 & 58 High Street – Grade II59 High Street – Grade II70 High Street – Grade II71 & 72 High Street – Grade II73 High Street – Grade II79 High Street – Grade II*80 High Street – Grade II*26 & 28 Queen Street – Grade IISt Andrews Arts Centre, Royal Pier Road - Grade II19 (The Mission House) Royal Pier Road - Grade II29 (Thames House) Royal Pier Road - Grade IIThe Royal Clarendon Hotel, Royal Pier Road - Grade IIThree Daws Public House – Grade IITown Pier - Grade II*2 (The Pier PH) & 3 Town Pier - Grade II96, 97 & 98 West Street - Grade II87 West Street (Public House) - Grade II44 West Street - Grade II45 (Hazards House & former Brewery offices) West Street - Grade IIThe impact of the proposals on the setting of Town Pier and the Old Town Hall is less immediate

than for St George’s Church, with the latter located at the heart of the Western Quarter proposals.The setting of this Church can be seen as its relationship to the wider town of Gravesend and theRiver Thames beyond. The Grade II Listed Statue of Princess Pocahontas stands within thechurchyard and may be considered as comprising a more contained setting.Members will recall that a previous application for development of this area was refused consent inpart due to the adverse impact upon the setting of the Church by reason of the height, bulk andmassing of the development. This is an aspect of the current scheme that has since evolvedsignificantly and now has the support of English Heritage, which is the statutory authority on suchmatters. The changes proposed essentially include enlarging the space around the Church bystepping away the inward facing elevations of the new buildings, as well as by stepping back theupper residential levels to provide further separation. As commented by English Heritage “theeastern face of the mall is pulled back significantly, thereby improving the relationship with thehistoric church by giving it a more respectful space in which to be seen and appreciated.”English Heritage comment further that the “suggested colonnade treatment at ground level at thisinterface is also likely to provide a more comfortable relationship between the scale of the modernretail development and the sensitive setting of the church.” A further positive element of theproposal is that the indicative public realm proposals now provide for not only the retention butalso the exposure of the historic western boundary wall of the churchyard that will emphasise theseparation between the tranquil churchyard and the new vibrant public space surrounding it. Inaddition, the principle that the new buildings are designed and orientated to face towards theChurch, thus making it the focus of the area, is entirely appropriate and in accordance with theDevelopment Brief which seeks to improve its setting. The demolition of the adjacent brickenclosed substation will further enhance the setting of the Church and will provide an attractivebackdrop to the enhanced amenity space proposed.Turning to views, when viewed from the River Thames the town’s skyline is generally defined byone strong and continuous horizontal line punctuated at intervals by the spires and towers ofpublic buildings, particularly churches. In conjunction with amendments to enhance the immediatesetting of St George’s Church, the applicant has also made considerable efforts through reducingthe mass and height of new buildings in both quarters to ensure that the Church spire is retainedas a principal element in that skyline. It is recognised that the proposals are particularly successfulin this regard as in views from the river the new buildings could be described as “cradling” theChurch spire and as commented by English Heritage “the visibility of the spire is not diminished forvirtually the whole panorama as one travels east to west along Gravesend Reach”.Although more immediate views of the Church spire from Clifton Road and The Terrace will beaffected, on balance English Heritage have accepted the loss which will in part be offset by thecreation of an enhanced view from within the St George’s shopping centre itself as the existingunit and canopy opposite Sports Direct is to be demolished as part of the proposals. It is alsonoted that the layout of the Western Quarter buildings provides for glimpsed views to be retainedand in some respects enhanced, particularly the approaches from the passenger ferry and theTown Pier.It is concluded therefore that the current proposal positively enhances the setting of the Grade II*Listed St George’s Church.A second reason for refusal of the previous application concerned the adverse impacts of theheight, bulk and massing of the development upon the character of the adjoining High StreetConservation Area. The significance for the setting of the listed High Street buildings is theirassociation with the High Street and the assessment here relates principally to the impact uponthe character and appearance of that Conservation Area. This consideration relates principally tothe Eastern Quarter built development proposals and has formed part of English Heritage’s remitfor comment. Although not objecting previously, English Heritage did note some concern about the

elationship in scale between the new buildings and the historic High Street, particularly in viewsfrom the riverside and the river itself. In acknowledging the modest changes to this quarter that“will help resolve the change in scale between the old town and the new build development”,English Heritage’s formal consultation response states that it will “facilitate a better townscaperelationship in longer views towards the town from the river, and will enhance the framing of viewsof the spire of St George’s Church from the east”.Furthermore, the siting and alignment of the new buildings themselves will not obstruct existingview towards the river from Queen Street that aid in connecting the town and the river. In fact thisis a view that will actually be improved by the scheme that includes the removal of some treesadjacent to Thames House that will be of benefit to the character and appearance of the HighStreet Conservation Area.Proportionately less emphasis has been placed on assessing the impact on the setting of the lesssignificant heritage assets within the area of the proposals. This is particularly the case in WestStreet and Queen Street but the replacement of open car parks with reinstated urban form thatthey were once associated with will be of benefit to their setting, as accepted by the BoroughCouncil’s Conservation Officer.Furthermore the proposals for St Andrews Gardens are indicative and do not anticipatedevelopment other than improvements to accessibility and attractiveness of the spaces so theimpact upon the setting of the Grade II listed St Andrews Arts Centre, The Mission House,Thames House and the Royal Clarendon Hotel should be nothing other than beneficial. Likewisethese improvement works will also ensure the character and appearance of the RiversideConservation Area will be preserved or enhanced.The applicant concludes that where the setting of a listed building is directly affected that thenature of the effect is generally beneficial, whereas those listed buildings located further awayexperience a largely neutral effect to their setting. It concludes further that effect of thedevelopment on the character and setting of built heritage assets in and around the applicationsite will be beneficial. These findings have been verified by the Borough Council’s ConservationOfficer and for reference purposes extracts of the applicant’s heritage assessment is includedwithin Appendix 4.As a final point, the protection of potentially significant buried heritage assets is an appropriateconsideration, as highlighted within the NPPF. English Heritage have highlighted the high potentialfor archaeology to be located beneath the application sites and this has been supported by initialdesk based assessments, and so it is important that appropriate field evaluation is carried out priorto any development commencing. Whilst pre-submission field works were encouraged toaccurately determine the presence and significance of any archaeology, it remains a matter thatcan sufficiently be safeguarded through a planning condition. This approach has been acceptedby the KCC Archaeological Officer to ensure that any significant archaeology is adequatelyprotected and the applicant has confirmed that such works will be carried out to inform the detaileddesign of the Western Quarter. It is commented further that this provides an opportunity for agreater understanding of the area’s history through archaeological investigation that would onlyrealistically take place as part of an extensive redevelopment such as when the original shoppingcentre was built in the 1980’s.Residential AmenityIn considering any proposals for development it is important to have regard to the impact that itmay have on adjoining buildings, which is most sensitive when it will cause harm to residentialamenity. It is also important to assess the quality of any new residential environments proposed toensure adequate living conditions for future residents.

Policies seeking to protect amenity and ensure acceptable future living conditions are included inthe Gravesham Local Plan First Review 1994. The NPPF also assists and seeks to ensuredevelopments will function well, do not undermine quality of life and create attractive andcomfortable places to live, work and visit and seeks to “secure high quality design and a goodstandard of amenity for all existing and future occupants of land and buildings”. The term ‘amenity’can encompass a number of factors and in the context of this application this assessment willfocus on the extent to which the proposal impacts upon the living conditions of the existingresidents in adjoining buildings and the standard of accommodation proposed for future residentswithin the proposed buildings.Impact of Development on Existing ResidentsA key issue in considering this application is the extent to which the new development – principallythe new buildings themselves but also the associated impacts such as vehicle movements – willimpact upon the living conditions of the adjoining residents. Whilst in most cases an inevitableconsequence of redeveloping a town centre location will be a detrimental impact upon somenearby residents, it is necessary to be able to ascertain the level of harm to resolve whether themerits of redevelopment outweigh the harm that may be caused.Members will recall that an earlier application for redevelopment of this area was refused with oneground relating to the height, bulk and massing of the development causing an adverse impactupon the adjoining residential and non-residential properties. There has also been a high level ofobjection from residents living in the flats along West Street and Queen Street concerned that theirliving conditions will be harmed by the development. This only serves to further highlight thesensitivity of this matter in considering this current application. It is though also appropriate to notehow the scheme has evolved in an attempt to respond to this previous reason for refusal.Daylight, Sunlight and Overshadowing - A significant potential impact will be a result of the newbuildings blocking daylight and sunlight to adjoining property. The application has beenaccompanied by a formal assessment on this matter and due to its sensitivity and complex naturethe Council commissioned an independent review – both of which were undertaken by experts inthis field. Following on-going dialogue an agreed position has now been resolved on technicalmatters such as the appropriate tests to use, the extent of surveying adjoining properties and thecriteria for assessing the results. This exercise was important to ensure that the tables of resultspresented had been independently verified.In the context of daylight and sunlight impacts on the existing residents, it is relevant to haveregard to opportunities for mitigating the impact. In responding to previous concerns the currentapplication incorporates stepping the proposed West Street buildings further away from theexisting flats as well as reducing their heights. Despite now reducing the massing, it was agreedby the experts that the only reasonable prospect of further mitigation would be to reduce theheights further. The applicant has declined to incorporate further reductions or setting back, andconsiders that such impacts are normal for an urban development. Other suggestions expectingthe existing residents to redecorate with lighter colours and/or alter their windows were agreed tobe unreasonable.The findings highlight Regents Court, Melbourne Quay and 88 West Street as being mostsignificantly affected by the Western Quarter buildings and St Andrews Court and the partlyimplemented residential development at the rear of 12-14 High Street as being most significantlyaffected by the Eastern Quarter buildings. A more detailed assessment will be provided within asupplementary report.Overlooking/Privacy – A further factor to consider in assessing residential amenity is the extentof overlooking that may be introduced by a proposed development, and the Borough Council’sresidential guidelines recommend a generic minimum distance of 21 metres for facing windows.

Whilst there are some ‘pinch points’ opposite St Andrews Court and Melbourne Quay, whereseparation is approximately 12 to 13 metres, in the context of a town centre location this is notconsidered to be unreasonable. Therefore, having regard to the proposed location of newbuildings and subsequent separation from existing buildings, it is generally concluded that theproposed development will not introduce unacceptable levels of overlooking to existing residentssurrounding the application site.Noise and Air Quality - The calculations carried out indicate the increase in road traffic on themain roads in 2018 on completion and occupation of the development will be less than 1dB(A)which is a negligible change. Whilst there are small predicted increases in noise at the vehicularentrance to the car park off the Bath Street roundabout and along the realigned Bank Street,having regard to existing noise levels and the increase being gradual over the course of thedevelopment the Borough Council’s Senior Environmental Health Officer is comfortable that theywill not introduce perceptible increases to existing residents. The accepted traffic flow predictionswhich indicate a slight reduction in traffic flow has the effect of producing a small decrease in roadtraffic noise on West Street itself where it runs in front of the existing flats. Whilst the significanceof this decrease in noise awareness terms is negligible, it must be stated it would usually beexpected with this type of town centre development for there to be an increase in traffic noise.In air quality terms the combination of reduced traffic flows and increased separation betweenbuildings on West Street (reducing the previous ‘canyon’ effect) are predicted to reduce pollutionlevels in that environment. The promotion of a Travel Plan designed to reduce reliance on theprivate car and provision of electric car charging points aim to further improve air quality. Althoughonly a modest improvement to noise and air quality, it is nonetheless reported as a beneficialimpact upon the amenity of existing residents in West Street.TV reception - The impact upon television reception is a less relevant consideration at this pointin time given the phasing out of analogue television broadcast as digital television is largelyunaffected by atmospheric conditions and does not suffer reflection effects and ‘ghosted’ imagegeneration caused by the presence of buildings. However as recognised in an assessment of thismatter as part of the previous application, there remains the potential for some modest mitigationto be required to avoid any disruption to radio, television and satellite reception in the vicinity of thesite. Whilst this impact will be reduced due to the generally reduced massing and heights of theproposed buildings, as accepted by the applicant it remains appropriate and necessary tocondition for pre-demolition and post-completion surveys to resolve if retrospective mitigation maybe required.Construction Impacts - Due to the size and nature of the proposed development, which ifapproved is programmed to take place over a four year period, it is also particularly relevant tohave regard to the impacts that construction works will have upon the amenity of the surroundingresidents. Whilst recognising that some impacts associated with construction works areunavoidable, it is necessary to consider appropriate mitigation to minimise those impacts, such ascontrolling working hours, timing for deliveries, routes for construction traffic and dust suppression.This will include approving the most appropriate means of foundation construction, which currentlydoes not anticipate impact piling. The applicant accepts that a Construction EnvironmentalManagement Plan will require approval by the Council in advance of any works commencing onsite, and this may be required through planning condition. The Port of London Authority advocatemaximising use of the River Thames for the import and export of materials and waste and thisoption, which if feasible will take construction vehicles off the local highway network, is supportedby the Council and should be considered by the applicant in devising a Plan.Due to the estimated length of the construction period, it is also considered appropriate andnecessary for the developer to agree with the Council the proposed siting and design of any sitehoarding.

Living Conditions for Future ResidentsIn considering proposals for new residential developments it falls within the remit of the planningsystem to ensure that adequate living standards for future occupants are achieved. The provisionof decent sized living accommodation can have a positive impact upon family life and the generalwellbeing of the occupants, provide spaces that are flexible and can be adapted to meet people’schanging needs such as working from home, and create an enhanced sense of social cohesion aspeople are more likely to ‘put down roots’ in the area. In designing accommodation that isattractive and ultimately meets the needs of the future residents, in addition to room sizes andamenity space it is also appropriate to consider ‘functional’ type provisions such as arrangementsfor refuse storage, clothes drying, internal storage and cycle storage.Room Sizes - A concern with the previous application related to the proportion of small onebedroom flats, of which the general perception is of being unattractive to future occupants andproviding poor living conditions. Whilst it is agreed that smaller units (one and two bedroom) canplay an important role within the housing market, an important factor relates to the spacestandards provided within the units.GBC Residential Layout Guidelines (1996) are adopted Supplementary Planning Guidance (SPG)and are the starting point for assessing room sizes and layouts. Saved Policy H2 of the adoptedLocal Plan requires the Council to have regard to these standards when considering proposals fornew residential development. Although now somewhat dated, reference to these standards isretained in the Proposed Submission Core Strategy. These standards do not however include aminimum standard for the relatively modern concept of ‘open plan’ living that is included within theapplication proposals, which combines living, dining and cooking provisions within a single space.As such, whilst reference to other recognised and more recent standards such as the LondonHousing Design Guide (LHDG) may be helpful for comparative purposes, Members are advisedthat decisions should be based on the Borough Council’s adopted guidelines. In advisingdevelopers on the local standard for open plan living spaces the consistent and reasonableapproach of the LPA is to amalgamate a kitchen/diner and a lounge (or indeed a lounge/diner anda kitchen) to arrive at the recommended floor area of 25.2sqm, albeit that a slightly smaller spaceis not inappropriate for a one bedroom unit (say 23sqm in accordance with the LHDG standard).It is on this basis that the scheme has been assessed and since only the Eastern Quarter isdetailed the focus has been on the apartments proposed for that quarter. If outline approval isgranted the detailed Western Quarter units would be subject to similar scrutiny at a later date.As highlighted by the majority of local residents in opposing the scheme, however, the originallysubmitted plans raised significant concerns over the standard of the accommodation proposed, aview supported by an officer assessment highlighting that approximately 60% of the open planliving spaces fell below adopted GBC standards. Whilst it is appropriate for a large scaleresidential development to comprise a mix of unit types and sizes (in part to avoid flooding themarket with identical apartments but ultimately to provide for a mixed and balanced community)the number of substandard living spaces was considered unacceptable and the applicant wasrequested to amend the plans.The applicant has responded positively to the concerns of officers and local residents, and hasundertaken a thorough exercise of reviewing the room sizes and ultimately changing the internalarrangement to increase the size of the spaces proposed. Whilst the individual unit sizes andoverall flat numbers remain unchanged, the amendments secured have included (i) removing orreducing some of the second bathrooms, (ii) replacing some double bedrooms with singles and (iii)reducing corridor and hallway widths. The reduction in designed occupancy levels will also placeless pressure on the living spaces and assist in providing adequate and functional areas for theresidents. Whilst accommodation in the Western Quarter is not subject to detailed approval at thisstage, the applicant has however provided amended examples of typical units to suitably

demonstrate that the broad quantum of apartments proposed will not be at the expense ofundersized and substandard internal spaces.The outcome of this exercise has been particularly positive and the updated floor plans now fullycomply with the adopted GBC Residential Layout Guidelines in respect of room sizes. This hasadequately overcome previous concerns regarding undersized rooms and, in addition, it isrelevant to note that almost one third of the proposed living spaces within the Eastern Quarterapartments are notably in excess of the minimum standard. Furthermore, a detailed assessmenthas confirmed that the new apartments will experience adequate daylight and sunlight conditions.Whilst the internal changes proposed reduce the number of units that meet the Lifetime Homescriteria, the Eastern Quarter still includes over half of the units designed to this standard, whichremains far in excess of the proportion included in most developments in the Borough. Storagespace is also a relevant consideration when assessing new apartments and the proposed schemedoes include some modest provision within most of the units to facilitate storage of basic domesticequipment such as ironing boards and a vacuum cleaners. However the absence of localstandards on this matter prevents a more formal assessment.Residential Amenity Space - An assessment carried out by the applicant demonstrates thatadequate private and semi-private amenity space to meet the needs of the new residents will beprovided. Amenity space for the new residents is provided through a combination of privatebalconies and communal gardens. Acceptable noise levels within these spaces will be providedthrough screening from the new buildings and, where necessary, incorporation of solid balustradesenclosing balconies.Within the Eastern Quarter 60 of the 141 apartments will have a private balcony (5 sqm), whilst aproportion of those without such provision will have access to semi-private residential gardenseither side of the pedestrian link through the site. This level of provision is considered appropriatefor a town centre development where the new residents will be able to utilise enhanced publicspaces within the immediate vicinity and whereby the incorporation of large gardens and morebalconies (i.e. facing towards St Andrews Court) will likely lead to unacceptable overlooking ofexisting and future residents.Within the Western Quarter the direct amenity needs of the future residents will be provided withincommunal roof gardens, most notably above the new retail units. This communal space will besouth facing and should therefore afford the residents with an attractive amenity provision, albeitfull details will be required through reserved matters to include considerations regardinglandscaping, privacy and security.Refuse Storage - The proposed arrangements for bin storage are that each floor will have adedicated and ventilated area for convenient use by individual residents, but that at regularintervals the management company will transfer the refuse sacks to the larger communal storageareas at street level for ease of collection. As well as being convenient for residents, this has theadded benefit of enabling the principal bin stores to be secured to prevent opportunities for crimeand antisocial behaviour that are associated with unauthorised access to such areas, ashighlighted by Kent Police.Following consultation with the Borough Council’s Operational Services Manager comfort isprovided in that a sufficient quantum of storage space is provided to accommodate the anticipatedquantity of domestic refuse that will be generated by the development. Subject to satisfactoryarrangements for management of the buildings, to be secured through a s.106 Agreement, thisprovides an appropriate means for dealing with refuse and should ensure that amenity is notundermined by the inconsiderate dumping of rubbish. Because the council is increasing andchanging its recycling and refuse collection arrangements, the details of the bin storage areasshould be reserved for subsequent approval, by a planning condition.

Air Quality - As described previously, the slight reduction in traffic flows along West Street,coupled with the ‘canyon’ effect being designed out of the scheme, will reduce pollution levelsalong this stretch of the one way system. In order to protect the amenity of the new residents it hasbeen identified that the only apartments across both quarters that will require mechanicalventilation are those in the West Street facing facades of Buildings W01 and W02. This is positiveas the inclusion of such mitigation is not desirable and should only be incorporated where it isnecessary. For clarification, mitigation is not required in other apartments due principally to theirset back from the highway and their location above street level.However, through agreement with the applicant the few new apartments directly above the carpark entrance to Building W03 should also include mechanical ventilation to mitigate the combinedeffects of noise from cars travelling below and associated direct vehicle fumes. This is considerednecessary by the Borough Council’s environmental health officers for general amenity purposesrather than an explicit air quality requirement. This may be safeguarded through planningcondition, but ultimately it may be that the applicant omits these units from the detailed scheme.Noise – The mitigation proposed within the new residential apartments will ensure ‘good’ internalnoise levels from external factors such as traffic noise - the ‘good’ standard represents noisewhere it is possible to comfortably relax and sleep without disturbance from externalenvironmental noise. In addition, the Borough Council’s Senior Environmental Health Officeraccepts the applicant’s report that potential noise from the non-residential uses and plant may beadequately mitigated through the new construction itself. Assurance on these matters will beprovided through a planning condition committing the developer to satisfy recognised standards.The approval of a Servicing Management Plan will control delivery hours for heavy goods vehiclesto avoid early morning or late night deliveries.Wind - This has been tested and subject to mitigation such as inclusion of recessed entrances tosome buildings and planting to provide some shelter, the layout and massing of the buildingswould not exacerbate wind conditions experienced by pedestrians.Substations - The inclusion of electricity substations within new developments, particularly wherethey are in close proximity to existing or new residential properties, can raise concerns over healthrisks from perceived electromagnetic radiation, as well as noise. The applicant has confirmed thatthe substations will be encased with adequate screening to prevent the emission of any radiationand attenuate the “humming” noise to ensure an acceptable and safe living environment. Ifapproved, further details should be required through condition, including an Electromagnetic FieldStudy as part of the detailed design stage as accepted by the Borough Council’s SeniorEnvironmental Health Officer.Impacts on Existing Non-Residential BuildingsIn addition to considering impacts upon adjacent residential property, it is also necessary to haveregard to the impact of the new development on non-residential buildings. In particular impactsupon the Gravesend Medical Centre were a factor in the previous application being unsuccessfuland similar concerns have again been expressed by the landlord/occupant regarding loss of lightto the waiting room as well as loss of privacy to the top floor community room. The daylightassessment concludes that some sunlight and natural light would be reduced to the front of thebuilding and this will detrimentally impact mainly upon the patients waiting area. The majority ofthe rooms tested do however meet the recommended levels, including the top floorcommunity/consultation room where users may consider natural light to be more important. Theuse of task lighting in commercial buildings is a common and not unreasonable requirement so it isconcluded that the impact upon the Gravesend Medical Centre due to some lost daylight/sunlightis not overriding in the context of this application. Similarly, whilst the new development will placesome residential development adjacent to it, the hours of use combined with the separation

distance suggests that this will not significantly compromise the function of the top floor communityspace, which in any event the occupant explains is used infrequently at present.The assessment does however confirm that daylight and sunlight levels to other nearby buildingssuch as St Andrews Arts Centre and the The George Inn will still meet recognised levels followingdevelopment. The applicant also considered the impact upon St George’s Church which resolvedthat the space around and orientation will ensure no loss of light.Open Space, Public Realm and PermeabilityDue to the town centre location of the application site any existing and proposed open space willbe placed under increasing pressure from the increased resident population as well as by visitorsto the retail, tourism, commercial and other facilities within the Town Centre so pressures for openspace will only increase over time. Good quality open spaces and public realm also encouragepeople to stay for longer in an area, which would contribute further to the Town’s daytime andnight time economy. The NPPF recognises that access to high quality open spaces andopportunities for sport and recreation can make an important contribution to the health and wellbeingof communities.In considering this matter it is relevant to have regard to the on-site provision of open space andpublic realm that will be intrinsic to the success and usability of the development, but also to thepressure that will be placed on existing formal leisure provision by the increased residentpopulation.Open Space and Public Realm StrategyTaking on-site provision first, as recognised by the independent design panel (SERDP) prior toapplication submission, the design of the public realm has significantly improved from the previousapplication which is due in large part due to the involvement of an urban designer who hasbrought to life the hard and soft landscaping proposals, albeit that they remain indicative at thisstage. It is also recognised by English Heritage that the landscaping proposals have been greatlyimproved from the earlier scheme. English Heritage state that the consistent treatment ofmaterials and furnishings through the two quarters, although modern retain resonance with thetraditional materials of the Town, and is appropriate.In terms of on-site open space the development proposals comprise three core areas – ChurchGardens, Market Square and St Andrews Gardens. Whilst St Andrews Gardens and the ChurchGardens are essentially to remain similar to existing in terms of their size, their quality is to beimproved, such as through the demolition of an existing electricity substation and re-gradinglevels. Also, the existing covered area within the Market Square car park will be replaced with theMarket Square public space that will comprise a larger, more vibrant and better connected publicspace.Qualitative improvements will include (i) works to upgrade St Andrews Gardens, (ii) connectingMarket Square with the Borough Market, and (iii) demolishing the electricity substation on PrincesStreet to open up the existing space to increase and enhance the sense of openness and usabilityof the area. The indicative proposals for St Andrews Gardens are an elaborate urban designresponse. It is considered that the space should retain its green appearance to provide flexibilityover its use and also avoid an overprovision of ‘civic space’, particularly in view of the new MarketSquare proposed and indeed the recent Community Square at the Civic Centre forecourt.Therefore the detailed design should be reserved by planning condition.The public realm improvement works extend to upgrading of a stretch of the existing river walk,envisaged to comprise improvements to lighting and surface treatments. A comment has beenmade by a local resident complaining that the existing walk is dark, damp and poorly maintained

so improvements to this area will be a recognized local benefit. This should also complement theobjective of improving connections between the Town and the River.As an aside, although the Development Agreement is not a planning consideration, it isconsidered relevant to note that it commits EHEL to spend a significant sum of money (c.£4,300,000) on the public realm as part of the scheme. This provides comfort that the open spaceand public realm will be of high quality and possibly greater than may otherwise be securedthrough granting of a planning permission for this site. In any event, the detailed landscapingproposals, which will include soft and hard treatments, will be controlled through planningcondition to safeguard the quality promoted as an intrinsic aspect of this application.PermeabilityThe gain in other open space across the site essentially stems from the removal of the existingsurface car parks and provision of new pedestrian circulation areas which create ‘secondaryspaces’, such as Princes Square and St Georges Square. These spaces will provide significantlyimproved pedestrian connections and public realm within the site, principally enhancing links toand from the River that will benefit from traffic calming and additional pedestrian crossings onWest Street and Crooked Lane. Although indicative at this stage there are some unresolvedqueries with how the re-aligned Princes Street levels will work due to the presence of the semibasementcar park beneath Building W01, the extent of which will be roughly fixed through anoutline approval – further details will be provided in a supplementary report. This relates back toone of the originally identified objectives in the Development Brief which is to provide improvedaccessibility through a framework of routes and spaces. The promotion of pedestrian links to StAndrews Gardens is also welcomed.Good permeability is essential to encourage links to and from the town centre so that the proposeddevelopment is seen as an integrated extension to it rather than a separate and isolated area. Tothis end both the retention of the existing ramp (connecting the shopping centre to the High Streetvia Jury Lane) and the physical opening up of the shopping centre (by removing an existing retailunit and part of the canopy), are welcomed. The previous scheme closed off the ramp and so itsretention as part of the present proposal is positive and should assist in encouraging pedestrianmovement along and across the High Street as people move between the new quarters. Also, theconnection from the existing shopping centre appears to be successfully worked and the openingup of views of the Church in longer vistas (i.e. from the route past Argos and Boots) will aidlegibility and encourage people to the area as well as provide an attractive circulation area andshopping experience. Likewise, the provision of a pedestrian link between Buildings W01 andW02, leading towards the existing passenger ferry terminal will provide an improved pedestrianlink as well as provide some activity along West Street.Also, as recommended by English Heritage, the retention of historic surfaces, such as the settedsurface of the alleys running off the High Street, should be retained to reinforce the connectionbetween new and old quarters and encourage people to explore them. The scheme will alsoinclude an integrated signage strategy to assist identifying pedestrian routes and the location offeatures of interest.An objective of the Development Brief is to enhance the urban grain of the town and it has beensuggested by the SERDP that spaces between buildings could be made narrower to moreaccurately reflect the fine grain of the historic Town. Whilst on one hand there would be benefits toenlarging the footprint of the new buildings since it would more closely recreate the historic grainof the town and even enable a reduction in overall building heights to further mitigate impactsupon existing residents, the desire for increasing public realm and open space to overcome aprevious reason for refusal is overriding. Furthermore, the inclusion of narrow spaces betweenbuildings along new and existing routes would introduce privacy conflicts for upper residentialapartments that face each other.

Public Safety and MaintenanceThrough a combination of improved public spaces and the inclusion of a mix of vibrant daytimeand evening uses, the development should contribute to improving the sense of safety in the area.Whilst there has been some concern from local residents regarding the development potentiallyincreasing the risk of crime, it is considered that the redevelopment of existing surface car parkswith attractive buildings that define well lit and overlooked public spaces that will create a safe andaccessible environment.In order to ensure the long term maintenance of the public spaces it will be necessary to ensurethat an acceptable management regime is put into place, including clearly establishing who will beresponsible for implementing it. It is envisaged that this will be dealt with through a planningcondition, but in brief summary the principle will be that the Council will retain responsibility for StAndrews Gardens, KCC will retain the highway, the Church will retain the churchyard whilst thedeveloper will set up a private management company to maintain the remaining public realm.In addition, in designing the details of the landscaping proposals at St Andrews Gardens, carefulattention will be required to ensure it will be complementary to the character and appearance ofthe two conservation areas within which it is located, and will also need to have regard toconstraints imposed by small parcels of land with Village Green status. There will however remainsufficient flexibility for fresh design ideas to be considered, such as the inclusion of artifactsoffered by the Port of London Authority to act as public art. Given that the responsibility ofmaintaining this area will remain with the Council, it will also be necessary to consider the costimplications of maintaining the enhanced gardens when a detailed design is progressed.TreesIn considering the overall open space and public realm proposals, it is appropriate to have regardto the contribution that trees make to an area, not only in softening the urban environment andtheir amenity value but also providing shade for people in the summer . A detailed tree survey hasbeen undertaken to accompany the application which indicates that 107 trees may require removaland that 148 new trees will be planted. Whilst none of the trees within the application site aresubject to Tree Preservation Orders, around half of them lie within designated conservation areaswhereby they are afforded a degree of protection – namely that Council approval is required tocarry out works to them.In total 37 no of the trees to be felled are within conservation areas, a number of which are trees inpoor condition by the substation in Princes Street and whose removal is recognised as enhancingthe openness and usability of that area. The remaining conservation area trees lie within StAndrews Gardens and following concerns over the extent of tree removal here the applicant hasaccepted that the detailed landscaping scheme should seek to retain some more trees, particularlysome of those adjacent to Thames House to protect residential privacy whilst still ‘framing’ viewsof the river from Queen Street. A focus for enhancement of these gardens however will be regradingit to improve access and so it is inevitable that some trees will need to be felled.Outside of the conservation areas, whilst it is unfortunate that the established avenue of Mapletrees along Bath Street will be removed, the development will retain sufficient breathing spacealongside the building to allow the highway verge to be re-planted with semi-mature trees. It ishowever positive that one of the large London Plane trees by the Blockbuster site is beingretained, particularly as its amenity value has been highlighted by a qualified arboriculturalist.The proposals include for a net increase in the number of trees across the application sites andthese will include lining the streets as well as planting ‘feature’ trees designed to complement thenew spaces to be created. The applicant confirms that the new trees will be semi-mature upon

planting which is hoped will strike the appropriate balance between providing an immediateamenity benefit and maintaining the health of the tree to ensure an appropriate long term solution.Furthermore the applicant confirms that no problems are envisaged in sourcing good qualityspecies of the sizes proposed. In considering the detailed soft landscaping scheme it will also benecessary to have regard to matters such as coordination with the CCTV system and selectingspecies that do not cause maintenance problems or attract unwanted insects that maycompromise the public realm or deter people using spaces.SummaryAs a point of clarification to Members, whilst all the landscaping and public realm proposals areonly indicative at this stage, a mechanism exists within the planning framework (Circular 01/2006)to fix the broad design rationale that is set out in a Design and Access Statement. This shouldprovide comfort in considering these matters as a legitimate planning condition may be imposed toensure that the high quality public realm and landscaping proposals will not be compromised atthe detailed design stage.In summary officers are in support of the applicant’s approach to upgrading existing open spacesand enhancing public realm as a means of addressing additional pressures that will be put onthese town centre spaces through demand anticipated from additional shoppers, residents andvisitors. Despite the adopted Local Plan 1994 including a policy promoting the West Street carpark as a major landscaped public space, present Government pressures to make the mostefficient use of sustainably located sites, coupled with constraints of viability and the benefits of acomprehensive mixed use development in this location as promoted by emerging Council policy,the strategy adopted by the applicant is considered to be appropriate and acceptable. The spacesand connections between buildings are also considered to be appropriate to realise objectives ofthe scheme such as promoting pedestrian movements to the river and encouraging the cross flowof people along and through the High Street. The impact of the scheme on existing trees, whilstrequiring review in St Andrews Gardens, is not regarded as being significant as any negativeimpacts will be outweighed by benefits of the proposed landscaping proposals which willcomplement the overall development layout and function.Formal Leisure ProvisionThe provision of high quality and accessible leisure facilities in the Borough is essential toimproving the health, community cohesion, prosperity and wellbeing of its residents. Although thedevelopment itself will provide for enhanced open space and additional public realm, which isrecognised and which in itself will afford residents and visitors with some informal recreationalopportunities, the application also needs to respond to the more formal provisions as highlightedby Sport England. The approach promoted by officers is to secure a financial contribution towardsthe upgrading of existing local sporting facilities located within a reasonable distance of theapplication site, such that it will be directly related to the development and will contribute tooffsetting the impact of the increased population. This is in accordance with Policy CS13 of theProposed Submission Core Strategy and GBC Leisure Services have identified some projects thatthe development could contribute towards, including:• Replacing the artificial pitch at Gravesend Rugby Club which is the only such pitch in theBorough and which is available for use by hockey and football clubs;• Improvements to the pool hall and associated pipework, as well as providing an enlarged gymand on site car parking, at Cygnet Leisure Centre;• Expansion and upgrading of existing allotments.The outcome of discussions on this matter will would be incorporated in a s106 agreement..

Highways and Car ParkingCar ParkingA significant proportion of the application site comprises existing surface car parks andsubsequently an inevitable consequence of redevelopment will be the partial/complete loss ofthese existing facilities. At present the existing car parks provide a total of 654 short-stay publiccar parking spaces across the following car parks:• West Street - 76 spaces• Market Square - 121 spaces• Horn Yard - 85 spaces• St Georges Centre - 372 spacesThe proposed development will completely redevelop the West Street, Market Square and HornYard car parks, but will only result in the loss of the open parking element of the St George’s carpark (49 spaces) – the result being a loss of 331 existing short-stay public car parking spaces.However, the parking needs of the new development will be provided on site within the twoquarters and will total 650 spaces, which is a quantum accepted by KCC Highways followingdetailed pre-application discussions and having regard to the sustainable and well-connected towncentre location. This provision includes 264 public spaces, split roughly equally across the twoquarters, and 386 private allocated spaces to provide one space for each residential unit and onefor each hotel room.This loss of existing public car parking has been highlighted as one of the principal concerns fromlocal residents and some local businesses. However, with the retention of the existing St George’smulti-storey car park (323 spaces), upon completion there will remain a total of some 587 publiccar parking spaces available for use by shoppers, workers and visitors across both quarters – anet loss ‘on the ground’ of 68 public spaces, which may be justified as representing little over 10%of the existing public parking. It should be noted however that this post-development public carparking will be subject to the additional demands of the new uses, but the point should also bemade that it will be available for use by all existing users and, following updating of the existingreal-time car parking signage system around the Town to be funded by the developer, it is onlywhen these spaces are fully occupied that users will have to park elsewhere.As a late change to the scheme, the applicant has included the provision of an additional 5no.open car parking spaces on the land to the immediate south of the Gravesend Medical Centre,and confirmed that they will provided and made available solely for use in connection with thatfacility. This responds to concerns expressed by the Medical Centre regarding the loss of existingstaff and disabled patient car parking and the importance that they are re-provided in appropriatelocations.Whilst the applicant identifies surplus provision in existing public car parks at Lord Street andParrock Street to offset the overall loss of existing public parking spaces, the Council has takenthe view that it is not acceptable to wholly rely on existing provision which may or may not beretained for such purposes in the long term. In forming this stance regard has been taken to thefact that the provision at Lord Street is only temporary and cannot currently be relied upon in thelong term and furthermore that a combination of development pressures has the potential to addfurther strain to existing provisions, including potential loss of existing spaces through schemessuch as the Rathmore Road link. In addition, due to their peripheral location, existing car parkssuch as the Gurdwara and Milton Place may not be regarded as appropriate car parks in which toprovide for short-stay Town Centre car parking.The principle has therefore been agreed between the applicant and the Council that a financialcontribution will be paid to the Council to enable the longer term re-provision of public parking

elsewhere within the Town – with potential options being a more formal and permanent surfacecar park at Lord Street or indeed a new multi storey car parking at Lord Street that may free upParrock Street for an alternative use. The agreed financial contribution will be secured through as106 legal agreement, with payment to be phased and subject to agreed triggers and the moneywill be ring fenced for the provision of future car parking in the town.In order to mitigate the impacts of lost public parking during the construction phases, which couldhave a particular impact upon local businesses, a planning condition will require approval of a planto sensitively manage the temporary loss of parking as despite some surplus short-stay parking inParrock Street it remains desirable to retain a supply of conveniently located public parking duringthe interim construction period.Traffic FlowsThe displacement of some public parking to the south of the town is considered to have a numberof potential benefits, including actually reducing the number of vehicle movements along WestStreet at certain times of the day, principally as motorists visiting from the south may not need toenter the one way system to find convenient town centre public car parking. Despite much localrepresentation to the contrary, this unexpected result has been verified by KCC Highways. It isalso relevant to highlight that the traffic modelling has had regard to the predicted impacts ofapproved schemes such as the Transport Quarter and Albion Quayside, and hence consideredthe potential longer term impacts on the highway network.Whilst it is possible that in some instances this relocated parking will require a greater walkingdistance to the users’ final destination, the key requirement is the availability of town centre carparking to which users will adapt. In the context of the new retail floorspace being proposed, thisparking displacement may actually have the beneficial impact on smaller businesses of increasedfootfall through the existing town centre as people walk to the new shops. Notwithstanding theabove, whilst there will be a net loss of public parking to the north side of the town (587 rather thanthe existing 654) the majority of those remaining will be covered spaces within a controlled,managed and fully staffed facility that may actually make them more attractive to users than theexisting open car parks. As encouraged by Kent Police, the developer should consider achieving‘Park Mark’ status for its parking facilities, which will provide confidence to its users thatappropriate measures have been put in place to deter crime and anti-social behaviour.Whilst a concern of some local residents is that this proposal will exacerbate traffic congestion andassociated impacts along West Street, KCC Highways have verified the traffic modelling whichdoes predict a reduction in traffic flows along West Street in the evening peak hour (5 to 6pm),principally due to the displacement of some public car parking to the south of the Town. Whilst aknock on impact of this will see increased vehicle movements around the southern part of the onewaysystem, such increases are generally less than 10% of total flows and so it is concluded byKCC Highways that it would not be sufficient to cause serious congestion. The traffic modellingalso shows that vehicle flows along West Street will remain similar to the existing within themorning peak hour (8 to 9am), with the only increases in the immediate vicinity being the stretchalong Crooked Lane, a result of new residents of the EQ buildings leaving for work/school in themorning.The displacement of existing parking, rather than re-provision on site by the developer, alsoreduces overall development costs and subsequently has enabled the overall scale and massingof the development to be reduced when compared with the previous unsuccessful proposal.Despite concerns over scale and massing remaining from various local residents, there seems tobe a common appreciation that the current scheme has moved on positively from the last schemeand this is in part to the reduction of on-site car parking levels. Whilst there would be obviousbenefits to the townscape if on site car parking provision was reduced further - such as removingsome of the dead frontages at street level along West Street - the loss of such provision would risk

deterring shoppers and other visitors. In considering this point the added constraint imposed byflood risk would in any case limit the uses that may be appropriate at street level.In terms of the residential car parking, whilst communal provision is most efficient and avoidsunderused spaces, the applicant has taken the understandable view that market demand is forallocated parking. To avoid a situation whereby car free households result in empty spaces whenthere is perhaps demand from other residents with more than one car (as occurs locally at theBaltic Wharf development) an active car parking management strategy will be necessary. It isenvisaged that this would be operated by the residential management company and would enableresidents to lease unoccupied spaces - if approved this could be secured through planningcondition, as accepted by KCC Highways. The applicant has also committed to the provision ofelectric car charging infrastructure within the residential car parks to future proof the development,and this is regarded as a positive and highly sustainable measure.It is relevant to note that the private car parking within the Western Quarter makes provision forreplacement car parking for the White Hart Yard properties (26 spaces).Overall, it is considered by officers that the approach to the provision of car parking is acceptableand strikes an appropriate balance between on-site car parking to meet the needs of thedevelopment whilst retaining provision of an adequate supply of conveniently located public towncentre parking.Highway Improvement WorksIn addition to the provision of on-site car parking to meet the needs of the new development and afinancial contribution to enable re-provision of the public spaces to be built upon, the proposal alsoincludes a package of physical highway improvement works designed to not only to minimise theimpact of the development on the highway network but also to meet an overarching objective ofthe development which is to encourage pedestrian movements to and from the river.The principal works proposed relate to creation of a more pedestrian friendly West Street byadopting a ‘semi shared surface’ approach which incorporates raised sections of carriagewaydesigned to reduce vehicle speeds to 20mph. The provision of five pedestrian crossing pointsalong West Street and Crooked Lane, coupled with enhanced surface treatments and a reductionin width of West Street to a single lane, should help reduce the severance effect of the one-waysystem and encourage pedestrian movements across it, particularly to and from the Town Pierand St Andrews Gardens, as well as the Gravesend Riverside Gardens further afield.Furthermore, the previously proposed bus lane has now been omitted from the scheme and thatwill further lessen the dominance of the highway and encourage safe pedestrian crossing. Thispedestrian friendly approach was welcomed by the SERDP and the retention of modest kerbupstands has been included to satisfy concerns of the Gravesham Access Group.The scheme designs in provision for a three metre wide dedicated cycle and pedestrian route fromBath Street to Royal Pier Road running along West Street and linking through St AndrewsGardens, which will constitute an enhancement to the existing National Cycle Route 1.The highway works are not submitted for detailed approval and therefore represent an indicativescheme at this juncture, however they have been subject to an initial safety audit and KCCHighways are satisfied with the principle of the works and that the detailed design stage can dealwith any issues, such as suitably accommodating vehicle, cycle and pedestrian movements andthe required modifications to the Bath Street roundabout approach to reduce vehicle speeds.As part of a further measure to encourage sustainable travel, which the NPPF stronglyencourages, in addition to an enhanced cycle route and future-proofing for electric chargingpoints, the applicant will prepare a Travel Plan that will include a travel pack to all new residents.

Servicing and DeliveriesThe NPPF advises that developments should be located and designed wherever practicable toaccommodate the efficient delivery of goods and supplies, and this is particularly relevant in thecontext of a town centre redevelopment where unsatisfactory arrangements would be likely to leadto disruption and inconvenience to a number of people and services and compromise the day today operation of the new development.The principal requirement for servicing will be deliveries to the new retail units and the applicanthas confirmed that delivery lorries will utilise the existing service bays off Bath Street. This areawill also be used for much of the commercial and residential refuse collections, with the appointedmanagement company being responsible for transferring the domestic waste from individualstores to the collection point. Elsewhere within the development, where such servicingrequirements will be significantly less, provisions have been designed in to enable delivery andrefuse vehicles to safely pull off the one-way system to carry out their function without detriment tothe safe and free flow of traffic. For example, access to the public space around the church yardwill be controlled by barriers that may be lowered to enable service vehicles to enter temporarily,and this will again be managed by the site based management company. This would includearrangements for bulky domestic deliveries as well as official vehicles using the Church. BankStreet will be utilised within the Eastern Quarter for the same purposes.Whilst such requirements will be explored in further detail as part of the highway and public realmworks, having regard to the anticipated servicing requirements the scheme demonstrates sufficientflexibility to adequately accommodate them in a safe, practicable and efficient manner.EconomyAs highlighted in the NPPF, concurrent with the Government’s ‘pro-growth’ agenda, “theGovernment is committed to ensuring that the planning system does everything it can to supportsustainable economic growth. Planning should operate to encourage and not act as animpediment to sustainable growth. Therefore significant weight should be placed on the need tosupport economic growth through the planning system.” A major town centre redevelopment, suchas that currently proposed, represents a significant opportunity to provide employmentopportunities in the area and accordingly significant weight should be afforded to the economicbenefits of the proposed development in determining this application.The mix of uses proposed as part of the present development proposals, including the retail,office, hotel and restaurants, would generate a significant number of direct job opportunities,estimated to be in the region of between 729 and 831 (full time equivalent). In addition to thesepermanent jobs the development will also create over 1000 temporary construction related jobs.The applicant has also publicly committed to establishing initiatives to give local firms anadvantage when tendering for construction contracts, referred to as the Local Firms TrainingPledge. Whilst not guaranteeing contracts for local companies it will give them an advantage overothers. The intention is also to provide opportunities for a significant number of local training andapprenticeships, including working alongside North West Kent College, the Council and localbusinesses. It has been agreed with the applicant that a firmer commitment to this may be securedthrough the s.106 Agreement.In addition to the creation of actual jobs, the investment in enhanced public realm and the creationof new squares and spaces should provide an improved experience for shoppers, visitors andresidents alike to encourage them to spend more time in the town and ultimately spend theirmoney here, thus contributing further to the local economy. The layout of buildings and improvedpedestrian links should also strengthen the relationship between the town and the river which

should help to build on the town’s history and attract visitors. The significant role that the provisionof a hub of restaurants within the Eastern Quarter can play in stimulating the evening economyand attracting families to the town is also recognised and welcomed. The provision of a hotel canalso play a positive role in drawing additional visits.Flood Risk and Surface Water DrainageWhilst much of the application site is sufficiently elevated to ensure no risk of tidal flooding fromthe River Thames, the northern parts of the site, particularly along West Street, rely on existingflood defences to afford adequate protection. Since the objectives of the development could not beachieved if it was sited elsewhere, officers are satisfied that the requirements of the sequential testare met; and furthermore that the exception test is met since the land is previously developed andthe scheme will generate sustainability and regenerative benefits. The key test is therefore that thedevelopment is safe.The existing flood defences are sufficient to protect the sites from a 1 in 1,000 year flood eventand therefore only St Andrews Gardens, which lies on the river side of the defence and comprisesonly landscaping proposals, would experience tidal flooding from anything other than an extremeflooding event.However, given the importance afforded to protecting human life it is necessary to consider thepotential effects of an actual breach in the defences coinciding with an extreme flood, and theproposed development therefore excludes vulnerable uses at street level along West Street as aresponse to this constraint by proposing car parking as a practical design solution.The Environment Agency has accepted that the floor levels of the proposed residential and retailelements of the scheme (at not less than 7.0m AOD) would ensure they remain adequatelyprotected and subsequently that their users would not be at risk from tidal flooding. However theenclosed parking along West Street may experience flooding, but this risk can be adequatelymitigated through a Flood Management Plan, which will ensure that the developer signs up to theEnvironment Agency’s flood warning system and provides suitable safe escape routes.In the unlikely event of a flood, the impacts will also be mitigated by the incorporation of floodresilient design techniques and materials and the above matters can all be sufficientlysafeguarded through planning conditions.Impacts of flooding are not solely restricted to tidal flooding though, as surface water flooding canoccur if adequate drainage is not incorporated into new developments which can undermine thefunctionality and accessibility of a development, as well as increase the risk of flooding elsewhere.This is particularly relevant in the context of climate change and within urban environment where asignificant amount of hardstanding exists. Furthermore Southern Water Services have advisedthat there is currently inadequate capacity in the local network to serve the proposed development.The applicant has therefore prepared a drainage strategy for the application site which principallyincorporates permeable paving to direct surface water in to underground attenuation tanks whichwill in turn control run-off rates of water and avoid saturating the ground and giving rise to surfacewater flooding, even in extreme rainfall conditions. The strategy also includes the incorporation ofgreen roofs and swales that can collect and store rainwater, with the added benefit of improvingthe quality of the water upon discharge. The latter can also provide an opportunity forenhancement of the soft landscaping proposals as part of the overall sustainable urban drainagesystem. Full details of the proposed drainage strategy will be required through planning condition.In addition to surface water disposal, Southern Water Services has advised that upgrades toexisting infrastructure will be required to ensure an adequate water supply and foul sewerage

disposal to serve the proposed development, both of which may be safeguarded through planningcondition albeit they will be undertaken under non-planning legislation.EcologyThe site supports habitats of limited ecological value, and although there is bat activity at the sitethere is no evidence of roosts in buildings. Some of the habitats would be lost through demolitionworks but following completion of the development, owing to creation of new habitats throughlandscaping proposals and incorporation of bat and bird boxes, as well as a ConstructionEnvironmental Management Plan to reduce disturbance during construction, the developmentdoes not raise detrimental impacts upon ecology.In particular a sensitive landscaping scheme utilizing native species will provide opportunities forpromoting broad habitat enhancements in the area and, if approved, conditions should alsoimpose necessary safeguards such as presence of a watching brief for birds if demolition worksare to take place within the bird breeding season.Members will be aware of the ecologically sensitive and nationally important status of the marshesat NE Gravesend, parts of which are designated as a Site of Special Scientific Interest, a Ramsarsite and a Special Protection Area. However, due to the distance of the application site from theseareas they do not pose a constraint to development, as confirmed by Natural England.Subsequently, there is no requirement for a Habitat Regulations Assessment (commonly known asan Appropriate Assessment).SustainabilityThe submitted Sustainability Statement provides a review of the proposed development againstrelevant sustainability criteria and planning policies and, overall, it is considered that thedevelopment accords with many of the goals of sustainable development. The SustainabilityAppraisal indicates that the development would make a substantial contribution to the social,amenity and economic vitality of the area. There is also a considerable commitment to reduce thedevelopment’s environmental effects, which have been explored as part of the design evolution.Policy CS18 of the Proposed Submission Core Strategy covers measures to mitigate the impactsof climate change. In particular it encourages sustainable drainage solutions for surface waterdisposal, reducing demands on local water supply and renewable energy. Reference is also madeto an original objective of the Development Brief being to meet modern sustainabilityrequirements. It is noted however that the revocation of the South East Plan leaves no adoptedpolicies that cover climate change and sustainability requirements in new developments.The applicant has, though, confirmed a commitment to achieving Code Level 4 for all residentialunits as well as a 10% renewable energy contribution across the site by utilising Combined Heatand Power (CHP) and air source heat pumps. Pursuant to this the application also highlights theneed to carry out a post completion sustainability review to ensure relevant standards have beenmet and enable grant of certificate – BREEAM and Code for Sustainable Homes.In addition to these, the development would include the following sustainability features thatshould be regarded as benefits of the scheme:• water efficient fittings to reduce water consumption;• a Sustainable Urban Drainage System;• improved public transport provision and cycle network;• provision of waste recycling facilities for residents;

• incorporation of infrastructure for electric car charging points;• over 50% of dwellings to comply to Lifetime Homes standards;• efficient re-use of previously developed land to provides homes and employment opportunities.Furthermore, the applicant is committed to sustainable construction, including preparation of aConstruction Environmental Management Plan (CEMP), a Site Waste Management Plan andregistration with the Considerate Constructors Scheme. The PLA have also promoted maximisinguse of the River Thames for transporting materials to and from the site, which may be built into theCEMP.Subject to appropriate safeguards that such standards are achieved, it is considered that thisrepresents a significant benefit of the proposed scheme.s.106 Heads of Terms and ViabilityIn considering applications for planning permission LPAs should consider whether otherwiseunacceptable development could be made acceptable through the use of conditions or planningobligations. This section will consider planning obligations, which should only be used where it isnot possible to deal with through a condition, such as requiring the payment of a financialcontribution or imposing a requirement on a third party. Typical examples of a planning obligationare where the applicant is required to fund or part-fund a piece of local highway infrastructure orcontribute towards upgrading a local facility. Planning obligations do however need to be (i)necessary to make the development acceptable, (ii) directly related to the development, and (iii)fairly and reasonably related in scale and kind to the development. These tests set the boundarieswithin which planning obligations can be sought.In the context of the current planning application the LPA, in part through consultation with variousexternal bodies, has identified a number of planning obligations that it considers are necessary tomake the development acceptable and which cannot be suitably addressed through a planningcondition.However, as advised by the NPPF, when seeking to discuss and negotiate planning obligationsLPAs should take account of changing market conditions and maintain flexibility to preventplanned development being stalled. This essentially relates to ensuring that the LPA’srequirements, such as provision of affordable housing, are not overly onerous such that they makethe scheme unviable and therefore undeliverable. Such consideration and negotiation stands tocomprise part of the balanced determination process yet whilst seeking to encourage developmentit is not the case that the LPA should be expected to concede normally essential obligations solelybecause they would render the scheme unviable.In cases where the applicant contends that viability of a scheme is stretched, it is necessary forthem to submit details of a financial appraisal to support that view which can then be used as atool in negotiating the obligations, which in the present climate is likely to include a mechanism fordeferred contributions. In the current application the applicant has submitted a commerciallyconfidential financial appraisal that the Council have had independently reviewed. This will informfurther discussions with the applicant that will be reported in a supplementary report.CONCLUSIONThe application site comprises a key site directly adjoining Gravesend Town Centre and itsredevelopment will therefore form a fundamental part of the town for many years to come; hencethe high profile nature of the application and the extent of press coverage and localrepresentation. Particularly in the current economic climate redevelopment of these areasrepresent a significant opportunity to re-establishing the town as a destination through the

provision of a high quality mixed-use development in place of the existing open car parking whichseparate the town from the river and form an unattractive setting for St George’s Church.In planning policy terms there is clear national and emerging local support for the over-ridingmixed-use development approach proposed through this application. Furthermore, independentretail advice is that large modern retail units are required to halt the current economic decline ofGravesend Town Centre by attracting major retailers that will complement rather than competewith the existing small and independent traders.Whilst the principle is acceptable, it is however also necessary to consider the merits of theapplication in detail including the impacts of the proposal upon existing residents, the character ofthe area and its heritage assets, environmental constraints and the highway network, as well asthe quality of the new development in respect of building design and appearance, provisions fornew and existing residents and visitors and meeting current sustainability objectives.The broad design approach to the development is generally considered to be appropriate andacceptable in respect of its overall scale and massing and the creation of new and improvedpedestrian connections to the river and across the High Street. The scheme will also enhance thequality of existing open spaces and create better public realm and in particular this will improve thesetting of St George’s Church and create an integrated extension to the existing shopping centre.The provision of a variety of public uses and high quality public realm, coupled with a significantquantum of residential apartments, will ensure the new areas are alive with activity to improve theirattractiveness, functionality and sense of security.This application has received an unprecedented amount of local representation, with a mix ofopinions. Whilst the scheme will have an impact upon the living conditions of some existingresidents in the adjoining apartment blocks along West Street and Queen Street (summary tofollow in supplementary report) and the height of the Bath Street building (Building W03) continuesto raise concern, a positive recent change has been the improvement of the residential units toensure the room sizes accord with the adopted local standard. It is considered that the currentscheme, due to changes incorporated by the applicant, has advanced positively from thepreviously refused scheme.The NPPF states that “significant weight” should be afforded to the need to support economicgrowth and so the provision of substantial new retail space and the generation of significantemployment opportunities as part of the present application proposals are immediately recognisedas key benefits. The combination of new and enhanced public spaces, increased activity andnatural surveillance, and a balanced mix of uses will also stimulate the local economy andcontribute to providing a more welcoming and attractive environment to people visiting and living inthe town centre, which should be afforded significant weight in determining this application.These benefits are considered to outweigh the negative impacts referred to above, and it is theview of officers that the application provides an exciting and much needed opportunity forinvestment in, and regeneration of, Gravesend Town Centre.RECOMMENDATION:To be provided in the supplementary report.APPENDICESAppendix 1 – List of supporting documents and plansAppendix 2 - Full consultation responsesAppendix 3 - Summary of local representationsAppendix 4 - Extracts from EHEL’s heritage statement