Planning Applications Sub Committee 9 April 2024 Subject: Hill

Committee:

Date:

Planning Applications Sub Committee

9 April 2024

Subject:

Hill House, 1 Little New Street, London EC4A 3JR.

Demolition of existing building above ground with

retention of existing basement and piles/ foundations

and erection of a mixed use office building

comprising two basement levels, lower ground,

upper ground and upper ground mezzanine plus 18

upper storeys for the provision of office space (Use

Class E), gym/auditorium (Use Class E), flexible

office, café/retail (Use Class E), reprovision of

existing library (Use Class F1), flexible library/office

(Use Class F1/E) and restaurant (Use Class E),

discontinuance of the City Walkway (Little New

Street To Wine Office Court), enhanced and

enlarged public realm, hard and soft landscaping,

highway works, and associated enabling works.

Public

Ward: Castle Baynard

For Decision

Registered No: 23/01102/FULMAJ

Registered on:

19 Oct 2023

Conservation Area: No

Listed Building: No

Summary

Existing site

The Site is located in the northwest of the City to the north of Fleet Street.

The building is bounded on all sides by public highway with Little New Street

to the north, Shoe Lane to the east, Wine Office Court to the south, and

Printer Street and Gunpowder Square to the west.

The existing site comprises office use, a public lending library and a bar.

There is existing City Walkway through the centre of the Site from north to

south; this is proposed to be removed as part of proposals. There are areas

of permissive path located across the Site.

Proposals

The scheme would provide a total of 58,333 sq.m GEA floorspace,

comprising 44,105 sq.m of office floorspace providing a significant amount of

flexible Grade A floorspace, an uplift on the site of both quality and quantity

of office floorspace.

The proposal will re-provide the existing public library at the site, with

additional floorspace for flexible affordable workspace and library use.

The development would provide an uplift in retail floorspace with the

provision of a retail/café unit at ground, and a restaurant at level 17.

The applicant would deliver a comprehensive landscaping scheme across

the site, and at Gunpowder Square providing an enhanced entrance and

public space directly adjoining the library, subject to a Section 278

Agreement.

This application is accompanied by an Environmental Statement.

Consultation

A total of 49 responses from the public were received. This comprised four

objections and two neutral comments which raised residential amenity

impacts including for daylight and sunlight, overlooking, and relating to the

construction period. Officers have considered these issues and

recommended conditions and Section 106 obligations to mitigate impacts.

A total of 43 responses were received supporting the proposals, these all

state: “I am writing to share my support for the Hill House proposals” with

some responses also highlighting support for the rooftop restaurant, new

public realm and library proposals.

Sustainability

The proposed development would deliver a high quality, energy efficient

development that is on track to achieve “outstanding” BREEAM assessment

ratings. The proposals cannot meet the London Plan target of 35%

operational carbon emission savings compared to a Part L 2021 compliant

scheme which the GLA acknowledges will initially be difficult to achieve for

commercial schemes. However, the proposed energy efficiency and the MEP

strategy would perform highly, with an innovative façade system that would

provide both operational and embodied carbon efficiency and an additional

opportunity to use timber for internal elements.

The assessment of options, carried out in compliance with the Carbon

Options Guidance 2023, confirmed that although the preferred proposal

would result in the highest whole life-cycle carbon emissions out of the four

options, none of the other options would be able to deliver the holistic

sustainability benefits that would complement the repositioning of the

emerging Fleet Valley area into a vibrant, healthy and sustainable new part

of the City. The planning stage whole life-cycle carbon emissions are

calculated to reach close to the GLA’s Aspirational Benchmark, and

opportunities to maximise the reuse of deconstruction materials from the site

and from other reuse sources have been identified to mitigate impacts of

redevelopment. The proposal therefore would satisfy the GLA’s circular

economy principles and London Plan policy, Local Plan policy, and Draft City

Plan 2040. The building design responds well to climate change resilience

by reducing solar gain, saving water resources and various opportunities for

urban greening and biodiversity and complies with London Plan Policies

Local Plan policies.

There will be a loss of four existing trees at the site at Gunpowder Square

however these are considered to be of a low quality and the applicant is

proposing approximately 28 trees across the site and will be required to

deliver at least four trees with larger canopies in the new public realm at

Gunpowder Square, alongside significant public realm and greening

improvements. This would be secured in the Section 106 and Section 278

agreements.

Transport

The trip generation assessment identifies that the proposed development

would generate 976 trips during the AM peak (8:00-9:00) and 1,156 trips

during the PM peak (17:00-18:00). When considered against the existing site

and associated trip generation, this is an increase of +635 trips during the

AM peak and +786 trips during the PM peak.

Given the accessibility of the site in relation to local public transport services,

and when considering the projected mode share of trips, it is considered that

this additional level of activity could be absorbed by the existing transport

networks, subject to appropriate mitigation and improvements to local

footway conditions.

The applicant has committed to consolidate deliveries which would reduce

the number of servicing vehicles arriving on site and result in a total of 49

deliveries per day (or a net increase of 14 trips when compared to the existing

scenario). A daily servicing vehicle cap would be applied to the proposals.

The Applicant also commits to restricting servicing activity between the peak

network hours.

The applicant would provide a minimum of 750 long-stay cycle parking

spaces internally, and 113 short-stay cycle parking spaces across internal

and external spaces which meets the London Plan requirement. In addition,

the applicant would also re-provide / retain the additional 24 existing cycle

parking spaces that are located on Wine Office Court in the improved public

realm.

The development will be car free however the applicant proposes to provide

two additional disabled bays on-street on Little New Street, and the applicant

has committed to providing EV charging capabilities for the proposed on-

street bays.

The proposals will result in the loss of City Walkway (174 sqm) through the

centre of the site, which is considered to be of poor quality with relatively low

usage.

Local Plan Policy DM 16.2 resists the loss of pedestrian routes unless an

alternative public pedestrian route of at least an equivalent standard is

provided. An alternative route is not proposed by the applicant, and it could

therefore be considered that there is some element of non-compliance of the

aforementioned policy. However additional public realm space is to be re-

provided (194 sqm) around the periphery of the building as part of an

enhanced public realm.

The pedestrian comfort results indicate that there is to be no change in the

pedestrian comfort level of the assessed footways at Little New Street and

Shoe Lane and there will be a slight reduction in the pedestrian comfort level

for Printer Street, which is considered immaterial and is still within an

acceptable and comfortable range. However Officers consider that footways

should be considered in more detail as part of the proposed Section 278

works.

Enhancements to Gunpowder Square have been proposed, to create a

much-improved public realm along the key pedestrian desire line between

New Street Square and Fleet Street. The works to public highway would be

secured through a Section 278 Agreement.

The transport proposals are considered acceptable subject to conditions and

section 106 obligations, including Construction Logistics details, to mitigate

impacts to nearby uses and residents.

Design and Heritage

The Twentieth Century Society and the City of Westminster objected to the

proposals on heritage grounds. Historic England responded to the

consultation raising concerns on heritage grounds and identifying harm to

heritage assets. In addition, St Paul’s Cathedral responded to identify harm

to heritage assets.

The City’s long-term, plan-led approach to tall buildings is to cluster them to

minimise heritage impacts and maximise good growth. As such, the adopted

Local Plan seeks to consolidate tall buildings into a singular, coherent City

Cluster (Local Plan policies CS7 and CS14 (1)), an approach carried forward

in the emerging City Plan 2040 with the addition of a smaller proposed

Cluster in the Holborn and Fleet Valley area (S12 (2) and S21).

The application site falls outside the ‘Eastern Cluster/City Cluster’ policy

areas in the adopted Local Plan and emerging City Plan (CS7, fig. G; S21,

fig. 28), but does fall within the proposed Holborn and Fleet Valley Cluster in

the emerging City Plan (S12, fig. 14). At 94.80m AOD, the proposal would

exceed the highest of the contours of the proposed cluster (90m AOD) by

4.8m and would therefore create a degree of conflict with emerging policy

S13 (3) of the 2040 Plan. This Plan is yet to undergo Regulation 19

Consultation and consequently its provisions can be afforded only limited

weight as a material consideration.

Having conducted a detailed assessment of the potential impacts of the

proposal, officers conclude that the site would be appropriate in principle for

a tall building.

Officers consider that the architectural design of the building would be

compatible with the existing context, being read as a well-layered piece of

design, which celebrates moments in the public realm. Officers consider that

the sculptural form of the building's massing, which breaks the building down

into a series of different elements is successful, and responsive to its context,

while also delivering a unique piece of architecture with its own identity and

well-articulated facades.

Overall, it is considered that the proposal would make the best use of land,

following a design-led approach that optimises the site capacity to

accommodate employment growth and would increase the amount of high-

quality office space. The proposals align with the function of the City to

accommodate substantial growth in accordance with Local Plan Policies

CS1: Offices and London Plan Policies SD4, SD5 and E1.

The architecture and urban design proposals comply with Local Plan Policies

CS10 and DM10.1, DM19.1 emerging City Plan Policy S8, DE2, HL1, DE3,

and London Plan Policy D3 and D8, paragraphs 130 and 132 of the NPPF

and the City Public Realm SPD all require high-quality public realm and

increased urban greening.

Following rigorous assessment, officers consider that the proposal would

preserve all relevant strategic views in accordance with London Plan Policy

CS13, City Plan policy S13 London Plan Policy HC4 and associated

guidance in the LVMF SPG and Protected View SPD. The proposal would

not harm the characteristics and composition of relevant strategic views and

their landmark elements.

Furthermore, the proposals would preserve the significance (via change in

the setting) of heritage assets and an appreciation of it. As such, they would

accord with Local Plan policies CS12 and DM12.1, emerging City Plan 2040

policies S11 and HE1, London Plan policy HC1, having accounted for and

paying special regard to s.66 (1) of the Planning (Listed Buildings and

Conservation Areas) Act 1990 and the relevant NPPF policies.

Environmental impacts

Two wind assessments were undertaken: a Computational Fluid Dynamics

(CFD) and Wind Tunnel. No wind safety risks were identified associated with

the proposed development.

For the wind tunnel, with the inclusion of the proposed development the

majority of locations would have wind conditions suitable for the intended

use. Bench seating by the gym/auditorium entrance and higher-level terrace

locations would have wind conditions one category windier than suitable.

With the existing and proposed landscaping in place, all ground level

locations would have suitable wind conditions for the intended use and no

mitigation would be required. On the terrace levels the majority of areas

would have suitable wind conditions for terrace use, however, a number of

locations would have wind conditions windier than suitable for amenity use.

Mitigation measures have been suggested and with these mitigation

measures in place it is expected that wind conditions would be suitable for

the desired amenity uses.

The CFD found that conditions will be either suitable for the intended use or

no windier for the baseline conditions, without landscaping or mitigation

measures, for all thoroughfares, building entrances (both proposed and

existing off-site), existing off-site amenity (both ground level and elevated

terraces), the proposed benches by the main entrance lobby, the proposed

benches in Gunpowder Square, and the majority of the proposed elevated

terraces (up to level 14, plus level 18). The baseline conditions which are

unsuitable would be made suitable by the proposed Development for existing

benches adjacent to 1 New Street Square and 120 Fleet Street, and on

Stonecutter Street. Conditions for the proposed level 15 and 16 terraces

would have regions which are not suitable when tested without the proposed

landscaping, but would be made suitable by the inclusion of the proposed

landscaping scheme. Conditions for the proposed level 17 terrace would not

be suitable when tested without the proposed landscaping, but would be

made suitable for use as a mixed-amenity terrace by the inclusion of the

proposed landscaping scheme. Should spill-out restaurant seating be

required in detailed design, it is recommended that screening is incorporated

into the terrace design at that stage. A condition to secure wind mitigation is

proposed. Conditions for the proposed bench outside the flexible

gym/auditorium entrance would be a category windier than the target without

the proposed landscaping, but would be made suitable with the inclusion of

the proposed landscaping scheme.

For the CFD, at 120 Fleet Street, there is a small area shown to the north of

building on the western elevation for uncomfortable conditions shown in the

windiest season only. This is shown on the façade of the proposed retail unit

to the side of the entrance. The consultant states there is a highly localised

region of red “uncomfortable” conditions does not extend more than 500mm

from the wall of 120 Fleet Street, therefore is not of sufficient extent to impact

the pedestrian experience in this area and is therefore considered negligible.

This region was picked up in the CFD analysis, but was not picked up by the

wind tunnel testing due to being such a localised region that it fell between

probe locations.

Therefore subject to condition and s106 obligation, the wind microclimate

impacts are considered acceptable.

It is considered that the thermal comfort in and around the site, would be

acceptable in accordance with London Plan Policy D8 and Policy D9 and

emerging City Plan policies S8 and S12, and the guidance contained in the

Thermal Comfort Guidelines for Development in the City of London.

A Solar Glare Assessment has been submitted. It states that occurrences of

solar glare at angles beyond 30 degrees would be of little significance in most

situations and if the angle between the driver’s line of view and the reflected

sun is less than 10 degrees, solar glare could be a significant issue. The

analysis states that the likelihood of experiencing solar glare throughout the

year is relatively minimal, and even in cases where it does occur, it is at

angles greater than 30 degrees. Therefore impacts are considered

acceptable.

With regard to impacts on daylight and sunlight to nearby residential

properties, for Pemberton House, 7 Wine Office Court and 1-23 Bolt Court,

these would experience Minor to Major Adverse effects. Despite failures

against the BRE guidelines, it is not considered that the proposal would result

in an unacceptable impact on the existing use of the properties in the context

of the location of the site in a dense urban area. In addition, an independent

review was undertaken for the results that concluded that the results are not

considered unacceptable in the urban context. As such, the impacts are

considered to be such that to cause the proposals to conflict with Local Plan

Policy DM10.7 and Policy DE7 of the draft City Plan 2040.

Local Plan Policy DM15.7 and draft City Plan 2040 policy DE8 requires that

development should incorporate measures to reduce light spillage

particularly where it would impact adversely on neighbouring occupiers. An

assessment of lighting impacts was undertaken by the applicant and

identifies sensitive receptors at Pemberton House including bedrooms which

face towards the Site. An assessment of the likely significant light intrusion

effects of the proposed development are of moderate to major adverse

significance. However the assessment assumed a ‘typical’ lighting design

and also assumed that all lights are switched on at the same time and no

blinds or shading devices are installed, and assumes that all lights remain on

after 11pm. Therefore the assessment states that this represents a

reasonable worst case scenario and the effects are likely to be materially

lower in reality when one takes into account of a mitigation scheme that

would be deployed as part of good building management practices.

The applicant states that the lighting will be designed to reduce the potential

effects on residents of Pemberton House, such that the likely effect of the

proposed development after mitigation will likely be minor adverse and

therefore not significant. Conditions are recommended to ensure that

impacts to residents and other sensitive receptors are mitigated including

compliance with the Lighting SPD. Subject to detailed design and conditions,

the impacts are considered acceptable.

Benefits

The scheme would provide benefits through CIL for improvements to the

public realm, housing and other local facilities and measures. That payment

of CIL is a local finance consideration which weighs in favour of the scheme.

In addition to general planning obligations there would be site specific

measures secured in the S106 Agreement.

There are a range of public benefits associated with the proposal which

includes the delivery of:

• An enhanced library offer with potential to generate income from

meeting rooms;

• Potential for affordable workspace at the site to be managed by the

library to generate income;

• Exclusive managed use of the level 18 amenity space and rooftop for

library use and for community events;

• A Changing Places Toilet;

• A flexible gym/ auditorium use with offer for discounted use for

qualifying groups and users;

• Public realm improvements including an enhanced Gunpowder Square

subject to s278 agreement;

• Provision of public art.

Planning obligations

The S106 agreement will secure the reprovision of the library at Hill House

and the temporary relocation during construction at One New Change,

subject to the grant of planning permission.

Financial security in the form of a payment or guarantee will be given by the

applicant to ensure that the Corporation can deliver a library in the event that

the applicant fails to deliver in accordance with the agreed timetable. The

applicant would meet the costs and carry out works for fit out and furnish both

the temporary and permanent library.

New lease terms would include a peppercorn rent throughout the 65 year

term with a reasonable cap on service charge to be agreed with better

commercial terms than the existing lease.

Conclusion

The principle of high-quality Grade A office, reprovision of a library, flexible

retail and gym/auditorium floorspace are acceptable and would be secured

through condition.

Virtually no major development proposal is in complete compliance with all

policies and in arriving at a decision it is necessary to assess all the policies

and proposals in the plan and to come to a view as to whether in the light of

the development plan when taken as a whole the proposal does or does not

accord with it. The Local Planning Authority must determine the application

in accordance with the development plan unless other material

considerations indicate otherwise.

Paragraph 11 of the NPPF sets out that there is presumption in favour of

sustainable development. For decision taking that means approving

development proposals that accord with an up to date development plan

without delay.

Other material considerations, including the application of policies in the

NPPF and the significant weight to be placed on the need to support

economic growth (paragraph 85), also indicate that planning permission

should be granted.

Although there is some non-compliance with parts of the tall building and

pedestrian movement policies, it is the view of Officers that the proposal

complies with the Development Plan when considered as a whole and that

material planning considerations weigh in favour of the scheme.

Therefore, it is recommended that planning permission be granted subject to

all the relevant conditions being applied and Section 106 obligations being

entered into in order to secure the benefits and minimise the impact of the

proposal.

Recommendation

1. That, subject to the execution of a planning obligation or

obligations in respect of the matters set out under the heading

‘Planning Obligations’ the Planning and Development Director be

authorised to issue a decision notice granting planning

permission for the above proposal in accordance with the details

set out in the attached schedule; and

2. That your Officers be instructed to negotiate and execute

obligations in respect of those matters set out in "Planning

Obligations" under Section 106 of the Town and Country

Planning Act 1990 and any necessary agreements under

Sections 278 and 38 of the Highway Act 1980 in respect of those

matters set out in the report.

3. That your Officers be authorised to provide the information

required by regulations 29 of the Town and Country Planning

(Environmental Impact Assessment) Regulations 2017, and to

inform the public and the Secretary of State as required by

regulation 30 of those regulations.

Image 1: Aerial view of site looking north-west.

Image 2: View looking southwest from Stonecutter Street.

Image 3: View looking south from Printer Street into Gunpowder Square.

Image 4: Visual of proposed development looking northeast.

Image 5: Visual of the library use at the proposed development.

Image 6: Visual of proposed development at Gunpowder Square.

Image 7: Visual of proposed library entrance at Gunpowder Square.

Application Sheet: Hill House

TOPIC

INFORMATION

1. HEIGHT

EXISTING

PROPOSED

49.33m AOD

94.8m

2. FLOORSPACE

GIA (SQM)

USES

EXISTING

PROPOSED

Office (Use Class

15,842.4

Office (Use Class E)

43,341

Bar (Sui Generis)

1,014.2

Flexible

Office/Café/Retail (Use

Class E)

319.7

Library (Use

Class F1)

1,016.4

Library (Use Class F1)

1,040.7

Flexible Library/Office

(Use Class F1/E)

467.5

Flexible

Gym/Auditorium (Use

Class E)

460.7

Restaurant (Use class

823.4

Ancillary/Back of

House

6,836.3

Ancillary/Back of House

10,829.2

Total

24,709.6

57,056.5

3. OFFICE

PROVISION IN

THE CAZ

An increase of at least 27,498.6 sqm GIA of office floorspace in the CAZ.

A potential for 467.5 sqm GIA additional affordable workspace.

4. EMPLOYMENT

NUMBERS

EXISTING

PROPOSED

Estimated 2,986

5. VEHICLE

+CYCLE

PARKING

Blue Badge

Cycle Parking

Long Stay Cycle

Parking

750

Short Stay Cycle

Parking

113

6. HIGHWAY

LOSS / GAIN

There is no highway loss proposed. There is a loss of City Walkway

proposed. However there would be an increase of 52 sqm of new public

realm (permissive path) compared to the existing development.

7. PUBLIC REALM

Public realm improvements around the site including at Gunpowder

Square, subject to S278 Agreement.

8. STREET TREES

EXISTING

PROPOSED

Approximately 28 subject to detailed

landscape design with at least four

with large canopy in Gunpowder

Square.

9. DAILY

SERVICING

VEHICLE TRIPS

EXISTING

PROPOSED

35 deliveries (70 trips)

49 deliveries (98 trips). This assumes

50% consolidation and 5% of all trips

undertaken by cargo bike.

10. SERVICING

HOURS

Deliveries will take place outside the peak hours (07:00-10:00, 12:00-

14:00 and 16:00-19:00).

11. RETAINED

FABRIC

Substructure – 90% by mass retention

Superstructure – 0 % retention

12. OPERATIONAL

CARBON

EMISSION

SAVINGS

Improvements against Part L 2021: 13%

GLA requirement: 35%

13. OPERATIONAL

CARBON

EMISSIONS

35,216.6 tonnes CO

over 60 years

0.617 tonnes CO

per square meter over 60 years

(includes life-cycle modules B6+B7)

14. EMBODIED

CARBON

EMISSIONS

PROJECT LIFE CYCLE EMISSIONS COMPARED TO GLA

BENCHMARKS

A1-A5: upfront embodied carbon emissions per square meter

B – C (excluding B6 and B7): in use stage embodied carbon emissions

per square meter

Total upfront embodied carbon 36,817.8 tonnes CO

e / 645 kgCO

e per

sqm

15. WHOLE LIFE

CYCLE

CARBON

EMISSIONS

Total whole life-cycle carbon emissions: 92,019.3 tonnes CO

Total whole life-cycle carbon emissions per square meter:

1.612 tonnes CO

/sqm

16. WHOLE LIFE-

CYCLE

CARBON

OPTIONS

17. TARGET

BREEAM

RATING

Policy target Excellent or Outstanding

18. URBAN

GREENING

FACTOR

0.34

19. BIODIVERSITY

NET GAIN

517.33%

20. AIR QUALITY

An all electric system is proposed for plant. The Air Quality Assessment

confirmed that development is air quality neutral and that overall, with the

recommended mitigation measures in place (construction phase only),

the development would be compliant with legislation and policy.

Good

Very Good

Excellent

Outstanding

Main Report

Environmental Statement

1. The application is for EIA development and is accompanied by an

Environmental Statement (ES). The ES is a means of drawing together, in a

systematic way, an assessment of a project’s likely significant environmental

effects. This is to ensure that the importance of the predicted effects and the

scope for reducing them are properly understood by the public and the

competent authority before it makes its decision.

2. The Local Planning Authority must take the Environmental Statement into

consideration in reaching its decision as well as comments made by the

consultation bodies and any representations from members of the public about

environmental issues as required by the Town and Country Planning

(Environmental Impact Assessment) Regulations 2017.

3. The duties imposed by regulation 26 of the EIA Regulations require the local

planning authority to undertake the following steps:

a) To examine the environmental information;

b) To reach a reasoned conclusion on the significant effects of the proposed

development on the environment, taking into account the examination

referred to at (a) above, and where appropriate, their own supplementary

examination;

c) To integrate that conclusion into the decision as to whether planning

permission is to be granted; and

d) If planning permission or subsequent consent is to be granted, consider

whether it is appropriate to impose monitoring measures.

4. A local planning authority must not grant planning permission unless satisfied

that the reasoned conclusion referred to above is up to date. A reasoned

conclusion is to be taken to be up to date if, in the opinion of the relevant

planning authority, it addresses the significant effects of the proposed

development on the environment that are likely to arise as a result of the

proposed development. The draft statement attached to this report at Appendix

A and the content of this report set out the conclusions reached on the matters

identified in regulation 26. It is the view of the officers that the reasoned

conclusions address the significant effects of the proposed development on

the environment that are likely to arise as a result of the proposed development

and that reasoned conclusions set out in the statement are up to date.

5. Representations made by any body required by the EIA Regulations to be

invited to make representations and any representations duly made by any

other person about the environmental effects of the development also form

part of the environmental information to be examined and taken into account

by your Committee.

6. The Environmental Statement is available online, together with the application,

drawings, relevant policy documents and the representations received in

respect of the application.

Site and Surroundings

7. The Site is located in the northwest of the City to the north of Fleet Street. The

building is bounded on all sides by public highway with Little New Street to the

north, Shoe Lane to the east, Wine Office Court to the south, and Printer Street

and Gunpowder Square to the west.

8. The existing building was completed in 1979 and comprises seven storeys

above ground with two basement levels and has accommodated

predominantly office floorspace over its lifetime. The total existing height is

49.33 metres above ordnance datum (AOD).

9. There is existing City Walkway through the centre of the Site from north to

south which is proposed to be removed as part of proposals. There are areas

of permissive path located across the Site.

10. The uses at existing site comprises:

• Office use (15,842 sq.m GIA) – from lower ground to level six with the

principal entrance facing Little New Street;

• Library use (1,016 sq.m GIA) – at basement two level with entrance facing

Little New Street;

• Bar (1,014 sq.m GIA) – on lower and upper ground floor with entrance

from Shoe Lane;

• Gym for office use – on upper ground floor with entrance from Printer

Street;

• Loading bay and servicing area – ground and basement one;

• Plant and back of house (6,837 sq.m GIA) – basement two, basement one,

lower ground, upper ground, and level seven.

11. The site is not within a conservation area; however, the Fleet Street

Conservation Area is located nearby to the southwest.

12. Part of the site sits within the London Panorama (5A.2) from Greenwich Park

in the London View Management Framework (LVMF).

13. The building is not listed, however there are listed buildings nearby including

no. 7 Wine Office Court (Grade II) and no. 17 Gough Square No 17, Dr

Johnson's House (Grade I).

14. On 7

June, Historic England confirmed that the existing building is not

recommended for listing and recommended that a Certificate of Immunity

should be issued.

15. The surrounding area is comprised of predominantly commercial uses

including office and retail. In addition, there are a number of residential

properties near to the Site and this includes directly to the west at Pemberton

House and southwest at Wine Office Court.

16. Existing blue badge bays are located on Little New Street to the north of the

Site, a space on St Bridge Street to the east, and a space in Gough Square to

southwest.

17. There is existing public realm at Gunpowder Square which includes three City

managed trees.

18. Topographically the site slopes downwards to the east between Printer Street

and Shoe Lane.

19. The existing servicing takes place from Shoe Lane via a dedicated loading

bay.

Planning history

20. There is no relevant recent planning history at the Site apart from an

application currently pending for the bar unit at the Site for a temporary

community kitchen and exhibition space (app. ref. 24/00094/FULL).

21. Directly to the east of the Site is the consented 120 Fleet Street development

which is currently under construction for the: Demolition of the existing River

Court building at 120 Fleet Street, including part demolition of the basement

and the erection of a new building comprising two basement levels and ground

floor plus 20 upper storeys (93.15m AOD) including retail, commercial, office

and service use (Class E). Creation of new pedestrian routes. Change of use

of Daily Express Building from office (Use Class E) to learning and non-

residential institutions use (Class F1), retail, flexible learning and non-

residential institutions and commercial use (Class E), Alterations to and

refurbishment of the existing Grade II* listed Daily Express Building at 120

Fleet Street, including works to detach the building from the River Court with

demolition of part of linking floorplate and structure from basement level 01 to

level 06, demolition of roof and installation of new roof with associated roof

garden, erection of new north facade, retention of south-east curved corner

and part demolition of existing east facade from ground level to level 05,

erection of new facade and shopfront and associated works.

Proposals

22. Planning permission is sought for the demolition of existing building above

ground with retention of existing basement and piles/ foundations and erection

of a mixed use office building comprising two basement levels, lower ground,

upper ground and upper ground mezzanine plus 18 upper storeys for the

provision of office space, gym/auditorium (Use Class E), flexible office,

café/retail (Use Class E), reprovision of existing library (Use Class F1), flexible

library/office (Use Class F1/E) and restaurant (Use Class E), discontinuance

of the City Walkway (Little New Street To Wine Office Court), enhanced and

enlarged public realm, hard and soft landscaping, highway works, and

associated enabling works.

23. The existing basement slab at basement level two is proposed to be retained

alongside the perimeter walls with other walls and structure to be demolished.

24. The scheme would provide a total of 58,411 sq.m GEA floorspace, comprising:

• 44,110 sq.m of office floorspace (Class E(g(i)));

• 336 sq.m of flexible retail (Class E(a-d);

• 479 sq.m of flexible gym /auditorium use (Class E);

• 1,066 sq.m of public library use (Class F1);

• 515 sq.m of flexible affordable workspace and library use (Class E / F1).

25. The scheme would provide a significant amount of flexible Grade A office

floorspace, an uplift on the site of both quality and quantity of office floorspace

and an increase in the floorspace for other proposed retail and commercial

uses.

26. The proposals would re-provide the public library at the site at ground and

mezzanine level with an entrance from Gunpowder Square. This will include

additional adjoining floorspace at mezzanine level for affordable workspace or

library use.

27. The site would provide a restaurant at level 17 and café/retail at ground floor.

28. In addition, the proposed development would include a gym or auditorium use

at basement level.

29. The servicing is proposed to take place from the same location as existing from

Shoe Lane to the east of the Site.

30. Two additional blude badge spaces are proposed on Little New Street and

cycle parking is proposed at ground floor and basement internally and in the

public realm on Wine Office Court and at Gunpowder Square.

31. There would be new and enhanced public realm at Gunpowder Square and

around the site, and terraces on levels 1 to 18. This would include urban

greening and biodiversity measures. There would be an increase of public

realm at ground level next to Gunpowder Square where the building line is

pushed back to mitigate for the loss of City Walkway at the Site.

Consultations

Statement of Community Involvement

32. The Applicant has submitted a Statement of Community Involvement outlining

their engagement with stakeholders. Public consultation took place via

leafleting and in-person consultation events as well as digital engagement. A

total of 241 attendees were present at December - July consultation events.

33. The Statement of Community Involvement concludes that the majority of

attendees at the events were particularly interested in the public realm, library,

and rooftop restaurant proposed and that the proposal to relocate Shoe Lane

Library from its existing basement location to a highly prominent new home at

ground floor level adjacent to Gunpowder Square was met with positive

feedback.

Statutory Consultation

34. Following receipt of the application, it has been advertised on site and in the

press and has been consulted upon in accordance with article 15 of the

Development Management Procedure Order (as amended). Received letters

and e-mails making representations are referenced in Appendix A to this

report. A summary of the representations received, and the consultation

responses is set out in the table below.

35. In accordance with the City’s SCI, notification letters were sent to residential

properties in the vicinity in addition to the site and press notices.

36. The application was advertised in accordance with the EIA Regulations 2017

(as amended).

37. The applicant has provided detailed responses to matters raised in consultee

and third-party responses. All received letters and e-mails making

representations are referenced in the appendix to this report.

External Consultation responses

City Police

Responded and no comments.

City of

Westminster

Responded to state:

We object to the impact of the proposals on the setting of the

Grade I listed churches of St Mary Le Strand and St Clement

Danes. When looking eastwards along the Strand toward the

churches, the proposed development will be highly visible,

and will be overbearing in relation to them and crowding in on

them in the townscape.

As is noted on page 199 of the Townscape, Heritage and

Visual Impact Assessment, the area around the Church is a

high-quality large area of public realm, and that it provides a

"good quality view of two Grade I listed churches along the

important primary route of the Strand which forms part of the

historic processional route to St Paul's Cathedral", concluding

that the value of the view is "accordingly high". We would

agree with this assessment that the value of this view is high.

The report however goes on to say that impact of the

proposals on this view will be neutral as the proposed

development "distinctly legible as a background element, and

it will not dominate or alter the ability to appreciate the

character and composition of the view or the landmark church

within it". This is not accepted as an accurate statement of

the effect of the proposals on the setting of the listed

buildings. Currently when looking eastwards down the

historic processional route to St Pauls, the churches are

framed by the sky, which draws the eye up the spire and

toward the heavens. The architecture of the churches is

therefore in direct conversation with the sky. This

development would reduce the amount of surrounding sky,

resulting in a cluttered and lopsided surrounding townscape

in long distance views which negatively impacts the viewers

ability to appreciate the character and composition of the

churches.

This harm is tacitly acknowledged on page 82 of the Design

and Access Statement which acknowledges that the

redevelopment of the site would result in the loss of the sky-

gap between St Mary-le-Strand church and 120 Fleet Street.

It goes on to state that took on board that "the design should

aim to minimise coalescence with 120 Fleet Street through

elevation design and materiality. The height of the proposed

scheme should not detract from the appreciation of the

churches (St Mary-le-Strand & St Clement Danes) and their

respective spires. The southwest elevation should be

articulated to avoid appearing broad in these views".

Whilst it is appreciated that this harm was acknowledged by

the design team, and an attempt was made to mitigate the

harm, this attempt was not successful. The approach taken

fails to resolve the harm cause by the loss of the sky gap and

the cluttering of the townscape.

Officer response: This is addressed in the ‘Design and Heritage’

section of the report.

Civil Aviation

Authority

No response received.

Crossrail

Responded with no comment.

Dean And

Chapter of St

Paul's

Cathedral

No response.

Environment

Agency

Responded to state:

- Contaminated Land - This development site appears to

have been the subject of past industrial activity (printworks

and cast iron and glass manufacturing) which poses a

medium risk of pollution to controlled waters. However, we

are unable to provide site-specific advice relating to land

contamination as we have recently revised our priorities so

that we can focus on:

• Protecting and improving the groundwater that supports

existing drinking water supplies

• Groundwater within important aquifers for future supply

of drinking water or other environmental use.

- We recommend that you refer to our published ‘Guiding

Principles for Land Contamination’ which outlines the

approach which should be adopted when managing this

site’s risks to the water environment. We also advise that

you consult with your Environmental Health/Environmental

Protection Department for advice on generic aspects of land

contamination management. Where planning controls are

considered necessary, we recommend that the

environmental protection of controlled waters is considered

alongside any human health protection requirements. This

approach is supported by paragraph 174 of the National

Planning Policy Framework. Water Resources Increased

water efficiency for all new developments potentially

enables more growth with the same water resources.

Developers can highlight positive corporate social

responsibility messages and the use of technology to help

sell their homes. For the homeowner lower water usage

also reduces water and energy bills. We endorse the use of

water efficiency measures especially in new developments.

Use of technology that ensures efficient use of natural

resources could support the environmental benefits of

future proposals and could help attract investment to the

area. Therefore, water efficient technology, fixtures and

fittings should be considered as part of new developments.

Residential developments All new residential developments

are required to achieve a water consumption limit of a

maximum of 125 litres per person per day as set out within

the Building Regulations &c. (Amendment) Regulations

2015. However, we recommend that in areas of serious

water stress (as identified in our report Water stressed

areas - final classification) a higher standard of a maximum

of 110 litres per person per day is applied. This standard or

higher may already be a requirement of the local planning

authority.

Officer response: This is addressed in the ‘Land contamination’

section of the report. Conditions and informatives are

recommended.

GLAAS,

Historic

England

Archaeology

A response was provided that stated no further assessment was

required.

Officer response: A condition is recommended.

Greater

London

Authority

Responded to state that: whilst the proposal exceeds the threshold

plane of this protected view, it is not considered that the

proposal would have significant impact on or cause harm to the

protected landmark in this view, and it is not therefore

considered that the amendments give rise to any new strategic

planning issues; therefore, under article 5(2) of the above Order

the Mayor of London does not need to be consulted further on

this application and the City may proceed to determine the

application without further reference to the GLA.

Heathrow

Airport

Responded to state:

- Obstacle Lighting - Although it is not anticipated that the use

of a cranes at this site will impact Heathrow’s Obstacle

Limitation Surfaces, Instrument Flight Procedures or Radar.

We would like to advise the developer that if a crane is

required for construction purposes, then red static

omnidirectional lights will need to be applied at the highest

part of the crane and at the end of the jib if a tower crane, as

per the requirements set out by CAP1096.

- CAA Crane Notification - where a crane is 100m or higher,

crane operators are advised to notify the CAA

([email protected]) and Defence Geographic Centre

([email protected]) via Crane notification. The following

details should be provided before the crane is erected:

• the crane's precise location

• an accurate maximum height

• start and completion dates

Officer response: Conditions are recommended.

Historic

England

Detailed response was received, including the following:

- Whilst we have no objection to the redevelopment of the

current building on the site, we consider that due to their

height of the proposed replacement building, it would have a

harmful impact upon the significance and setting of a number

of heritage assets, particularly the Grade I listed churches on

The Strand and surrounding conservation areas. If your

authority is minded to approve these proposals we

recommend that you seek to ensure that the proposals are

fully justified and weighed in the balance against any public

benefits arising from the proposals, in accordance with

policies set out in the NPPF…. We consider the level of harm

to be less than substantial in NPPF terms, but towards the

middle range… Historic England has concerns regarding the

application on heritage grounds.”

Officer response: This is addressed in the ‘Design and Heritage’

section of the report.

Lead Local

Flood Authority

Responded with conditions.

Officer response: Conditions are recommended.

London City

Airport

Responded to state:

- “London City Airport has now assessed the above application

against safeguarding criteria and can confirm that we have no

safeguarding objections to the proposed development.

However, as a crane is needed for construction purposes, we

would like to draw your attention to the following:

- Obstacle Lighting - Although it isn’t anticipated that the use of

a cranes at this site will impact London City Airport’s Obstacle

Limitation Surfaces, Instrument Flight Procedures or Radar.

We would like to advise the developer that if a crane is

required for construction purposes, then red static

omnidirectional lights will need to be applied at the highest

part of the crane and at the end of the jib if a tower crane, as

per the requirements set out by CAP1096. CAP 1096:

Guidance to crane users on the crane notification process and

obstacle lighting and marking.

- CAA Crane Notification where a crane is 100m or higher,

crane operators are advised to notify the CAA

([email protected]) and Defence Geographic Centre

([email protected]) via Crane notification.

Officer response: Conditions are recommended.

London

Borough of

Camden

Responded with no objections.

London

Borough of

Islington

No response received.

London

Borough of

Lewisham

No response received.

London

Borough of

Tower Hamlets

Responded with no comments.

London

Borough of

Southwark

Confirmed no comments.

London

Underground

No response received.

Ministry of

Housing,

No response received.

Communities

and Local

Government

National Air

Traffic

Services

(NATS)

Responded to state:

- The proposed development has been examined from a

technical safeguarding aspect and does not conflict with our

safeguarding criteria. Accordingly, NATS (En Route) Public

Limited Company ("NERL") has no safeguarding objection to

the proposal. However, please be aware that this response

applies specifically to the above consultation and only reflects

the position of NATS (that is responsible for the management

of en route air traffic) based on the information supplied at the

time of this application.

Natural

England

Responded with no comments.

Network Rail

Responded with detailed advice.

Officer response: An informative has been recommended.

Royal Borough

of Greenwich

Responded with no objections

Thames Water

Responded with detailed advice and recommended conditions and

informatives.

Officer response: Conditions and informatives are recommended.

The City of

London

Archaeological

Trust

Responded with no comments.

The Gardens

Trust

Responded with no comments

Transport for

London

Responded with detailed response including to state:

- Trip Generation and Public Transport Impact

The trip generation exercise was undertaken for the office and

restaurant uses, concerns over missing trip generation

figures for the gym, library and retail. A mode share sensitivity

study using nearby comparison sites has been undertaken to

sense check 2011 census mode split, and the resultant mode

share split for AM and PM peak hours is considered robust.

Public transport trip generation figures have been split out by

station, line or direction as outlined within TfL’s latest Healthy

Streets TA guidance which is welcomed. It is accepted that

additional trips generated by the scheme are unlikely to have

a specific adverse impact on the strategic transport network.

- TfL question the proposed 750 cycle parking spaces, given

the proposed office trip generation modal split is at 4.1%, this

percentage is very low given the aspirations of the Mayors

Transport Strategy. Further discussion and work may be

required regarding the trip generation and public transport

impact.

- Healthy Streets and public realm

TfL welcomes that there has been a Pedestrian Comfort Level

assessment and recognises the importance of the removal /

changes made to the City Walkway. Regarding pedestrian

access, there has been a reprovision of a new 24/7 footway

around the periphery of the site, enhancing public realm, with

active frontages across a 5 to 10 minute all areas. This should

be secured via section 106 (s106) agreement or 278 as

necessary. The public realm changes should include new

Legible London wayfinding signage secured by S106, and

updates to all other existing Legible London signage within

walking distance of the site.

Active Travel Zone (ATZ) and Vision zero

- TfL requested a day and night-time ATZ, though the applicant

has provided an Active Travel Audit. TfL strongly

recommends a ’night-time/dark hours’ ATZ assessment is

submitted to reflect the walking environment in the context of

the Healthy Streets criteria ‘People feel Safe’. TfL is

commitment to improving women’s safety and delivering the

Mayor's Strategy to Reduce Violence Against Women and

Girls. Given the workspace and leisure elements of the

scheme, a night-time/ dark hours ATZ is justified through the

shorter periods of daylight in winter months.

- Within the Active Travel Audit are 5 routes which align with

the Healthy Streets Approach, the audit was taken between

the hours of 14:30 – 16:30, TfL recommends the applicant

carries out a morning Active Travel Audit as well to reflect the

peak hours cycle commute.

- In line with the Mayors Vision Zero goal for deaths and serious

injuries (KSIs) to be eliminated from London’s transport and

street networks by 2041, collision data was mapped against

all the ATZ routes referred to above. In total for the ATZ, there

were 47 recorded serious collisions and a single fatal,

including 30 involving cycles. Given this figure, TfL may seek

funding for highway safety improvements in line with London

Plan policy T4 especially on cycleways.

- From the assessments taken, the applicant has proposed

recommendations for improvements to the local transport

network, which would facilitate an environment that

encourages walking and cycling. TfL would support the CoL

in securing these improvements: provision of appropriate

tactile paving at the informal crossing over the A4 New Fetter

Lane/ Bartlett Court Junction, provision of dropped kerbs and

tactile paving at the crossover on Shoe Lane beneath the A40

Holborn Viaduct.

Car parking

- Given the high PTAL, the car free scheme is strongly

supported in accordance with London Plan policy T6 TfL also

welcomes the removal of the existing porte cochère to

therefore remove two existing vehicle crossovers, reinstating

the footway and hence creating additional kerbside for the

provision of two extra disabled car parking spaces. TfL

accepts the current proposal for the location of the disabled

car parking, given it is the main access to the primary use of

the development, being the main offices entrance. In line with

Policy T6 of the London Plan, TfL request the applicant

ensures that all disabled parking spaces are Electric Vehicle

Charging Points (EVCP) active spaces. In line with Policy T6,

a Parking Design and Management Plan should be submitted

alongside this application indicating how proposed blue

badge car parking would be designed and managed, with

reference to Transport for London guidance on parking

management and parking design.

Cycle parking

- The applicant is committed to providing long and short stay

cycle parking in accordance with the minimum London Plan

standards which is welcomed. Clarification is sought however

on how of long stay cycle parking spaces were calculated.

- The proposal states there will be 5% accessible parking

spaces, meeting the London Cycling Design Standards

(LCDS) requirement, the applicant therefore must provide at

least 38 spaces for larger / adapted cycle spaces which must

be accessible, meet the space requirements and involve step

free access.

- The applicant should increase the proportion of Sheffield

stands to 20% as they are more accessible and more

convenient for all.

- The London Plan 2021 states space for folding bicycles

should not exceed 10% of all spaces; this meets the proposed

percentage and therefore TfL accept that 10% of long stay

cycle parking spaces are folding cycle lockers.

- TfL welcomes the proposed number of short stay cycle

parking, being 111 as a minimum, as well as the reprovision

of the existing cycle hire parking on Wine Office Court. TfL

welcomes the division between Sheffield stand and two tiered

for the internal short stay cycle parking.

- TfL welcome further discussion for the remainder of the

proposed short stay cycle parking.

Design

- The proposed cycle parking can be accessed level and at-

grade via Shoe Lane, Wine Office Court, Gunpowder Square

and Printer Street. TfL have concerns regarding access to the

proposed location of basement 2 level. Access is from a wide

staircase with cycle channels or ‘suitably sized lifts. To

accommodate all types of cycle, the applicant must confirm

that the proposed lifts have the minimum dimensions of 1.2

by 2.3 metres, with a minimum door opening of 1000mm, and

any door to a cycle parking area should be automated – push

button or pressure pad operated to accommodate larger /

adapted cycles.

- Requirements by the LCDS state that accessing the cycle

parking should involve passing through no more than two sets

of doors, with a recommended minimum external door width

of 2 metres.

Cycle Hire

- Due to the significant uplift in development on the site, there

will be an additional strain on cycle hire capacity in the

surrounding area. This will drive additional pressure onto

mitigating constantly empty docking stations and so

increasing vans and drivers on the roads. TfL therefore

requests a financial contribution and land for a new docking

station to be provided.

- TfL are open to working with the City Corporation and the

applicant to find a location within the vicinity. This should be

addressed before the application is determined so that it can

be secured in the section 106 agreement.

Cycle Promotion Plan

- The applicant has provided a Cycle Promotion Plan as part of

the submission rather than a travel plan which is current

practice for the City of London. However, the document

appears to provide limited measures and targets to

encourage cycling, and this does not appear to be focussed

on visitors. This should be amended accordingly. S106

funding for monitoring the cycle plan should also be secured

with robust cycle mode shift targets in line with the MTS.

Delivery and servicing

- An outline Delivery and Servicing Plan (DSP) is part of the

submission. Delivery and servicing is proposed to take place

off street from existing service yard from Shoe Lane which is

welcomed in line with Policy T7 (Deliveries, servicing, and

construction) part G. The service yard provides 2 large

loading bays capable of accommodating vehicles up to and

including a large refuse vehicle. The proposed development

includes an at grade service yard in the south-east corner of

the site with access retained in the same location but with an

improved layout, The servicing yard is proposed to be

improved and provide 2 loading bays accommodating for

vehicles up to 7.5t box vans. TfL welcomes that the improved

layout enables all vehicles to enter and egress the site in

forward gear.

- Given the location there may be potential conflict with the

main access routes for cyclists and therefore urges the CoL

to ensure that all delivery and servicing activity to take place

outside of peak hours of traffic (AM, PM and lunchtime peaks)

in line with policy T7. The DSP should establish how the

delivery and servicing activity would not increase road danger

or lead to collisions between pedestrians, cyclists, and large

vehicles.

- TfL notes that there is an increase in delivery and servicing

vehicles, it is requested that the applicant demonstrates how

the total expected vehicles will be accommodated in the

loading bays.

- Given the high number of deliveries and servicing TfL

recommends a delivery booking system to avoid queuing onto

roads, as well as avoiding peak hours. The use of cargo bikes

should be encouraged for deliveries in line with sustainability

aims in the London Plan 2021

- The final DSP should be secured through planning condition.

Construction

- A temporary pitlane loading bay is being proposed for

construction vehicle access provided on Little New Street

adjacent to the site, prior to commencement of demolition and

construction works, to have the capacity for two articulated

vehicles. The pitlane arrangement is proposed to require the

suspension of the southern footway on Little New Street

throughout the duration of construction. As Little New Street

is not TLRN, the appropriate licensing must be obtained with

CoL prior to commencement.

- TfL welcomes the use of Banksmen position at the site to aid

directing of vehicles to and from the proposed loading

locations, ensuring efficiency of vehicle manoeuvres avoiding

conflict with road users and the safety of pedestrians. This

includes the access route on Shoe Lane and Little New

Street.

- TfL recommends that construction hours avoid peak traffic

hours and therefore suggest the proposed construction hours

don’t include the time between 8-9:00am and 17-18:00pm to

reduce congestion on the surrounding networks.

- TfL welcomes that vehicles will egress in forward gear from

the loading bay pit lane, proceeding west along New Street

Square and Bartlett Court, before proceeding northbound or

southbound.

- Given the location and scale TfL request the applicant

ensures the site becomes at least FORS / CLOCS silver

accreditation.

- Regarding the staff travel plan, cycle parking allocated for

construction workers should be accompanied with end of use

facilities. See attached link for further guidance,

https://content.tfl.gov.uk/lcds-chapter8-cycleparking.pdf

- The CLP should be secured by condition.

Officer response: Addressed in the ‘Transport’ and ‘Planning

obligations’ sections of the report.

Transport for

London

Safeguarding

Engineer

Confirmed no comments.

Officer response: Addressed in the ‘Transport’ section of the

report.

Twentieth

Century

Society

Provided detailed response which included:

- The Society objects to the demolition of the existing building,

which should be identified as a Non-Designated Heritage

Asset… 1 Little New Street is a historic building of

architectural merit and it contributes positively to the character

and appearance of the area. It should be identified as a Non-

Designated Heritage Asset (NDHA) – it clearly has “a degree

of significance meriting consideration in planning decisions”.

Local planning authorities can identify NDHAs as part of the

decision-making process on planning applications and we

urge you to do so here…To summarise, the Society objects

to the loss of 1 Little New Street and urges the local authority

to identify the building as a Non-Designated Heritage Asset

(NDHA) and to refuse the application on heritage grounds.

Officer response: Addressed in the ‘Design and Heritage’ section

of the report.

Surveyor To

the Fabric Of

St Paul's

A detailed response was received, including identifying harm to

heritage assets.

Officer response: Addressed in the ‘Design and Heritage’ section

of the report.

Letters of Representations

38. A total of 49 representations have been received including from residents

nearby at Pemberton House, Dean Wace House and Wine Office Court

properties comprising four objections and two neutral comments and

Alderwoman Martha Grekos provided a neutral comment.

39. A total of 43 supporting the proposals, these all state: “I am writing to share my

support for the Hill House proposals” with some responses also highlighting

support for the rooftop restaurant, new public realm and library proposals.

40. Responses received can be summarised as follows:

Representations

For residential buildings nearby

including listed building (Wine

Office Court) - requested window

cleaning and façade cleaning

during construction period

including on bi-weekly basis, and

deep clean of façade on

completion of the ground works

and of development, and repaint

all woodwork and painted

elements and metal railings

A condition is recommended to secure

a condition survey for windows and

facades.

There should be no exception to

the City of London quiet rules for

limited construction at weekends.

The Environmental Health were

consulted and recommended conditions

including scheme of protective works

prior to demolition and construction

which includes details for noisy works

hours. The criteria for variations to the

standards noisy working hours are set

out in the Code of Construction Practice.

It may be required in instances related to

public safety or engineering with a

business case.

Privacy and overlooking, and the

current floor levels of Hill House do

not align with the floor levels of

Pemberton House which means

there are no existing direct

sightlines

A condition is recommended to address

overlooking and privacy issues to the

nearby residential properties.

Impact to residential amenity

Environmental Health have been

consulted and recommended

conditions. This is addressed in

‘Environmental Impacts’ section of the

report.

Noise and vibration including in

early morning, late evening and

weekends

Environmental Health have been

consulted and recommended

conditions. This is addressed in

‘Environmental Impacts’ section of the

report.

This would include securing a condition

for a scheme of protective works to be

approved by the Local Planning

Authority.

Dust including on the exterior of

Pemberton House, private spaces

including patio

Environmental Health have been

consulted and recommended

conditions. This is addressed in

‘Environmental Impacts’ section of the

report.

This would include securing a condition

for a scheme of protective works to be

approved by the Local Planning

Authority.

Rubbish including screws, cable

ties, etc left on the street and work

persons sitting on the front steps of

the building or Wine Office Court

Environmental Health have been

consulted and recommended

conditions. This is addressed in

‘Environmental Impacts’ section of the

report.

This would include securing a condition

for a scheme of protective works to be

approved by the Local Planning

Authority.

Road closures and HGV traffic

Conditions are recommended for

construction logistics details to be

approved by the Local Planning

Authority. The proposed condition has

been amended to include restriction of

HGV movement to and from the site to

with in the hours of 9:30 to 16:30

Monday to Friday, 8 till 13:00 Saturdays

and fully restrict movement on Sundays

and Bank Holidays.

Loss of light, including with low

existing levels and Applicant has

not shared details or requested

access to premises to assess.

This is addressed in the ‘Daylight,

Sunlight and Overshadowing’ section of

the report.

Right to light, and not been

contacted by the Applicant

regarding this who is ignoring legal

obligations.

‘Right to light’ is not a material planning

consideration and should be dealt with

outside of the planning process. The

impacts to residential amenity in respect

to daylight and sunlight is addressed in

the ‘Daylight, Sunlight and

Overshadowing’ section of the report.

41. It is noted that all material planning consideration raised in the representations

above are addressed within this report.

Policy Context

42. The Development Plan consists of the London Plan 2021 and the City of

London Local Plan 2015. The London Plan and Local Plan policies that are

most relevant to the consideration of this case are set out in Appendix B to this

report.

43. The City of London (CoL) is preparing a new draft plan, the City Plan 2040,

which will be published for Regulation 19 consultation in the Spring of 2024. It

is anticipated that the City Plan will be submitted to the Secretary of State in

Summer 2024. Emerging policies are considered to be a material

consideration with limited weight with an increasing degree of weight as the

City Plan progresses towards adoption, in accordance with paragraph 48 of

the NPPF. The emerging City Plan 2040 policies that are most relevant to the

consideration of this case are set out in Appendix B to this report.

44. Government Guidance is contained in the National Planning Policy Framework

(NPPF) December 2023 and the Planning Practice Guidance (PPG) which is

amended from time to time.

45. The National Planning Policy Framework (NPPF) states at paragraph 2 that

“Planning Law requires that applications for planning permission must be

determined in accordance with the development plan unless material

considerations indicate otherwise”.

National Planning Policy Framework (NPPF)

46. The NPPF states at paragraph 8 that achieving sustainable development has

three overarching objectives, being economic, social and environmental.

47. Paragraph 10 of the NPPF states that “at the heart of the Framework is a

presumption in favour of sustainable development. That presumption is set out

at paragraph 11.

48. For decision-taking this means:

a) approving development proposals that accord with an up-to-date

development plan without delay; or

b) where there are no relevant development plan policies, or the policies

which are most important for determining the application are out of date,

granting permission unless:

i) the application of policies in this Framework that protect areas or

assets of particular importance provides a clear reason for refusing

the development proposed; or

ii)any adverse impacts of doing so would significantly and demonstrably

outweigh the benefits, when assessed against the policies in this

Framework taken as a whole.

49. Paragraph 48 states that local planning authorities may give weight to relevant

policies in emerging plans according to:

a) the stage of preparation of the emerging plan (the more advanced its

preparation the greater the weight that may be given);

b) the extent to which there are unresolved objections to relevant policies

(the less significant the unresolved objections, the greater the weight that

may be given) and

c) the degree of consistency of the relevant policies in the emerging plan to

this Framework (the closer the policies in the emerging plan to the policies

in the Framework, the greater the weight that may be given).

50. Chapter 6 of the NPPF seeks to build a strong and competitive economy.

Paragraph 85 states that decisions should help create the conditions in which

businesses can invest, expand and adapt. Significant weight should be placed

on the need to support economic growth and productivity, considering both

local business needs and wider opportunities for development.

51. Chapter 8 of the NPPF seeks to promote healthy, inclusive and safe places.

52. Paragraph 96 states that planning decisions should aim to achieve healthy,

inclusive and safe places which promote social interaction, are safe and

accessible and enable and support healthy lifestyles.

53. Paragraph 97 states that planning decision should provide the social,

recreational and cultural facilities and services the community needs.

54. Chapter 9 of the NPPF seeks to promote sustainable transport. Paragraph 109

states that “Significant development should be focused on locations which are

or can be made sustainable, through limiting the need to travel and offering a

genuine choice of transport modes. This can help to reduce congestion and

emissions and improve air quality and public health”.

55. Paragraph 116 states that applications for development should give priority

first to pedestrian and cycle movements and second to facilitating access to

high quality public transport; it should address the needs of people with

disabilities and reduced mobility in relation to all modes of transport; it should

create places that are safe, secure and attractive and which minimise the

scope for conflicts between pedestrians, cyclists and vehicles; it should allow

for the efficient delivery of goods and access by service and emergency

vehicles.

56. Paragraph 117 states that “All developments that will generate significant

amounts of movement should be required to provide a travel plan, and the

application should be supported by a transport statement or transport

assessment so that the likely impacts of the proposal can be assessed”.

57. Chapter 11 of the NPPF seeks to achieve effective use of the land. Paragraph

123 advises that “Planning policies and decisions should promote an effective

use of land in meeting the need for homes and other uses, while safeguarding

and improving the environment and ensuring safe and healthy living

conditions.”

58. Chapter 12 of the NPPF seeks to achieve well designed places. Paragraph

131 advises that “The creation of high quality, beautiful and sustainable

buildings and places is fundamental to what the planning and development

process should achieve. Good design is a key aspect of sustainable

development, creates better places in which to live and work and helps make

development acceptable to communities.”

59. Paragraph 135 sets out how good design should be achieved including

ensuring developments function well and add to the overall quality of the area,

not just for the short term but over the lifetime of the development, are visually

attractive as a result of good architecture, layout and appropriate and effective

landscaping, are sympathetic to local character and history, including the

surrounding built environment and landscape setting, while not preventing or

discouraging appropriate innovation or change (such as increased densities),

establish or maintain a strong sense of place, using the arrangement of streets,

spaces, building types and materials to create attractive, welcoming and

distinctive places to live, work and visit; optimise the potential of the site to

accommodate and sustain an appropriate amount and mix of development

(including green and other public space) and create places that are safe,

inclusive and accessible and which promote health and wellbeing.

60. Paragraph 136 of the NPPF states that “Trees make an important contribution

to the character and quality of urban environments and can also help mitigate

and adapt to climate change. Planning policies and decisions should ensure

that new streets are tree-lined, that opportunities are taken to incorporate trees

elsewhere in developments (such as parks and community orchards), that

appropriate measures are in place to secure the long-term maintenance of

newly planted trees, and that existing trees are retained wherever possible...”.

61. Paragraph 139 sets out that significant weight should be given to outstanding

or innovative designs which promote high levels of sustainability or help raise

the standard of design more generally in an area, so long as they fit in with the

overall form and layout of their surroundings.

62. Chapter 14 of the NPPF relates to meeting the challenge of climate change.

Paragraph 152 states that the planning system should support the transition to

a low carbon future in a changing climate. It should help to; shape places in

ways that contribute to radical reductions in greenhouse gas emissions,

minimise vulnerability and improve resilience; encourage the reuse of existing

resources, including conversion of existing buildings.

63. Paragraph 159 states that new developments should avoid increased

vulnerability to the range of impacts arising from climate change. When new

development is brought forward in areas which are vulnerable, care should be

taken to ensure that risks can be managed through suitable adaptation

measures.

64. Chapter 15 of the NPPF seeks to conserve and enhance the natural

environment. Paragraph 180 of the NPPF advises that planning policies and

decisions should contribute to and enhance the natural and local environment

by, inter alia, minimising impacts on and providing net gains for biodiversity,

including by establishing coherent ecological networks that are more resilient

to current and future pressures. It is also stated that development should,

wherever possible, help to improve local environmental conditions such as air

and water quality.

65. Local Planning Authorities should identify and assess the particular

significance of any heritage asset that may be affected by a proposal (including

by development affecting the setting of a heritage asset) taking account of the

available evidence and any necessary expertise. They should take this into

account when considering the impact of a proposal on a heritage asset, to

avoid or minimise any conflict between the heritage asset’s conservation and

any aspect of the proposal.

66. Chapter 16 of the NPPF relates to conserving and enhancing the historic

environment. Paragraph 201 of the NPPF advises that Local Planning

Authorities should identify and assess the particular significance of any

heritage asset that may be affected by a proposal (including by development

affecting the setting of a heritage asset) taking account of the available

evidence and any necessary expertise. They should take this into account

when considering the impact of a proposal on a heritage asset, to avoid or

minimise any conflict between the heritage asset’s conservation and any

aspect of the proposal.

67. Paragraph 203 of the NPPF advises, “In determining applications, local

planning authorities should take account of:

a) the desirability of sustaining and enhancing the significance of heritage

assets and putting them to viable uses consistent with their conservation;

b) the positive contribution that conservation of heritage assets can make to

sustainable communities including their economic vitality; and

c) the desirability of new development making a positive contribution to local

character and distinctiveness.”

68. Paragraph 205 of the NPPF advises “When considering the impact of a

proposed development on the significance of a designated heritage asset,

great weight should be given to the asset’s conservation (and the more

important the asset, the greater the weight should be). This is irrespective of

whether any potential harm amounts to substantial harm, total loss or less than

substantial harm to its significance.”

69. Paragraph 206 states that “any harm to, or loss of, the significance of a

designated heritage asset (from its alteration or destruction, or from

development within its setting), should require clear and convincing

justification. Substantial harm to or loss of:

a) grade II listed buildings, or grade II registered parks or gardens, should

be exceptional;

b) assets of the highest significance, notably scheduled monuments,

protected wreck sites, registered battlefields, grade I and II* listed buildings,

grade I and II* registered parks and gardens, and World Heritage Sites,

should be wholly exceptional.”

70. Paragraph 208 of the NPPF states “Where a development proposal will lead

to less than substantial harm to the significance of a designated heritage asset,

this harm should be weighed against the public benefits of the proposal

including, where appropriate, securing its optimum viable use”.

71. Paragraph 209 of the NPPF states “The effect of an application on the

significance of a non-designated heritage asset should be taken into account

in determining the application. In weighing applications that directly or

indirectly affect non-designated heritage assets, a balanced judgement will be

required having regard to the scale of any harm or loss and the significance of

the heritage asset”.

Statutory Duties

72. The Corporation, in determining the planning application has the following

main statutory duties to perform:

• To have regard to the provisions of the development plan, so far as

material to the application and to any other material considerations.

(Section 70 Town & Country Planning Act 1990);

• To determine the application in accordance with the development plan

unless other material considerations indicate otherwise. (Section 38(6) of

the Planning and Compulsory Purchase Act 2004).

73. In considering whether to grant planning permission for development which

affects a listed building or its setting, to have special regard to the desirability

of preserving the building or its setting or any features of special architectural

or historic interest which it possesses. (S66 (1) Planning (Listed Buildings and

Conservation Areas) Act 1990).

74. In exercising planning functions with respect to buildings or land in a

conservation area, there is a statutory duty to pay special attention to the

desirability of preserving or enhancing the character or appearance of that

area. (S72(1) Planning, Listed Buildings and Conservation Areas Act 1990).

Main Considerations

75. In determining the planning application before you, consideration has to be

taken of the documents accompanying the application, the updated

information, the consultation responses, the development plan, and other

material considerations including SPGs, SPDs and emerging policy.

76. There are policies in the Development Plan which support the proposal and

others which do not. It is necessary to assess all the policies and proposals in

the plan and come to a view as to whether in light of the plan as a whole the

proposal does or does not accord with it.

77. The principal issues in considering this application are:

a) The extent to which the proposals comply with Government policy advice

(NPPF) and with the relevant policies of the Development Plan.

b) The principle of development, including the proposed mainly office led use

and associated retail uses and culture/community uses.

c) The replacement of the public library (key City social infrastructure).

d) The economic impact of the proposal.

e) The impact of the development on the character and appearance of the

area and the design of the building itself.

f) The impact of the development on designated and non-designated

heritage assets.

g) The impact on strategic views in the London Views Management

Framework and on other strategic local views.

h) The impact of the development on public realm.

i) The impact of the development on ecology.

j) The accessibility and inclusivity of the development

k) The impact of the development on any potential archaeological assets

beneath the site.

l) The impact on the development on highway and transportation terms.

m) The impact of the development in terms of energy, sustainability and

climate change.

n) The impact of the development on air quality.

o) The impact of the proposed development on the amenity of nearby

residential and other occupiers.

p) The impact of the development on health and wellbeing.

q) The impact of the development on fire safety.

r) The impact on the development on flood risk.

s) The requirement for the development to secure financial contributions and

planning obligations.

t) Duties under the Public Sector Equality Duty (section 149 of the Equality

Act 2010)

u) The Human Rights Act 1998

Principle of Development – Economic impact of the proposal

78. The National Planning Policy Framework places significant weight on ensuring

that the planning system supports sustainable economic growth, creating jobs

and prosperity.

79. The National Planning Policy Framework establishes a presumption in favour

of sustainable development and advises that significant weight should be

placed on the need to support economic growth and productivity, taking into

account both local business needs and wider opportunities for development.

It also states that planning decisions should recognise and address the specific

locational requirements of different sectors.

80. The City of London is a world leading international financial and professional

services centre and has a nationally important role in the economy. The

intense concentration of business occupiers in a small area is a key part of the

attraction for companies looking to move into the City. The clustering of

businesses is a vital part of the City’s operation and contributes to its reputation

as a dynamic place to do business as well as providing agglomeration benefits.

The City lies wholly within London’s Central Activity Zone (CAZ) where the

London Plan promotes further economic and employment growth.

81. To maintain this position, it is vital to ensure that sufficient office floorspace is

available to meet projected employment growth and occupier demand and that

additional office development is of high quality and suitable for a variety of

occupiers. The Draft Local Plan 2040 sets out that the overall office floorspace

target of 1,200,000m2 is derived from the estimated growth in office

employment between 2021 and 2040 and represents a 13% increase in

floorspace. Capacity modelling demonstrates that there are sufficient sites to

meet this demand, provided primarily within the City Cluster area,

supplemented by additional capacity elsewhere in the City.

82. Alongside changes in the mix of businesses operating in the City, the City’s

workspaces are becoming more flexible and able to respond to changing

occupier needs. Offices are increasingly being managed in a way which

encourages flexible and collaborative working and provides a greater range of

complementary facilities to meet workforce needs. There is increasing demand

for smaller floor plates and tenant spaces, reflecting this trend and the fact that

many businesses in the City are classed as Small and Medium Sized

Enterprises (SMEs). The London Recharged: Our Vision for London in 2025

report sets out the need to develop London’s office stock (including the

development of hyper flexible office spaces) to support and motivate small and

larger businesses alike to re-enter and flourish in the City.

83. The City lies wholly within London’s Central Activity Zone (CAZ) where the

London Plan promotes further economic and employment growth. The London

Plan 2021 strongly supports the renewal of office sites within the CAZ to meet

long term demand for offices and support London’s continuing function as a

World City. The Plan recognises the City of London as a strategic priority and

stresses the need ‘to sustain and enhance it as a strategically important,

globally-oriented financial and business services centre’ (policy SD4). CAZ

policy and wider London Plan policy acknowledge the need to sustain the

City’s cluster of economic activity and provide for exemptions from mixed use

development in the City in order to achieve this aim.

84. London Plan Policy GG2 sets out the Mayor’s good growth policy with regard

to making the best use of land. These include prioritising sites which are well-

connected by existing or planned public transport; proactively explore the

potential to intensify the use of land to support additional homes and

workspaces, promoting higher density development, particularly in locations

that are well-connected to jobs, services, infrastructure and amenities by public

transport, walking and cycling; applying a design–led approach to determine

the optimum development capacity of sites; and understanding what is valued

about existing places and use this as a catalyst for growth, renewal, and place-

making, strengthening London’s distinct and varied character.

85. London Plan Policy GG5 sets out the Mayor’s good growth policy with regard

to growing London’s economy. To conserve and enhance London’s global

economic competitiveness and ensure that economic success is shared

amongst all Londoners, it is important that development, amongst others,

promotes the strength and potential of the wider city region; plans for sufficient

employment and industrial space in the right locations to support economic

development and regeneration; ensure that London continues to provide

leadership in innovation, research, policy and ideas, supporting its role as an

international incubator and centre for learning; promote and support London’s

rich heritage and cultural assets, and its role as a 24-hour city; and makes the

fullest use of London’s existing and future public transport, walking and cycling

network, as well as its network of town centres, to support agglomeration and

economic activity.

86. London Plan policy E1 supports the improvement of the quality, flexibility and

adaptability of office space of different sizes.

87. Strategic Objective 1 in the City of London Local Plan 2015 is to maintain the

City’s position as the world’s leading international financial and business

centre. Policy CS1 aims to increase the City’s office floorspace by

1,150,000sq.m gross during the period 2011-2026, to provide for an expected

growth in workforce of 55,000. The Local Plan, policy DM1.2 further

encourages the provision of large office schemes, while DM1.3 encourages

the provision of space suitable for SMEs. The Local Plan recognises the

benefits that can accrue from a concentration of economic activity and seeks

to strengthen the cluster of office activity.

88. Policy OF1 (Office Development) requires offices to be of an outstanding

design and an exemplar of sustainability.

89. Despite the short-term uncertainty about the pace and scale of future growth

in the City following the immediate impact of Covid-19, the longer term

geographical, economic and social fundamentals underpinning demand

remain in place and it is expected that the City will continue to be an attractive

and sustainable meeting place where people and businesses come together

for creative innovation. The recently prepared ‘Future of Office Use’ evidence

base report for the City Plan 2040, highlights that the demand for best in class

office space is higher than pre-pandemic. Local Plan and draft City Plan 2040

policies seek to facilitate a healthy and inclusive City, new ways of working,

improvements in public realm, urban greening and a radical transformation of

the City’s streets in accordance with these expectations. These aims are

reflected in the Corporations ‘Destination City’ vision for the square mile.

90. In addition, the draft City Plan 2040 identifies the ‘Fleet Valley’ tall building area

for the delivery of the required office accommodation.

Provision of Office Accommodation

91. Policy SD5 of the London Plan advises that offices and other CAZ strategic

functions are to be given greater weight relative to new residential

development within the City.

92. Strategic Policy CS1 of the City of London Local Plan 2015 and policy E1 of

the London Plan seeks to ensure that there is sufficient office space to meet

demand and encourages the supply of a range of office accommodation to

meet the varied needs of City occupiers. Policy DM 1.2 supports large office

schemes in appropriate location. Policy DM 1.3 of the Local Plan seeks to

promote small and medium sized businesses in the City by encouraging new

accommodation suitable for small and medium sized businesses and office

designs which are flexible and adaptable to allow for subdivision to meet the

needs of such businesses.

93. Draft Strategic Policy S4 (Office) sets out that the City Corporation will facilitate

significant growth in office development of the highest quality to meet projected

economic and employment growth by Increasing the City’s office floorspace

stock by a minimum of 1,200,000 m2 net during the period 2021 to 2040.

94. The proposed development would provide predominantly an office-led

development. It is predicted to result in estimated 2,986 Full Time Equivalent

(FTE) jobs. The proposed development would deliver an increase of in Grade

A office floorspace on the Cluster, contributing to the achievement of the office

floorspace target in both the adopted and emerging draft Local Plans.

95. The proposed development would result in an additional 38,941 sqm GEA of

high quality, flexible Class E office floorspace and includes a smaller unit for

affordable workspace suitable for SMEs. The office spaces are designed to

support a range of tenants across a range of corporate sector companies, with

flexibility to enable to extend across floors, to use part of individual floors

through the creation of dividable and flexible space. Emerging City Plan Policy

S4 encourages new floorspace to be designed to be flexible to allow adaptation

of space for different types and sizes of occupiers.

96. A range of office floorspace is required to meet the future needs of the City’s

office occupiers, including provision for incubator, start-ups and co-working

space. The S106 agreement would include an obligation to make specific and

identified provision within the development for such occupiers. Policy S4 of the

emerging City Plan encourages the provision of affordable office workspace

that allows small and growing businesses the opportunity to take up space

within the City. Policy E1 of the London Plan also highlights the need for

providing affordable workspace to new offices. This provision will be secured

through the S106 agreement.

97. The proposed development would provide a primarily office lead development,

providing a significant uplift in the number of full time jobs, as well as a

significant uplift in the office floorspace. Therefore, the proposed development

would support the strategic objectives of the development plan and the

emerging City Plan. The economic benefits of the proposed development

would be material and would weigh in favour of the proposed development.

98. For the reason stated above, it is considered that the scheme meets the aims

of policies in the London Plan, CS1, DM1.2 and DM1.3 of the Local Plan 2015,

S4 of the emerging City Plan 2040 and E1 of the London Plan in delivering

growth in both office floorspace and employment. The proposals provide for

an additional increase in floorspace and employment in line with the

aspirations for the CAZ and the requirements of the Local Plan and the

emerging City Plan. The proposed development would result in a significant

amount of additional, high quality, flexible Class E office floorspace for the City,

contributing to its attractiveness as a world leading international financial and

professional services centre.

Proposed retail and other commercial uses

99. Policy DM 1.5 encourages mixed commercial uses within office development

which contribute to the City’s economy and character and provide support

services for its businesses, workers and residents. Similar support of other

commercial uses particularly at ground and basement levels is also supported

by policy OF1 of the emerging City Plan.

100. The proposed development supports a range of Class ‘E’ uses with café/retail

use at ground and a restaurant at level 17, and a flexible gym / auditorium use

at basement level.

101. Although the site does not fall within a primary shopping area, it is already

occupied by a bar use at ground and lower ground floors.

102. Active retail frontage would be retained across the ground floor across the Site.

Therefore, the proposal would support the main function of the City and the

aims of the development plan and accord with the relevant planning policies,

as stated above.

Provision of flexible library (Use Class F1) and affordable workspace

(Use Class E)

Relevant policy

103. The NPPF states development should provide the social, recreational and

cultural facilities and services the community needs.

104. The London Plan Good Growth objective GG1 is considered applicable to the

provision of community use within development proposals.

105. The Site falls within the CAZ and London Plan Policy SD4 outlines that within

this area the unique concentration and diversity of cultural and arts functions

should be promoted and enhanced.

106. Policy HC5 of the London Plan recognises that the continued growth and

evolution of London’s diverse cultural facilities and creative industries should

be supported, and cultural facilities includes libraries.

107. London Plan Policy S1 supports proposals for social infrastructure and defines

this as services and facilities that meet local and strategic needs and contribute

towards a good quality of life including education and community uses.

108. Policy CS11 of the London Plan seeks to maintain and enhance the City’s

contribution to London’s world-class cultural status and to enable the City’s

communities to access a range of arts, heritage and cultural experiences and

should be providing, supporting, encouraging access to and further developing

a wide range of creative and cultural spaces and facilities across the City. Draft

Plan Policy CV2 states that all major developments should be supported by a

Cultural Plan outlining how the development will contribute to the enrichment

and enhancement of the City’s cultural offer.

109. Local Plan Policy CS22 protects existing social infrastructure in the City stating

there should be no overall loss of community facilities in the City where a need

exists.

110. Local Plan Policy DM22.1 states loss of social and community facilities should

be resisted unless replacement facilities are provided on-site or within the

vicinity which meet the needs of the users of the existing facility and states

new social and community facilities should provide flexible, multi-use space

suitable for a range of different uses and will be permitted:

• where they would not be prejudicial to the business City and where there

is no strong economic reason for retaining office use;

• in locations which are convenient to the communities they serve;

• in or near identified residential areas, providing their amenity is

safeguarded;

• as part of major mixed-use developments, subject to an assessment of

the scale, character, location and impact of the proposal on existing

facilities and neighbouring uses.

111. Emerging Strategic Policy S1 of the draft City Plan 2040 supports facilities for

the provision and improvement of social and educational services through the

City’s libraries. Similar requirements are set in Draft City Plan 2040 policy HL5.

112. Supporting text for Policy S6 of draft City Plan outlines that the City of London

will support and encourage access to and development of a wide range of

creative and cultural spaces and facilities across the City. Supporting text 8.1.0

states ‘…that the City of London contains a huge concentration of arts, leisure,

recreation and cultural facilities and spaces that contribute to its uniqueness

and complement its primary business function’ and that these include creative

workspaces and libraries.’

113. Emerging Policy CV2 of the Draft City Plan 2040 encourages the provision of

facilities that meet the need of visitors including libraries.

114. London Plan Policy E1 states that development proposals related to new or

existing offices should take into account the need for a range of suitable

workspace including lower cost and affordable workspace. Policy E3 of the

Plan states planning obligations may be used to secure affordable workspace

at rents maintained below the market rate for that space for a specific social,

cultural or economic development purpose.

Existing and proposed library

115. There is an existing City of London Corporation Library (Shoe Lane Library) at

the Site at basement level comprising 1,016 sqm (GEA) with the entrance at

the northeast corner.

116. Shoe Lane Library is one of the City’s three lending libraries. There are few

local residents and most of the library’s customers are City workers and

families. Prior to the pandemic, it was one of the busiest and best-used libraries

of its size in London and the second busiest public library in the City.

117. Shoe Lane is the home of the Dragon Café in the City, a highly successful

partnership with the charity Mental Fight Club which provides a programme of

regular digital and physical activities to support and promote good mental

health. It also has its own very popular events programme, working in

collaboration with partners such as Kings College and Westminster Abbey,

and a thriving offer for children under five and their families, as part of the

Children’s Centre Services for the City of London.

118. The libraries team have identified the need for additional rooms that can be

hired out to generate income.

119. The Applicant proposes providing a library use (1,040 sqm GEA), and

additional floorspace at upper ground mezzanine level for flexible library and

affordable office floorspace (638 sqm GEA).

120. The Applicant has agreed the principle of providing a temporary library at

basement level at One New Change for up to five years whilst the

Development at Hill House in underway; a planning application for change of

use at One New Change is to be submitted imminently and would be secured

through obligation.

121. The principle of relocation and redevelopment for the library has been

considered at City of London Committees including at the Culture, Heritage

and Libraries (CHL) for decisions on 13 December 2021 and 14 November

2022, and Community & Children’s Services (CCS) for information on 23

January 2023.

122. In the CHL meetings, members gave approval to enter into non-binding

negotiations with the Development and agreed to the temporary relocation of

the library and delegated authority to the Town Clerk, in consultation with the

Chair and Deputy Chair, to approve future decisions on the detail of the agreed

terms with the Applicant if they need to be made in advance of the next

Committee meeting. The Libraries team has provided an update to the Chair

and Deputy Chair on the discussions to date for the Section 106, as set out in

this report.

123. If this application is approved, a further update is expected to be provided at a

later CHL Committee and CCS Committee in advance of signing a Section 106

Agreement. The heads of terms for the relocation of the library are therefore

subject to members decisions at these committees.

124. The proposed library would be based at ground and mezzanine level through

a dedicated entrance leading from Gunpowder Square at the southwest corner

of the site. The existing library entrance is considered less visible with limited

active frontage with the facilities at basement level with a small frontage at

ground floor level. Therefore the proposal is considered an enhancement to

the existing library due to significant active frontage and facilities accessible at

ground floor level, which would be linked to new landscaped high quality public

realm significantly enhancing the library entrance.

125. The proposal would also provide meeting rooms in the main library demise

which could be used to generate income, which will be secured through

planning obligation. In addition, the Applicant is providing the opportunity for

additional space to be used as library and affordable workspace (outside the

core library demise) with a further opportunity to generate income for the

Libraries Team. This would be secured through planning obligation.

126. A Library Management Plan has been provided which includes indicative

layouts and proposed uses, and Section 106 obligations would require future

detail for this.

127. The Section 106 obligation would be required to secure the provision of a

library for the City of London Corporation. The details to be agreed through a

Section 106 obligation to secure this use are set out in the ‘City Planning

Obligations’ section of the report.

Fallback Financial Security

128. In order to safeguard the library re-provision, the Corporation is requiring

financial security in the form of a payment or guarantee which will ensure that

the Corporation can deliver a library in the West of the City in the event that

Landsec fails to deliver in accordance with the agreed timetable. This is to be

secured at part of the Section 106.

Relocation of Library

129. The Applicant will obtain all necessary consents for the temporary relocation

to One New Change and if it is unsuccessful it will provide details of alternative

sites and obtain consents for the alternative site, to be secured by obligation.

The library will remain in the temporary location until the permanent space at

Hill House has been completed however if Hill House has not been completed

by a long stop date the Corporation will be able to drawdown on the security

provided by the Applicant to find an alternative permanent site for the library.

130. The relocation costs of the move to the temporary library, and the return to the

permanent library, are to be covered by the Applicant.

131. The submission of the following would be required by the Applicant prior to any

significant works commencing on site:

• Decanting Strategy;

• Temporary Library Management Plan, Inventory and Specification, to

include details of contents, design and layout;

• Permanent Library Management Plan, Inventory and Specification, to

include details of contents, design and layout;

• Confirmation that the Temporary Library Lease and the Permanent Library

Agreement for Lease have been entered into.

New Library facilities

132. The Agreement will secure that the Applicant cannot occupy the development

until the library has been fitted out and is available for occupation by the library.

133. The Applicant will meet the costs and carry out works for the fit out and

furnishing of the new library in accordance with the Permanent Library

Inventory and Specification (to be agreed).

134. The current lease expires in March 2035. Draft Heads of Terms for the new

library space have been submitted to the City Surveyors by the Applicant and

are currently being considered. These terms are reflected within the Section

106 negotiations. These terms include peppercorn rent for the lease term of

65 years with a reasonable cap on service charge with commercially improved

terms to the existing lease to be agreed

135. A rolling Landlord development break option from 25 years has been

requested by the Applicant, which would only be exercised in the event of

redevelopment of the site which would require planning permission. The

Section 106 agreement and lease Heads of Terms will require the reprovision

of the library in an alternative location at that time, at no cost to the Corporation

should the break be exercised. The Corporation, as planning authority, can

also secure the reprovision of the library at that time in a new S106 agreement

tied to any new planning permission.

136. If approved, the draft heads of terms for both the temporary and permanent

lease would be appended to the Section 106 Agreement.

137. The Applicant has agreed to provide a Changing Places toilet and a lift within

the library demise. The cost of maintenance of Changing Places Toilet and of

a platform lift from ground to mezzanine in the main library demise is to be

maintained by the Applicant for the life of the Development, to be secured by

obligation.

Affordable workspace and hireable rooms in main library demise

138. The Applicant has confirmed that the workspace at mezzanine level will be for

flexible use of the library and affordable workspace, therefore would be utilised

for a mixture of both. The Section 106 will secure this for affordable workspace

and the library will have the opportunity to operate this and generate profit. If

not operated by the library the affordable workspace will be operated by the

Applicant, and remain as affordable workspace.

139. For the affordable workspace, a reasonable cap on service charge is to be

agreed and the Applicant has confirmed that additional service charge would

not be payable for the first three years or before the affordable workspace

becomes profitable, if this is being operated by the Libraries team.

140. The Section 106 will secure the use of meeting rooms in the main library

demise and the affordable workspace for the use and profit of the library.

141. An Affordable Workspace Management Plan will be secured by obligation.

Public rooftop terrace access

142. Regular access for community uses has been agreed in principle with the

Applicant to the floorspace and terrace located at the top of the building on the

level.

143. This is to be secured by Section 106 obligation and would include weekly

access on Friday mornings, fortnightly access for the Dragon Café or other

similar health and wellbeing or library uses, exclusive access for four

weekends (Friday-Sunday) a year for library events and the option to apply for

weekend exclusive use for an additional 22 weekends of the year for library or

community related activities and an obligation will secure this access.

Cultural Strategy

144. The applicant has submitted a Cultural Strategy with the application which sets

out the key elements of the proposal include:

• Creating an easily accessible library space with expanded services to cater

to various needs.

• Exclusive quarterly access (Friday-Sunday) to the Level 18 rooftop office

amenity level for programmed library and cultural events.

• Exclusive weekend access (Saturday-Sunday) to the Level 18 rooftop office

amenity level for up to 22 weekends per year for cultural events programmes

in the City.

• Fortnightly Level 18 rooftop office level amenity access for the Dragon Cafe

events and meetings.

• Designing a flexible workspace within the library to serve both the

community and SMEs/freelancers.

• Establishing an Apprentice Hub for learning and community-building.

• Introducing artistic interventions to celebrate the local heritage of the Fleet

Street area

145. Subject to a Cultural Management Strategy to be secured via S106, it is

considered that the policies referred to above would be complied with.

Sustainability Considerations

Circular Economy

146. London Plan Policy SI7 (‘Reducing waste and supporting the circular

economy’) sets out a series of circular economy principles that major

development proposals are expected to follow. The Local Plan Policies CS15

and DM 17.2 set out the City’s support for circular economy principles.

147. The application includes considerations as to whether there is an opportunity

to retain and refurbish the building or building elements currently on site.

148. The existing Hill House was completed in 1979. The building comprises seven

storeys above ground level including a plant floor, and it has two basement

levels. It is of brutalist design, clad in pre-cast concrete panels, and it has

strongly articulated features, such as the stair and lift towers facing east and

west that are prominent due to the progressively set back levels 04 to 07. The

base of the building is set back from the dominant facade line, with columns

expressed around the perimeter. Typical office floorplate structural slab to

structural slab level heights are 3.97 m with a 0.4m slab zone.

149. The foundations are designed to be suitable for a much taller building. It was

discovered in records that the initial design of the site was to accommodate a

tower construction with a deep basement; however, this plan was scrapped in

1964. Instead, the current building was developed on the foundations for the

tower and diaphragm walls including partially excavated basement before the

project was halted and redesigned.

150. A pre-redevelopment audit, a pre-demolition audit and a materials audit have

been undertaken. As part of the pre-redevelopment audit, 6 options were

considered:

Option A: minor refurbishment with partial ground floor extension, 100% of

substructure and 90% of superstructure retained

Option B1: minor refurbishment with partial ground floor extension and minor

extension to upper levels, 100% of substructure and 90% of

superstructure retained

Option B2: major refurbishment of retained substructure and 4-storey

superstructure and 7-storey extension, 99% of substructure and

46% of superstructure retained

Option B3: major refurbishment of retained substructure and 4-storey

superstructure with a 14-storey extension, new core, 93% of

substructure and 32% of superstructure retained

Option C: redevelopment above ground with18 storeys with retention of

91% of substructure and 0% of superstructure

Option D: full redevelopment

151. Subsequently, the following options were discounted:

Option A: The existing building would not meet the required modern office

quality and the spatial vision for the site as set out elsewhere in

this report.

Option B2: This option was optimised to form option B2+ with an adapted

core to enable a larger extension to achieve a 15-storey building

Option B3: This option was optimised to form option B3+ with a more

generously adapted ground floor to improve the library and

interface with the public realm

Option D: The replacement of the basement and foundations would

increase the carbon footprint by 29.27% compared to option C,

and as the retention of those elements are considered feasible,

option D was discounted.

152. The remaining 4 options B1, B2+, B3+ and C were considered in more detail.

153. Option B1 retains the majority of the building and includes refurbishment and

the extension of levels 4 and 5. This option would not result in much demolition,

however, it would not address the main shortcomings of the building, in

particular its lack of ground floor – public realm relationship and of occupier

amenity and greening, and therefore would only be a short term solution before

major works would become necessary.

154. Option B2+ removes the top 4 floors to be replaced with 7 storeys to create a

11-storey building with larger floorplates – the size is determined by the

retention of the core in order to minimise structural intervention that limits the

number of additional lifts and the potentials to improve the arrangement of

core, lift lobbies and the quality of office floorspaces.

155. Option B3+ retains the same extent of substructure and superstructure with

the exception of incorporating a larger core on the retained upper floors and

basements to allow for greater height. This would unlock a number of

constraints relating to the ground floor and upper floor plates, however the

lower 3 retained office floor levels would not be of the same high quality as the

new built floors.

156. Option C is the redevelopment of the building from ground floor upwards, to

create highest quality office floorspace and relationship with the public realm.

This option would still retain 91% of the substructure and avoid increased

complexity in demolition and temporary works to retain parts of the 4 upper

floors that would result in a longer construction programme. Option C therefore

has been developed for the application scheme.

157. Overall, the analysis of the options with regard to circular economy

demonstrates that the retention of higher percentages of existing

superstructure would not provide an attractive ground floor and public realm

relationship or highest quality office floorspace as has been developed in the

local area in recent years. However, the materials have been catalogued and

assessed for further reuse opportunities in form of an upcycling catalogue and

a façade panel reuse study, to ensure that deconstruction material resulting

from the preferred option C can be reused at highest values. This forms a

substantial basis for improving the material reuse opportunities at later project

stages, and the confirmation of details will be required through a condition.

158. The submitted Circular Economy Statement for the planning application

scheme describes the strategic approach to incorporating circularity principles

and actions into the proposed new development, in accordance with the GLA

Circular Economy Guidance.

159. The circular economy strategy includes details to support reuse and recycling

of existing materials within the new built elements identified in the pre-

demolition audit, as well as identifies an efficient materials strategy for all new

elements, to include:

• Reuse of 90% of the substructure, and 57% of retained materials of the

existing building, with strengthening and reconfiguration works that aim to

use a high recycled content

• Identification of reuse opportunities of the deconstruction materials

• Structural standardisation to minimise wastage rates and optimised

structure (e.g through post-tensioned slabs)

• Design of the façade system with reverse mullions that provide external

solar shading without additional external building elements, and maximum

use of recycled aluminium

• Modular nature of core plant installations for easy repair, maintenance and

disassembly

• Flexibility and adaptability of internal layout and fit-out

• Consideration to prepare material passports for the new building.

160. Confirmation of the proposed measures and identified opportunities through

an update to the Circular Economy Statement and a post-completion update

in line with the Mayor’s guidance on Circular Economy Assessments to confirm

that high aspirations can be achieved are required by condition.

Operational energy strategy and carbon emissions

161. The Energy Statement accompanying the planning application demonstrates

that the proposed development has been designed to achieve an overall 13%

reduction in regulated carbon emissions compared with a Building Regulations

Part L 2021 compliant building.

162. Energy demand and the risk of overheating would be reduced by including the

following key passive design measures:

• High levels of envelope insulation to reduce energy demand

• Airtight construction to prevent heat loss

• Optimised façade design to mitigate overheating risk and reduce cooling

demand whilst maximising daylight to reduce the use of artificial lighting

• Highly efficient facade with automated blinds to prevent excessive solar

gains

• External solar shading with solar control glass to help reduce unwanted

solar gains

163. The following energy-efficient plant is proposed:

• High-efficiency mechanical ventilation systems with heat recovery

• Low energy lighting throughout with daylight and occupant detection

• System controls and diagnostics systems to operate the building

effectively

• Metering and sub-metering to monitor energy use and by dwelling,

enabling energy use and occupant behavioural learnings and subsequent

adjustments to improve building energy demand post occupancy.

164. The strategy would reduce the new building’s operational carbon performance

by 6% beyond Part L 2021.

165. There is currently no available district heating network close enough to the site,

and the opportunity to connect into a future district heating network would be

incorporated into the basement of the proposed development.

166. In relation to low and renewable energy technologies, a system of air source

heat pumps and water source heat pumps, and rooftop mounted PV array of

52 sqm would provide low carbon and renewable energy, reducing the

operational carbon emissions by 7% compared to a Building Regulations 2021

compliant building.

Energy Use Intensity (EUI)

167. The adopted GLA energy assessment guidance (2022) requires developments

to calculate the EUI, a measure of total energy consumed in a building annually

including both regulated and unregulated energy, as well as the space heating

demand. For offices, the GLA targets an ambitious EUI of 55

kWh/m2(GIA)/year and a space heating demand of 15 kWh/m2(GIA)/year. The

estimated EUI from the proposed development is 75.8 kWh/m2/year and for

the space heating demand 5.0 kWh/m2/year. These values present equipment

consumptions from both the landlord and tenant perspective. They are based

on speculative allowances that will be reviewed in more detail to provide more

accurate estimations in the next stages.

168. The site-wide energy strategy does not meet the London Plan target of 35%

carbon emission savings compared to a Part L 2021 compliant scheme.

However, the calculated 13% reduction is broadly in line with other City office

developments approved since the adoption of Part L 2021 that now includes

low carbon heating for non-residential developments in the baseline, but not

for residential developments.

169. A S106 clause will be included requiring reconfirmation of this energy strategy

approach at completion stage and carbon offsetting contribution to account for

any shortfall against London Plan targets, for the completed building. There

will also be a requirement to monitor and report the post construction energy

performance to ensure that actual operational performance is in line with

GLA’s zero carbon target in the London Plan.

BREEAM

170. Four BREEAM New Construction 2018 pre-assessments have been

undertaken, one each for the offices, library, retail and gym uses targeting

“outstanding” ratings for each:

• Offices (shell and core): 90.8%

• Library (fully fitted): 91.4%

• Retail (shell and core): 88.5%

• Gym (shell and core): 88.1%.

171. The pre-assessments are on track to achieve a high number of credits in the

City of London’s priority categories of Energy, Water, Pollution and Materials,

as well as the climate resilience credit in the Waste category.

172. The BREEAM pre-assessment results comply with Local Plan Policy CS15

and draft City Plan 2040 Policy DE1. Post construction BREEAM assessments

are required by condition.

NABERS UK

173. This certification scheme rates the energy efficiency of a commercial building

from 1 to 6 stars over a period of 12 months of operation. The applicants are

signing up to this scheme, targeting a 5 star rating (out of 6 stars possible)

which will contribute to reducing common performance gaps between

modelled and actual energy use intensity.

Whole life-cycle carbon emissions

174. London Plan Policy SI 2 (Minimising greenhouse gas emissions) requires

applicants for development proposals referable to the Mayor (and encouraging

the same for all major development proposals) to submit a Whole Life-Cycle

Carbon assessment against each life-cycle module, relating to the product

sourcing stage, construction stage, the building in use stage and the end-of-

life stage. The assessment captures a building’s operational carbon emissions

from both regulated and unregulated energy use, as well as its embodied

carbon emissions, and it takes into account potential carbon emissions

benefits from the reuse or recycling of components after the end of the

building’s life. The assessment is therefore closely related to the Circular

Economy assessment that sets out the contribution of the reuse and recycling

of existing building materials on site and of such potentials of the proposed

building materials, as well as the longevity, flexibility, and adaptability of the

proposed design on the Whole Life-Cycle Carbon emissions of the building.

The Whole Life-Cycle Carbon assessment is therefore an important tool to

achieve the Mayor’s net-carbon city target.

Carbon options

175. The following options were chosen as described in the Circular Economy

section to be fully assessed and evaluated:

Option B1: minor refurbishment with partial ground floor extension and

minor extension to upper levels, 100% of substructure and 90%

of superstructure retained

Option B2+: major refurbishment of retained substructure and 4-storey

superstructure with an adapted core to enable a larger extension

to achieve a 15-storey building, 99% of substructure and 46% of

superstructure retained

Option B3+: major refurbishment of retained substructure and 4-storey

superstructure with a 14-storey extension facilitated by new core,

with a more generously adapted ground floor to improve the

library and interface with the public realm, 93% of substructure

and 32% of superstructure retained

Option C: redevelopment above ground with18 storeys with retention of

91% of substructure and 0% of superstructure

176. The following table and graph present the whole life-cycle carbon results from

the 4 options.

177. The options clearly show that, based on new building services installations, all

4 options’ carbon emissions rise at a very similar rate throughout a 60 year life-

cycle, and that the upfront and whole life-cycle carbon impact is higher with

more new build quantity. The existing building’s performance (option A) over

the reference period shows a much steeper graph, due to the lack of efficiency

of the existing façades and MEP. These will have to be fully replaced after

around 40 years at the latest, after which the operational performance would

run parallel with the other options. Qualitatively, the options can be assessed

as follows:

178. Options B1 and B2+ would not be able to achieve the improvements to the

ground floor and its relationship with the public realm around it to activate the

area and relationship with the reconfigured public library. Option B1, and

option B2+ in the retained parts would not be able to provide the high quality

office floorspace that is sought after in this part of the City. In option B2+, only

the new floors can achieve the highest office floorspace quality in terms of

spaciousness, daylight, orientation and flexibility.

179. Option B3+ and option C are similar in size and option B3+ would facilitate a

new, larger core for a greater floorspace uplift of higher quality compared to

the floorspaces on the retained floors. The resulting whole life-cycle carbon

emissions for both options, and both by square meter and absolute, would be

at a similar level (slightly higher for option C). While options B1 and B2+ would

result in significant carbon savings, they are not considered high quality

solutions that would attract occupiers in this location. Given the higher quality

improvements to the public realm, the ground and upper floors through better

configuration of the floorplates compared to option B3+, option C has been

further developed for the application scheme.

180. The optioneering approach set out in this section and in the Circular Economy

section is in line with the recommended approach in the GLA’s guidance on

circular economy and whole life-cycle carbon emissions. The optioneering

assessment complies with the more detailed methodology set out in the City

of London’s Carbon Options Guidance (2023) to establish and evaluate the

carbon impact of development options as confirmed by a 3rd party review.

181. The application proposal: The submitted whole life-cycle carbon assessment

sets out the strategic approach to reduce operational and embodied carbon

emissions and calculates the predicted performance that compares to current

industry benchmarks as set out in the table below. The results show that the

embodied carbon emissions can be reduced beyond the GLA’s Standard

Benchmark, reaching close to the Aspirational Benchmark.

182. The following principal carbon reduction measures have been incorporated

into the proposal, targeting the 3 materials steel, concrete and aluminium that

contribute most (55.63% of total embodied carbon) to the proposed scheme:

• Reuse 90% of the existing substructure, or 57% of the existing structure

overall

• Reuse of the existing external wall panelling as an internal finish

• Reuse of the ceramic floor tiles

• Reuse of the existing raised access floors

• Use of re-purposed steel from off-site facilities within the new structure

• Design for exposed ceilings to reduce the installation of fit-out items that

are subject to frequent change

• Maximation of standardised materials and elements to ease

disassembly, fitting and replacement.

183. Further opportunities will be considered such as cement replacements, low

embodied carbon rebar and tendons and high recycled content aluminium

profiles.

184. The applicants have specifically considered the carbon impact of the façade

system which is a large contributor to embodied carbon for large commercial

buildings – typically one-fifth of the total embodied carbon. In addition, façade

systems require more frequent replacements compared to structural building

elements. In a typical aluminium/glass curtain wall façade system, aluminium

contributes 66.5% of the façade panel, however, as the applicants prefer

aluminium due to its ability of 100% reclamation for other products and

systems, disassembly potential and greater elemental resilience, the proposed

façade design has been optimised with a reversed mullion system to provide

solar shading as part of the structural elements of the system. Potential other

materials, such as steel, copper or zinc, or a high (75%) recycled aluminium

content, and associated carbon impacts, will also be considered in the detailed

design phase.

185. The table below shows whole life-cycle carbon emissions per square meter in

relation to the GLA benchmarks (embodied carbon without carbonisation

applied) at planning application stage:

Scope

Proposed

Redevelopment

Benchmark

GLA Benchmark

RICS

components

kgCO2/m2

A1-A5

645

< 950

GLA Standard

< 600

GLA Aspirational

A–C

(excluding B6-

B7)

995

< 1400

GLA Standard

< 970

GLA Aspirational

B6+B7

617

A-C

(including B6)

1,612

186. These figures would result in overall whole life-cycle carbon emissions of

92,019,274 kgCO2 being emitted over a 60-year period. Of this figure, the

operational carbon emissions would account for 35,216,593 kgCO2 (38% of

the building’s whole life-cycle), and the embodied carbon emissions for

56,802,681 kgCO2, (62% of the building’s whole life-cycle carbon). The

embodied carbon from the substructure contributes 8.5% to the total embodied

carbon which accounts for the proposed reuse of substructure of more than

90%; while the superstructure accounts for 47.8% of the total embodied carbon

which is the highest proportion of embodied carbon in the new building.

Building services would contribute to 29.8% of total embodied carbon

emissions.

187. A higher recycled content of steel, aluminium and cement replacements in

concrete will be targeted in the detailed design and procurement stages which

would further reduce the upfront carbon emissions.

188. The whole life-cycle carbon approach of the proposed development addresses

the NPPF 2023 requirement stated in paragraph 157 that the planning system

should support the transition to a low carbon future and that it should help to,

amongst others, encourage the reuse of existing resources, including the

conversion of existing buildings. This is reflected in the carbon optioneering

that has been carried out as described above, in the whole life-cycle carbon

emission calculations that have been confirmed by an independent 3

party

review to be in line with the GLA Whole Life-cycle carbon assessment

guidance and in the details of the application scheme to include retained

substructure as well as a catalogue of reuse opportunities and low carbon

measures.

189. A detailed whole life-cycle carbon assessment confirming improvements that

can be achieved through the detailed design stage, in particular those that

have been identified in the application documents, and a confirmation of the

post-construction results are required by conditions.

Urban Greening

190. London Plan Policy G5 (Urban Greening) sets out the requirement for major

developments to contribute to the greening of London through urban greening

as part of the design and site. An Urban Greening Factor of 0.3 is

recommended for non-residential developments. Draft City Plan 2040 policy

OS2 (City Greening) mirrors these requirements and requires the highest

levels of greening in line with good design and site context. The proposed

development would incorporate significant public realm areas and landscaping

at street level and higher up the building in the form of new terraced areas.

The glasshouse office reception and lobby space will also be extensively

greened, albeit as internal space this does not contribute to the Urban

Greening Factor (UGF) score achieved for the application site.

191. The landscape proposals seek to create a robust green infrastructure

embedded within the architecture. There are terraces on all levels from level 1

providing large green spaces accessible to the occupants. The planting plan

includes a combination of wildflower/sedum, herbaceous planting, shrubs and

trees of various sizes. On the roof above level 18 there would be a biodiverse

green roof to contribute to reducing surface water run-off and by improving

building insulation, urban greening and biodiversity.

192. The proposed development would achieve a minimum Urban Greening Factor

(UGF) of 0.30, compliant with the London Plan requirement.

Biodiversity Net Gain

193. The Ecological Appraisal of the proposals recommends the following

enhancement measures to improve the ecology of the site:

• Invertebrate habitat features within areas of ground level landscaping and

within dense areas of planting on terraces

• Bat boxes integrated into the fabric of the building or on mature trees as

per the Applicant’s Biodiversity Brief

• Incorporation of bird nest boxes integrated into the fabric of the building,

targeting black redstart, swift and house sparrow in addition to generalist

boxes onto mature trees

• Biodiverse intensive green roofs with varied substrate and invertebrate

habitat features such as deadwood log piles, rope coils, sandy piles and

water trays

• Use of invertebrate-friendly plant species.

194. The proposed development would achieve a Biodiversity Net Gain (BNG) of

517.33%.

Overheating

195. To address urban heat island risks, the proposed development would

incorporate an optimised façade design with external shading through

projecting fins and solar control glass, minimising overheating risk and reliance

on active cooling. Openable windows will be provided to further reduce

reliance on mechanical ventilation. Urban greening and blue roofs on the

terraces would reduce heat absorption within the building.

196. A thermal comfort assessment has been submitted and impacts are

considered acceptable, subject to mitigation measures.

Flooding

197. The application site is located in Flood Zone 1 and therefore has a low

likelihood (less than 0.1% annual probability) to be affected by flooding from

tidal, fluvial, pluvial, groundwater and artificial sources. The proposed

development will reduce run-off rates by using surface water attenuation tanks

and blue/green roofs in high rainfall events.

Water Stress

198. The proposed development will incorporate water efficient fittings targeting a

55% water demand reduction against non-domestic baselines. Other proposed

measures to reduce potable water use are rainwater recycling and greywater

harvesting systems, details of which are requested by condition.

Conclusion on Sustainability

199. The City of London Climate Action Strategy supports the delivery of a net zero,

climate resilient City. The agreed actions most relevant to the planning process

relate to the development of a renewable energy strategy in the Square Mile,

to the consideration of embedding carbon analysis, circular economy

principles and climate resilience measures into development proposals and to

the promotion of the importance of green spaces and urban greening as

natural carbon sinks, and their contribution to biodiversity and overall

wellbeing. The Local Plan policies require redevelopment to demonstrate

highest feasible and viable sustainability standards in the design, construction,

operation and end of life phases of development as well as minimising waste,

incorporating climate change adaption measures, urban greening and

promoting biodiversity and minimising waste. The proposed development is

compliant with Local Plan Policy DM 15.5.

200. The proposed development would deliver a high quality, energy efficient

development that is on track to achieve “outstanding” BREEAM assessment

ratings for all uses, in compliance with London Plan policy SI 2, Local Plan

policy CS15 as well as Draft City Plan 2040 policy DE1. The proposals cannot

meet the London Plan target of 35% operational carbon emission savings

compared to a Part L 2021 compliant scheme which the GLA acknowledges

will initially be difficult to achieve for commercial schemes. However, the

proposed energy efficiency and MEP strategy would perform highly, with an

innovative façade system that would provide both operational and embodied

carbon efficiency and an additional opportunity to use timber for internal

elements.

201. The assessment of options, carried out in compliance with the Carbon Options

Guidance 2023, confirmed that although the preferred proposal would result in

the highest whole life-cycle carbon emissions out of the 4 options, none of the

other options would be able to deliver the holistic sustainability benefits that

would complement the ongoing repositioning of the Holborn and Fleet Valley

area into a vibrant, healthy and sustainable new part of the City. The planning

stage whole life-cycle carbon emissions reach close to the GLA’s Aspirational

Benchmark, and opportunities to maximise the reuse of deconstruction

materials from the site and from other reuse sources have been identified to

mitigate impacts of redevelopment. The proposal therefore would satisfy the

GLA’s circular economy principles and London Plan policy SI 7, Local Plan

policy CS15 and DM17.2, and Draft City Plan 2040 policy CE1. The building

design responds well to climate change resilience by reducing solar gain,

saving water resources and various opportunities for urban greening and

biodiversity and complies with London Plan Policies G5 SI 4, SI 5 and SI 13,

Local Plan policies DM18.1, DM18.2, CS19, DM19.2, and Draft City Plan 2040

polices S14, OS1, OS2, OS3, S15, CR1, CR3.

Design and Heritage

Environmental Impact Assessment (EIA)

202. The Townscape, Heritage and Visual Impact Assessment (THVIA) was

submitted with the application as part of the EIA. The visual and heritage

impacts are considered further in this report section.

203. However in addition to the analysis below, the EIA considers the construction

phase, including visual impacts for demolition of the existing structures on the

Site, the erection of tower cranes, the presence of scaffolding and heavy plant,

and the construction of the new building. It states that each of these will have

an effect on the Site’s townscape character, visual intrusion and the

appreciation of heritage assets. However, it is considered that their presence

will be an inevitable consequence of the nature and scale of the proposed

development and adverse effects will be temporary and short term.

204. The EIA assessment also considered each of the heritage receptors and

townscape character and concluded that whilst there may be cumulative

schemes in the surrounding area, these will not affect heritage receptors or the

assessment of the proposed development. For Visual Amenity, the

assessment states that Cumulative Schemes will only be visible in seven of

the 29 assessed views and in all of these views the magnitude of impact will

remain the same as the proposed development assessed in isolation. It states

that there are no increased visual effects as a result of the Cumulative

Schemes, and they will not give rise to significant effects in respect of visual

impact.

Design Approach: Architecture, Urban Design and Public Realm

Policy context:

205. The relevant local policies for consideration are CS10, DM10.1, DM, DM10.3,

DM10.4, DM10.5, DM10.6, DM10.8, CS16, DM16.2, CS19, DM19.1, DM19.2

of the Local Plan policies and HL1, S8, DE2, DE3, DE5, DE8, S10, AT1, S12

of the emerging City Plan, and London Plan policies D3, D4, D5, D8 and D9.

Principle of a Tall Building:

206. The proposal is for a building of 94.80m. This would be defined as a tall

building under the provisions of the adopted Local Plan Policy CS13 and

emerging City Plan 2040 Policy S12.

207. The City’s long-term, plan-led approach to tall buildings is to cluster them to

minimise heritage impacts and maximise good growth. As such, the adopted

Local Plan seeks to consolidate tall buildings into a singular, coherent City

Cluster (Local Plan policies CS7 and CS14 (1)), an approach carried forward

in the emerging City Plan 2040 with the addition of a smaller proposed Cluster

in the Holborn and Fleet Valley area (Policies S12 and S21).

208. The application site falls outside the ‘Eastern Cluster/City Cluster’ policy areas

in the adopted Local Plan and emerging City Plan Policy CS7, but does fall

within the proposed Holborn and Fleet Valley Cluster in the emerging City Plan

Policy S12.

209. London Plan policy D9 (B (3)) stipulates that tall buildings should only be

developed in locations that are identified as suitable in Development Plans.

While seeking in an overarching sense to cluster tall buildings within the

Eastern Cluster, the City’s adopted Local Plan 2015 defines those areas in

which tall building proposals would be inappropriate in principle and should

therefore be refused under Policy CS14. These areas include conservation

areas, St Paul’s Heights, St Paul’s protected vista viewing corridors and

Monument views and setting.

210. The application site is not within an area identified as inappropriate in principle

for a tall building under the 2015 Local Plan. On this basis, the proposal would

be compliant with the aims of CS14 (2), and would engage CS14 (3), under

which tall buildings would be permitted elsewhere in the City only on those

sites which are considered suitable in relation to townscape, skyline and

heritage impacts. The potential for these are assessed in detail below.

211. Emerging City Plan 2040 specifies, in accordance with London Plan Policy D9,

areas where tall buildings would be appropriate in principle which includes the

new proposed Cluster at Holborn and Fleet Valley. The application site falls

within the proposed Cluster and as such would be considered appropriate for

a tall building in principle in respect of the 2040 Plan.

212. At 94.80m AOD, the proposal would exceed the highest of the contours of the

proposed Cluster (90m AOD) by 4.8m and there would therefore be a degree

of conflict with emerging policy S12 regarding height of the 2040 Plan. The

emerging 2040 City Plan has not yet gone through Regulation 19 consultation

and as set out is considered to be a material consideration afforded limited

weight.

213. The application site is within the Central Activities Zone (CAZ), a highly

accessible and sustainable location with the highest PTAL rating of 6B and

excellent access to transport infrastructure. The proposal would complement

the unique, pan-London role of the CAZ, as an agglomeration and rich mix of

strategic functions, including nationally and internationally significant office

functions, cultural spaces and new and remodelled public gardens and public

routes in line with London Plan D4. The site would deliver 54,000sqm of the

requisite commercial space to meet projected economic and employment

growth demand until 2040. This quantity of floorspace would contribute to

maintaining the City’s position as a leading international financial and business

centre.

214. Taking all these matters into consideration, it is considered that the proposals

would conform to the City’s plan-led approach as the site is in an area

effectively identified by the 2015 Local Plan as appropriate for a tall building

and within the emerging City Plan 2040 Policy S12 in accordance with London

Plan D9 (B; 3), and notwithstanding the degree of conflict identified with

emerging City Plan 2040 policy S12 with regards to height.

Tall Buildings – Impacts

215. This section assesses the proposals against the requirements of London Plan

Policy D9 Parts C and D of the London Plan. The visual, functional and

environmental impacts are addressed in turn and elaborated upon in the

dedicated architecture, urban design and heritage sections which follow.

Visual Impacts – Policy D9 Part C (1)

216. The site is located to the west of the City in an established nucleus of tall

buildings (which is intended to be formalised as a Cluster under the 2040 Plan)

which form a prominent grouping of increased height around New Street

Square and the Shoe Lane ‘five dials’ junction.

217. Completed in 1979 (and thus one of the oldest of the buildings), Hill House is

located near the centre of this grouping. By virtue of the subsequent

redevelopment of these taller buildings around it, Hill House is now one of the

smallest in scale at 8 storeys, including plant – which at its tallest is 49.33m

AOD. It is framed on all sides by the following schemes, existing or under

construction:

• 6 New Street Square – 94m

• 120 Fleet Street – 93.15m AOD (consented, under construction)

• 1 New Street Square – 86.03m AOD

• 12 New Fetter Lane – 77m

• Stonecutter Court – 68.78m AOD (consented, under construction)

• Plumtree Court – 65.78m AOD

218. At 94.8m AOD the proposed redevelopment of Hill House would sit

comfortably among these neighbouring schemes. It would be very slightly taller

than the implemented scheme at 120 Fleet Street with which it would be

closely grouped in strategic City and pan-London views. Officers support the

overall form and massing strategy of the proposal with a sloping and terraced

form articulated by cascading terraces with jagged crevices of planting giving

charismatic articulation to the prominent south elevation. The proposal would

form a distinct but complimentary addition to its neighbours and pleasantly

diversify the forms and materiality of this emerging Cluster.

219. The impact of the proposals upon the City and wider London skyline has

fundamentally informed the optimisation of the site, and long-range views

(London Plan Policy D9 (C1; a; i) of the proposal have been tested in the

HTVIA.

220. In baseline and cumulative panoramic views, the proposal would appear as an

augmentation of the existing nucleus of tall buildings around New Street

Square which are visible in these views, though their low height compared with

the taller, more visually arresting buildings of the City Cluster. From the south-

east the proposal would be largely screened by 120 Fleet Street; from other

compass points the scale and stepped form of the proposal would assimilate

well with the existing group of comparably-sized tall buildings around the site.

221. In baseline and cumulative river prospects, the proposal would appear as a

prominent new element of the City’s skyline to the west, particularly from

western viewing points including Hungerford and Waterloo Bridges. Historic

England have objected to the proposal’s impact on the settings of designated

heritage assets in these views. Officers acknowledge these representations

but draw different conclusions as to the impact, discussed in detail in the

Strategic Views and Heritage sections of the report. The stepped form of the

proposal and articulation of the south façade would ensure it sits comfortably

in these views and its general scale would fit neatly into this established group

of tall buildings of comparable scale.

222. In relation to long range views, the proposal would comply with London Plan

Policy D9 (C1; a; i).

223. Mid-range views (London Plan Policy D9 (C1; a; ii) of the proposal have been

tested in the HTVIA. Historic England have identified harm to the settings of

heritage assets in the viewing experience along the Strand. Officers

acknowledge these representations but draw a different conclusion, discussed

in the Strategic Views and Heritage sections of this report. In both baseline

and cumulative viewing experiences from the Strand, Holborn Circus and the

Temples, the upper reaches of the proposal would appear as a high-quality

new addition to an established group of tall buildings of comparable scale,

clearly legible as part of a disassociated modern group beyond heritage assets

in the foreground of these views. In views along Cannon Street of St Paul’s

only a sliver of the proposals would be fleetingly glimpsed above the form of

120 Fleet Street.

224. In relation to mid-range views, the proposal would comply with London Plan

Policy D9 (C1; a; ii).

225. Immediate views (London Plan Policy D9 (C(1); a; iii) have been tested in the

HTVIA. When seen from the streets in the immediate vicinity of the proposal,

the proposal would ‘land’ appropriately amongst the neighbouring tall buildings

and would create high-quality new public realm around its base and particularly

to Gunpowder Square. Architecturally the proposed building would be

successfully articulated into a convincing base and well-designed upper

storeys, with simpler elevations to the north, east and west designed to act as

subtle foils to the elevations of the existing, surrounding tall buildings and allow

the principal south façade with its extensive greening and charismatic

articulation into stepped terraces to shine as the main architectural moment.

This would also allow the proposal to act as a calm, well-designed modern

backdrop to the views out of the Fleet Street Conservation Area and other

places immediate locality; the proposal would be a judicious neighbour to the

other tall buildings around New Street Square.

226. In relation to immediate views, the proposal would comply with London Plan

Policy D9 ((C)1; a; iii).

227. In relation to London Plan Policy D9 ((C)1; b), the proposal would form a

prominent new element of the existing nucleus of tall buildings around New

Street Square. In this it would reinforce the existing spatial hierarchy of the

locality in views from all ranges. It would help to reinforce the legibility of this

location as one characterised by taller development than its surroundings and

would thus support wayfinding by consolidating the identity of the place. In this,

the proposal is considered to accord with London Plan Policy D9 (C1; b).

228. In relation to London Plan Policy D9 (C1; c), the architectural quality and

materials would be exemplary and would be maintained through its life span.

229. Overall, the architecture is clearly well-considered in the round and of a high

quality, and would be a visually distinctive and attractive addition to the skyline

in and of itself.

230. Materials and detailed design would be the subject of conditions to ensure

quality is maintained to deliverability on site.

231. A full assessment of the architecture, urban design and the public spaces is

provided in the Architecture and Urban Design section. The development

would comply with London Plan Policy D9 (C1; c).

232. In relation to London Plan Policy D9 (C1; d), the proposal would preserve the

settings and significance of relevant heritage assets. Historic England and

other third parties have objected to the proposal’s perceived impacts on

heritage assets, but officers, whilst acknowledging this, have reached a

different conclusion. This is set out in detail in the Heritage section below. The

proposals would accord with London Plan Policy D9 (c1; d).

233. In relation to London Plan Policy D9 (C1; e), the proposal would not be of

sufficient scale as to be visible in relation to the World Heritage Site and

therefore would not trigger this part of the policy, being de facto compliant with

its aims.

234. In relation to London Plan Policy D9 (C1; f), the proposal, while visible in the

background of views of and from the river, is sited at enough distance from the

riverside to not trigger this part of the policy. It would be set well back from the

riverfront, outside the Thames Policy Area. It would preserve the historic scale

of the riverfront, the open quality and views of/along the river, avoiding a

‘canyon effect’, all in compliance with this part of the policy.

235. In relation to London Plan Policy D9 (C1; g), the proposal would not cause

adverse reflected glare, this is addressed in the Environmental Impacts section

of the report.

236. In relation to London Plan Policy D9 (C1; h) the proposal has been designed

to minimise light pollution from internal and external lighting, which will be

secured via condition. The potential light spillage impacts from the proposed

development on surrounding existing residential buildings have been

assessed and are addressed elsewhere in this report. The development has

been designed in accordance with the details and technical requirements of

the draft Lighting SPD.

237. In respect of ‘Functional Impact’ (D9, C(2)):

• The design has considered fire safety through the submission of a Fire

Statement and consideration of measures to prevent falling, to ensure

the internal and external design promotes safety of all occupants, and

details for the latter are proposed to be secured through condition;

• The building would be serviced, maintained and managed to not

cause disturbance to surrounding area, with details to be secured

through condition and Section 106 obligation;

• The entrances, access routes, and ground floor uses have considered

the proposed and surrounding pedestrian activity to ensure there is no

unacceptable overcrowding or isolation in the surrounding areas, and

further detail is to be secured through the Section 278 Agreement;

• The transport impacts have been considered and it is considered there

is capacity in the area and the transport network is capable of

accommodating the quantum of development in terms of access to

facilities, services, walking and cycling networks, and public transport

for people working and visiting the building;

• The jobs, services, facilities and economic activity that would be

provided by the development has informed the design to maximise the

benefits including the enhanced public realm adjacent to the library

use at Gunpowder Square , subject to Section 278 Agreement, and

increased activity around the site including improved frontage;

• Subject to proposed conditions recommended by relevant consultees,

the development, including construction, would not interfere with

aviation, navigation or telecommunication, and it is not considered it

would result in a significant detrimental effect on solar energy

generation on adjoining buildings from the available information.

238. For ‘Environmental Impact’ (D9, C(3)), the wind, daylight, sunlight, thermal

comfort, solar glare and noise have been carefully considered and it is

considered this would not compromise comfort and the enjoyment of open

spaces, including water spaces, and street level conditions around the

building. This is considered further in the ‘Environmental Impacts’ section of

the report.

239. For ‘cumulative impacts’, the relevant proposed, consented and planned tall

buildings the area have been considered as part of the assessment and

mitigation measures have been identified where required, and are proposed to

be secured through condition.

240. For ‘Public Access’ (D9, Part D), the applicant has proposed access for the

library use and for community and educational groups at dedicated times to

the level 18 amenity space and terrace, to be secured in the Section 106.

Tall Building, Conclusion:

241. Officers conclude that the site would be appropriate in principle for a tall

building and the impacts of the proposal are considered acceptable. The

proposal would comply with London Plan policy D9 (A, B, C and D) and Local

Plan 2015 Policy CS14 (3). Although there would be a degree of conflict with

emerging policy S12 with regard to height as a result of the proposal’s breach

of the highest (90m) contour of the emerging Holborn and Fleet Valley Cluster,

it is considered that the proposal complies with emerging Policy S12 with

regard to location, impacts, design and public access. It is not considered that

the degree of conflict identified with a material consideration afforded limited

weight outweighs the adopted development plan nor the acceptability of the

proposed tall building.

The existing site, surrounding context, and contribution to townscape

242. Hill House is located within a cluster of mid-rise commercial buildings

approximately 140m north of Fleet Street. It is an island site, bound by

Gunpowder Square to its southwest, Printer Street to its northwest, Little New

Street to its north, Shoe Lane to its east and Wine Office Court to its south.

243. The site is not located within a Conservation Area, but is located on the

northern boundary of the Fleet Street Conservation Area, and within 250-500m

of several others. To the west- Chancery Lane, Temples and the Strand

Conservation areas; to the north – Hatton Carden and Smithfield; To the east

– Newgate street, Postman’s park and St Pauls Conservation Areas; To the

south – Whitefriars Conservation Area.

244. The site sits in the aforementioned nucleus of tall buildings around New Street

Square and the Shoe Lane ‘five dials’ junction, just to the north of the Fleet

Street Conservation Area, which it is distinct from by virtue of its much coarser

urban gain, which is experienced as a campus of individual large-footprint

commercial buildings of scale, ranging in height between C.74m AOD and

c.93m AOD.

245. To the southwest of the site however, the scale and character is smaller and

more traditional, relating to the character and appearance of the Fleet Street

conservation area, with buildings fronting onto Gough Square, Wine office

Court and Gunpowder square being C.5- 8 stories, and faced with red brick.

246. Hill House has a distinctly brutalist aesthetic, formed from robust concrete

horizontal panels which clad the building from the first to fourth floor. Above

the fourth floor, the stories are set-back in a pyramidal stepped form, creating

a shoulder height which broadly aligns with the buildings to the southwest. The

upper 4 floors are clad in bronze-coloured metal framing and cladding with

bronze-tinted windows. Centred on the east and west ends of the building are

narrow concrete stair towers that rise up and form the tallest parts of the

building. The ground floors are set back behind the upper building line which

is supported by large concrete columns, interspersed with modern office and

servicing entrances. The extensive ground floor perimeter of the site, including

the route between Little New Street and Wine Office Court, is predominantly

inactive with large stretches of double-height blank frontage, giving it a

defensive, introspective character. Generally, the ground floors are considered

to perform poorly in terms of accessibility and wayfinding and are not

considered to make a positive contribution to the surrounding streets. While

the building offers a route through its middle, the public realm at the base of

the building is also generally of poor quality, with patchy and uneven ground

surfaces, with little urban greening or places to stop and rest.

247. Overall, officers consider the building to be without especial architectural merit,

making a poor contribution to the surrounding streets due to its lack of active

frontage, poor entrance design, and harsh streetscape design.

Architecture and urban design

Bulk height and massing

248. The height, massing, and overall expression of the development has been

carefully considered in relation to key townscape views from Monument,

Cannon street, the Strand and river Thames, in addition to the existing and

emerging context of tall buildings in this locality.

249. As such, the proposed massing steps up from its lowest point in the south west

corner, fronting Gunpowder Square, to its tallest point in the north east corner,

which addresses the prominent junction at ‘five dials’.

250. The southwestern corner strikes a commensurate shoulder height with

Pemberton House and Peterborough Court - some of the smallest scaled

buildings within the site's local context. From floors 1-4, this corner would also

feature terraces, with deeply recessed glazing, consciously easing the

massing of the building away from the public realm, to enhance the sense of

spaciousness around Gunpowder Square. Above this corner, from level 4

upwards, the massing gradually increases to its total height of 94.80m AOD in

the northeast.

251. The massing has been designed and carefully sculpted to mediate the change

in scale between the southwest and northeast, and makes this transition

through cascading terraces which sweep up and curve across the façade,

carving out massing, and prising apart two subtly differentiated volumes

diagonally across the site; the smaller of the two being to the south, and larger

to the north. The bulk and massing of the building is softened by the inclusion

of set back terraces on every floor of the building. From level 4 onwards, the

terraces increase in size at each level, meaning the building gradually tapers

back and creates a unique floorplate at each level. The sweeping central curve

of the building extends to its very top, and dissects the top floor roof pavilions

so they appear staggered, visually breaking up the whole southwest elevation.

Each pavilion is two storeys in height which helps express the top of the

building, and like the rest of the building, both levels are deeply set back behind

generous roof gardens. In combination with their lighter-coloured materiality,

these pavilions would create a clear distinction from the middle of the building

in terms of scale, proportion, and elevation design. The sculptural form of the

building's massing, which breaks the building down into a series of different

elements, is considered to successfully reduce its overall bulk, in addition to

giving the building a unique silhouette, which in combination with the

generosity of the terraces, would soften its appearance in local views, as well

as providing high-quality external amenity spaces for office users to enjoy.

Expression and materiality:

Ground floor

252. The proposed base of the building would be clearly defined and well

proportioned, with the majority of its curved frontage being wrapped with

double-height clear glazing, to maximize active frontage, and promote a

positive interactive relationship with the surrounding streets. Like the existing,

the ground floor frontages are recessed on all sides, with the building above

supported by concrete columns. However, these are well-spaced and of a

more compatible size, such that they do not impede views into the building, or

feel overbearing. The design of these columns is simple, with a band of fluting

at their base. The ground floor building line is also curved, helping to subtly

guide people around its base, as well as tying into the overarching architectural

language of the building, which uses softened rounded edges on all corners.

253. Each ground floor elevation has been designed slightly differently to respond

to their particular uses, and where possible, are all united by high levels of

visibility deep into the floor plans, and views around their corners to

surrounding streets.

254. The southwest corner would provide the entrance to the Shoe Lane Library,

with a clearly expressed entrance portal and signage zone. The library

frontage would be deeply recessed, providing greater space for the public

realm, the design of which is well integrated with the architecture the southwest

corner, giving it a rich, green and civic character. The frontage would be made

from double-height glazed bay windows enabling views into the expansive

high-spec modern library. The detailed design of the organic and asymmetric

soffit to this entrance will be conditioned, however, the design intent is for this

to be clad in a light-coloured aluminium, and be stepped according to each

layer of lighting channels, to give this surface a dynamic feel, with a high

degree of articulation. The entrance would also be framed by two columns,

which are given their own subtly different character, with inset bronze to their

flouted base, in addition to shadow gaps at their top. While these are fine

details, the attention to detail here is positive and would ensure the design of

this entrance is of particularly high quality, and subtly different from other

entrances, to reinforce the civic character of the library.

255. The rest of the western ground floor frontage would be activated by entrances

to the gym, and flexible office/retail/ café, with only a single solid bay required

to provide access to the fire stair. The extensive clear glazing would wrap

around the entire northern frontage, culminating in the office entrance. Facing

east, the office entrances would be set back from the roads, and be given

breathing space behind a generously-sized planter which, like the one for the

library, would provide an attractive and inviting planted frame to the entrance.

The detail of the return elevation to the entrance will be conditioned to ensure

the high quality of the design intent is sustained. Just to the south of this, is the

dedicated entrance to the rooftop restaurant – with a decorative spandrel panel

concealing the first floor slab behind. With the exception of the entrance to the

library, all bay windows and entrances would use dark bronze frames.

256. From the southeastern corner, to the middle of the southern elevation the

ground floors would be predominantly solid, concealing the loading bay and

serving area. With the exception of the upper floor windows, all bays would be

clad in dark bronze louvered panels, with a framing system to articulate large

chevron direction arrows. These shapes would also be in dark bronze, with the

arrows differentiated through a change in panel texture.

Upper floor elevations

257. Above the ground floor, the elevations to the middle portion of the building

would be set out over a 1.5m facade grid, and be clad in two types of aluminium

panel within a unitised aluminium system. The primary emphasis on all

facades is verticality, which would be expressed by light toned vertical

piers/fins. Composed of PPC aluminium, these fins would be given a cream

stone effect, with a matt finish and subtle sparkle, to imitate stone. These fins

would have a curved face – and V shaped plan form. The benefits of this

profiling would be twofold, firstly increasing solar shading and secondly

providing greater depth, interest and articulation to the facades.

258. Sitting behind these fins, is the secondary horizontal façade element of dark

bronze spandrels in a matt finish. All corners of the building would be treated

with curves, which the bronze spandrels would adorn. While the details of

these features will be conditioned, the design intent is to create bands of soft

smooth corners, which in combination with the profiled fins would become two

of the defining architectural features of the building.

259. Importantly, above the base of the building, the proposed development

incorporates four façade types, that respond to their orientation. Each type

uses the curved fin, but at a different scale/proportion, to create a hierarchy of

facades across the building.

260. As described above, the main façade is spaced according to a 1.5m grid, with

slim fin widths which run the full height of the storey. For the terrace façade,

the fin width and their spacing would double to create a facade that feels more

open. On these elevations, the fins would break through and extend above the

horizontal spandrel line to reinforce the vertical emphasis of the building. The

façade of the ‘sweep’ would share the fin dimensions of the main façade, but

the spacing between them would half, to give this elevation more solidity, and

emphasize the dynamic character of the south-west elevation in prominent

views. Finally, the rooftop pavilions would be given the grandest order, being

triple the width and spacing of the main elevation, in addition to a lighter tone,

to clearly express its top and create a visual distinction with the floor below.

The articulation and detail given to these pavilions is considered successful in

crowing the top of the building, and creating an expressive and celebratory

movement in the townscape. Similarly, the corners of the building have been

kept simple, with no fins, so that their pleasing curved radiuses are readily

legible on approach.

261. With the exception of the northern façade, areas of glazing will also incorporate

fritting to ensure that, along with automated blinds, the proposed scheme

achieves the ambitious 40 W/m2 perimeter solar gain target. A study will be

undertaken to ascertain the precise locations of the facades which require this

treatment. Officers are satisfied that this would be acceptable in principle, and

would not negatively impact the overall appearance quality of the facades.

262. Terraces and their landscaping also form an integral feature of the architectural

design of the building and are present at every level. The planting design has

been developed alongside the key architectural moves to reinforce verticality

and break up the massing. In particular, the terraces would feature a significant

number of trees (c. 85), with variation in species, ranging in size from large

specimens which could reach 5-6m tall, to smaller specimens of – 3-4m tall.

The proposed tree species have been selected according to their hardiness

and adaptability to a range of conditions, not least wind exposure and extreme

drought conditions. Planting beds have also been specially designed to ensure

they can accommodate enough root-ball space for trees to thrive while

balancing the overall size of the bed within the terrace. By virtue of the

proposed levels of tree planting and other planted areas, the proposal would

significantly increase the levels of urban greening within the area, though final

details on the planting specification, and maintenance of these areas will be

conditioned.

263. Terraces would be enclosed by simple clear frameless glass balustrades

(1.4m tall), with curved corners. Balustrades have been designed to be visually

unobtrusive, and not detract from the composition of the facades. Further

details of these will be secured via condition.

Public realm design

264. Proposals include landscaping enhancements to the southwestern corner of

the site, at Gunpowder Square, and the northeast corner of the site at the main

office entrance. Proposals would also result in the loss of city walkway, as the

route through the middle of the site would be removed. Enhancements to

Gunpowder Square would improve the quality of the pedestrian experience

along the predominant pedestrian desire line.

265. Working with the Libraries Team, the design aims to create a reinvigorated and

welcoming place, that supports greater biodiversity and provides a green foil

to the library. The strategy includes a series of planted areas on the east and

west edges of the square, with replacement trees, and would increase the

overall quality and quantity of planning into the ground. Connected tree pits

and larger soil depths would provide improved conditions for tree planting over

the existing condition, which is highly constrained and consequently the trees

have struggled. The shape of the beds would provide smaller intimate areas

within the landscape which would be integrated and defined by benches. The

proposals for Gunpowder Square will be delivered through a s278 agreement

by the City of London. Final details of the planting strategy will be agreed

through consultation with City Gardens to ensure the specification is

appropriate to the location and will thrive in these specific microclimatic

conditions.

266. In addition to ground level interventions - brass inscriptions inlays - further

design development will also include incidental play features, potentially in the

form of interactive art, to bring greater interest and interactivity to this civic area

for children. This strategy will be devised in conjunction with community

engagement, to ensure it makes a meaningful and enriching contribution to

placemaking.

267. All ground level hard surfaces will be York stone, to tie into the City of London

Public realm toolkit, and ensure the area feels fully public and integrates

successfully into the City’s wider public realm network.

268. Overall, officers consider that the organisation and layout of this area would

support the use of the library, and significantly enhance the character of the

public space. The higher levels of planting would also support local ecology,

through the provision of habitat. Feature seating – which has been designed

to be inclusive, with different height seats, arm and backrests, and niches to

allow space for wheelchair users and pushchairs – would also provide much-

needed additional seating within the area. The orientation of the seating would

also create social dwell spaces, where people can face one another and

interact, the space would have a positive relationship with the proposed library.

Furthermore, the adjacent context of the square is historic, and officers

consider that the proposals would have a positive synergy with the

neighbouring conservation area by providing an improved space set in and

amongst a network of human scale and enclosed routes and spaces on the

journey from Fleet Street to the application site.

269. Notwithstanding the approved drawings, the final details of the landscaping

including full planting specification, layout, hard and soft materials, furniture,

maintenance regime, and irrigation methods will be delivered through a S278

Agreement, in accordance with the City of London Technical Toolkit, to ensure

the design and materials are of high quality, and to ensure the landscape

thrives and is of acceptable design quality, and is fully inclusive. Officers

consider the design of Gunpowder Square would provide a dynamic,

characterful and inclusive public space where people can sit, rest or enjoy. The

planting would also significantly enhance the level of urban greening, within

this area of the city. The proposals would therefore enhance the overall quality

and character of this key pedestrian space, which was previously underutilised

and transitory.

270. While the proposals would not reprovide a route through the centre of the

building, as existing, officers do not consider this to be detrimental to

pedestrian movement, or the legibility of the area. The extensive contribution

of active frontage, and high quality landscaping around the site as would be

provided to offset this change, the upgrades to Gunpowder Square would

enhance the quality and function of the public realm on the pre-dominant

pedestrian desire line. Provision of attractive landscaping and seating would

provide pedestrians with visual interest and an opportunity to rest and dwell.

Conclusion on architecture and public realm design

271. Officers consider that the architectural design of the building would be

compatible with the existing context, being read as a well-layered piece of

design, which celebrates moments in the public realm. Officers consider that

the sculptural form of the building's massing, which breaks the building down

into a series of different elements is successful, and responsive to its context,

while also delivering a unique piece of architecture with its own identity and

well-articulated facades. Furthermore, the ground floors would be transformed

to be outward facing and visually permeable, encouraging positive relations

between the ground floor uses and the adjacent public realm, the base would

be an integral part of the arrival experience from all directions. The façade

treatments at ground floor level are well-suited to pedestrian desire lines and

sightlines, and particular care and attention has been paid to meet the needs

of pedestrians and cyclists. The prominent and attractive cycle hub entrance

would be accessible and visible to cyclists arriving at the site, providing high-

quality facilities that would promote active travel.

272. The proposals would also dramatically enhance the landscaping of the site,

providing much richer and more dynamic planting and greater opportunities

for sitting. The proposals would therefore enhance the overall quality and

character of this key pedestrian space, which was previously underutilised and

transitory.

273. The architecture and urban design proposals comply with Local Plan Policies

CS10, DM10.1, DM10.3, DM10.4, DM10.8 and DM19.1 emerging City Plan

Policies S1, S8, DE2-8, HL1, and London Plan Policies D3, D4 and D8,

paragraphs 130 and 132 of the NPPF and the City Public Realm SPD all

require high-quality public realm and increased urban greening.

274. Overall, it is considered that the proposal would make the best use of land,

following a design-led approach that optimises the site capacity to

accommodate employment growth and would increase the amount of high-

quality office space. The proposals align with the function of the City to

accommodate substantial growth in accordance with Local Plan Policies CS1:

Offices and London Plan Policies SD4, SD5 and E1.

275. Irrespective of the approved drawings, full details of the ground floor frontages,

design and materiality of the public realm improvements, and way-finding

strategy are reserved for condition to ensure these are well-detailed and are

useable. The development has had regard for Local Plan Policy DM 3.2 and

the Mayor’s Public London Charter promoting a safe, inclusive and welcoming

environment.

276. A high-quality signage strategy for the proposal would be required and would

be secured via condition.

Strategic Views

Policy context:

277. London Plan policies HC3 and HC4, Local Plan 2015 Policy CS13 and

emerging City Plan 2040 policies S12 and S13 all seek to protect and enhance

significant City and London views of important buildings, townscapes and

skylines. These policies seek to implement the Mayor’s London View

Management Framework (LVMF) SPG (the SPG), protect and enhance views

of historic City Landmarks and Skyline Features and secure an appropriate

setting and backdrop to the Tower of London.

278. A Built Heritage, Townscape and Visual Impact Assessment has been

prepared and submitted as part of the application documents.

279. For clarity, the application site is located in the west of the City, at considerable

distance from the World Heritage Site. Intervisibility between the two has been

tested in the TVIA, confirming that the proposal would have no visual

relationship with and would therefore have no impact upon the World Heritage

Site.

London View Management Framework (LVMF) Impacts

280. The LVMF designates pan-London strategic views deemed to contribute to the

Capital’s character and identity at a strategic level. Those relevant strategic

views where there would be a material impact are addressed here against

London Plan Policy HC4 and associated guidance in the SPG.

281. The site is located within the Wider Setting Consultation Area (WSCA) of LVMF

5A.2 Greenwich Park, and the proposal would breach the WSCA height

threshold, triggering qualitative assessment of its impact on the view.

282. Additionally, the WSCAs of LVMF 6A.1 Blackheath Point and 4A.1 Primrose

Hill pass very close to the application site. While the site does not fall directly

into 6A.1 or 4A.2, for completeness officers have assessed the impact of the

scheme on the edges of these viewing corridors, as these frame the

composition of the viewing planes. Officers have also assessed the impact of

the proposals on LVMF River Prospects.

View 5 (5A.2), London Panorama, Greenwich Park:

283. The impact would be perceived from Assessment Point 5A.2, at the eastern

extent of the panorama towards central London and St Paul’s Cathedral, which

is the sole Strategically Important Landmark (SIL), inclusive of the Protected

Vista. Other relevant identified landmarks include Tower Bridge, the

Monument, the Shard and the City Cluster. The proposal would breach the

Wider Setting Consultation Area (Background) of the Protected Vista.

284. The visual management guidance identifies the background of St Paul’s as

mostly unimpeded, with a clear silhouette afforded to the dome (above the

peristyle) and western towers, whilst the sky-etched silhouette is considered

crucial to the ability to recognise and appreciate the Cathedral (paragraph

142). In the baseline and cumulative scenarios, the proposal would be sited

south and west of the Cathedral, appreciated at a noticeable distance from the

Cathedral and be almost entirely shadowed by other tall intervening built

development of a similar total height, most notably 120 Fleet Street, which

would obscure all but the top two floors of the proposal. The proposals would

appear as a discreet, high-quality additional element to the existing nucleus of

tall buildings at New Street Square that are visible in this view.

285. The proposals would therefore form part of an established and coherent group

of tall buildings, which would not ‘crowd’ or create a ‘canyon effect’ to the wider

setting of the Cathedral and therefore not impact the viewer's ability to

appreciate the dome and upper parts of the western towers of St Paul’s

Cathedral or unacceptably impose on the landmark, all of which would still be

given appropriate context, reserving their setting and contribution to the special

characteristics of the view, in accordance with paragraphs 57, 58, 60, 61, 63,

146 and 147 of the SPG.

286. Overall, the proposal would not harm the characteristics or composition of the

strategic view and its landmark elements, including the ability to recognise and

appreciate St Paul’s as the SIL.

Wider LVMF panorama considerations:

287. As mentioned, the WSCAs of LVMF 6A.1 Blackheath Point and 4A.1 Primrose

Hill pass very close to the application site. For completeness, the proposal’s

impact on these is assessed below.

288. The Primrose Hill assessment point 4A.1, located at the summit of the hill,

allows the perception of considerable detail, including the principal buildings in

central London, principally in this case St Pauls Cathedral, and the Shard.

Views of the proposal would be virtually imperceptible by virtue of its location,

and commensurate height, within the existing consolidated cluster of tall

buildings which sit between St Pauls and the Shard. Overall the proposal would

preserve the composition of the view, and the viewer’s ability to recognise and

appreciate the salient features of St Paul’s in accordance with paragraph 132

of the SPG.

289. The Blackheath point panorama 6A.1 centres on the viewer's ability to

recognise and appreciate and St Pauls Cathedral and its western towers as

the sole SIL in the middle of the view. Officers consider that due to the

significant distance between, and the limited visibility of the proposals due to

the consented proposals at 120 Fleet Street which would block the majority of

this building from view, there would be no impact on the qualities or

composition of the protected vista and the ability to recognise and appreciate

the SIL in accordance with para 156 of the SPG.

River Prospects

LVMF 11A.1: London Bridge: The Upstream Pavement

290. St Paul’s Cathedral is the sole SIL, while other landmarks include the Cannon

Street Station towers, the Old Bailey and St Bride’s Church in a broad and

deep riparian composition. The visual management guidance identifies the

skyline presence of St Paul’s and the positive visual interaction it has with the

‘Wren-esque’ Cannon Street Station (paragraph 191).

291. In the baseline and cumulative scenarios, the proposal would not dilute this

dynamic, in accordance with paragraphs 193-4. The proposal, situated at a

discernible distance to the west of the Cathedral and of an appropriate height

and attractive form on the horizon, would be almost entirely screened by the

implemented scheme at 120 Fleet Street, with only a small portion of the top

visible.

292. As such, the proposal would not visually dominate the Cathedral in accordance

with paragraphs 194 and 197, consolidating a small cluster of taller buildings

around New Street Square, and it would not obscure or detract from any

contributing landmark in the composition, in accordance with paragraph 195.

293. Overall, in the baseline and cumulative scenarios, the proposal would not harm

and would make a positive contribution to the characteristics and composition

of the strategic view and its landmark elements, including preserving the ability

to recognise and appreciate St Paul’s as the SIL.

LVMF 12A.1: Southwark Bridge: The Upstream Pavement

294. St Paul’s Cathedral is the sole SIL, whilst other landmarks include Millennium

Bridge and St Bride’s Church in a broad riparian composition.

295. The visual management guidance, paragraph 209, describes the broad

expanse of the River as dominated by St Paul’s. The proposals would largely

be obscured behind Faraday house and 120 Fleet Street, with only fleeting

elements of the proposed uppermost pavilions visible. As such, the proposal

would form part of an established and recessive backdrop populated by the

small cluster of tall buildings around New Street Square - perceived at some

distance from the Cathedral. In accordance with the guidance, the proposal

would not harm the viewer's ability to recognise and appreciate the Cathedral

or dominate it. Furthermore, the high-quality architecture would complement

its wider skyline setting, in accordance with paragraphs 211 and 214.

296. The proposal would not obscure or detract from a contributing landmark or

feature (in accordance with paragraph 212, although the site is not within the

foreground);by virtue of the intervening distance, the distinctive vertical

presence of St Bride’s steeple would be unchallenged.

297. LVMF view 12A.2 is orientated southwest, and the proposal would have no

additional impact.

298. Overall, the proposal would not harm the characteristics and composition of

the strategic view and its landmark elements, including preserving the ability

to recognise and appreciate St Paul’s as the SIL.

LVMF 13A.1: Millennium Bridge and Thames side at Tate Modern

299. St Paul’s Cathedral is the sole SIL, while wider landmarks and contributing

features are Millennium Bridge and several Wren church towers and spires

which contribute greatly to the wider setting of St Paul’s.

300. The visual management guidance identifies the dominance of the bridge and

St Paul’s, whereby the St Paul’s Heights has preserved an appreciation of the

Cathedral above cornice line, whilst some tall buildings, including the Barbican

Towers, compromise that backdrop (paragraph 225). It recognises how the

Heights has led to an unrelenting horizontal emphasis of those middle ground

buildings relived by the spires and towers of the City churches (paragraph

226).

301. The proposal would be sited just west of centre within the prospect, and as

such would not ‘crowd’ close to St Paul’s or undermine the visibility or

dominance of the Cathedral in accordance with paragraphs 227-9 of the visual

management guidance in the SPG. The proposal would not harm the

contribution of a landmark or contributing feature, preserving the historic

skyline and the juxtaposition of elements including river frontage and

landmarks, whilst allowing these to continue to be enjoyed in their context, in

accordance with paragraphs 68, 69 and 70 of the SPG.

302. The striking tiered form and silhouette, which would be seen beyond 120 Fleet

Street would add a high quality new architecture which, with its sculptural form

created by tiers of external terracing, would assist in relieving that ‘unrelenting

horizontality’ referred to in the SPG.

303. Overall, the proposal would not harm the characteristics and composition of

the strategic view and its landmark elements, including preserving an ability to

recognise and appreciate St Paul’s Cathedral as the SIL.

15B.2: Waterloo Bridge: The Downstream Pavement (with night time –

southern end)

304. St Paul’s Cathedral is identified as the sole SIL in this iconic London view and

River Prospect, with other landmarks and contributing features including

Temple Gardens, St Bride’s and the Old Bailey. The river defines the

foreground, while the eye is dawn towards Temple Gardens, St Paul’s

Cathedral and the City Cluster.

305. The proposed development would not be visible from LVMF 15B.1 and would

emerge into view during the kinetic experience between 15B.1 and 15B.2.

Here it would rise above the foreground buildings enclosing the river in the

middle ground, and form part of a secondary layer of background townscape

composed of similarly scaled modern commercial buildings to the north of

Fleet Street. The sweeping and stepped façade of cascading terraces would

contribute a high-quality new piece of sculptural architecture to the view

306. Whilst the proposal would modestly consolidate it, the existing nucleus of tall

buildings around New Street Square is set at some distance away from the

Cathedral in this view and the proposal would not draw it closer to the

Cathedral, preserving the composition of the view, including the sky backdrop

of St Paul’s, avoiding a ‘canyon effect’ and would not dominating the SIL, in

accordance with the relevant visual management guidance at paragraph 264

of the SPG.

307. Historic England have identified that the proposal would have a harmful impact

on the setting and significance of the Strand and Temples Conservation Areas,

by virtue of the development’s presence in the view, which they considered to

draw attention away from these heritage assets, thereby harming the character

and appearance of the conservation areas and the ‘perception of the

significance’ of (unspecified) listed buildings.

308. Officers disagree with this conclusion. Paragraph 262 of the SPG requires

proposals to show how they contribute to the settings and spaces and buildings

immediately fronting the river.

309. The proposal would nestle into to the existing background of modern mid-rise

developments around New Street Square which already define the skyline of

this viewing experience. These are already read as recessive background

elements, separate from rather than competing with the Temples and Strand

CAs in the foreground.

310. The proposal’s distinctive green landscaped terraces, articulated with tall and

medium sized trees, would rise out of and complement the verdant foreground

distinctive of the Victoria Embankment, sloping away from the pre-eminent

foreground setting of the river, and complementing the verdant character of

the Temples.

311. As such, the proposal would comply with paragraph 262 of the SPG and would

preserve the settings of the Strand and Temples conservation areas, including

the juxtaposition between elements and the river frontage which would still be

enjoyed in their context, in accordance with paragraphs 68-70 of the SPG.

312. Further consideration of the impact on the heritage assets of the Temple is

given in the Heritage section of the report below.

313. Overall, the proposal would not harm and would make a neutral contribution to

the characteristics and composition of the strategic view and its landmark

elements, including the ability to recognise and appreciate St Paul’s as the SIL.

16A.1: The South Bank: outside Royal National Theatre

314. The view is principally focused on Somerset House and its immediate setting

as described in the SPG. Other landmarks include Waterloo Bridge and the

Fleche of the Royal Courts of Justice. St Paul’s Cathedral is the sole SIL in

this view, located at the furthest, easternmost periphery of this broad river

prospect.

315. The visual management guidance describes the dominance of the River in the

foreground, and has been positioned to capture the Grade I Listed Somerset

House as its principal focus. The view also captures Temple Gardens, and

remarks on the low profile both features display. It goes on to identify how, due

to the topography of rising ground, the background of this is backdropped by

buildings (paragraph 271). The verdant density of trees along the Embankment

are also identified as an important element in the view (paragraph 272).

316. It is considered that the proposal would preserve the pre-eminence of the open

prospect over the river and skyline presence of the Temples. It would comprise

an attractive part of the established backdrop of larger commercial/institutional

buildings transitioning in scale from that foreground to Fleet Street and the

more recent developments around New Street Square. Its attractive sweeping

form would offer a new high-quality piece of architecture with a skyline

presence that would complement the varied layering of the townscape from

here. Its position on the skyline in the centre of this view, combined with its

height and scale, will help integrate the adjacent 120 Fleet Street within the

background skyline, reinforcing the coherence of a group of similarly scaled

modern commercial buildings to the north of Fleet Street, all in accordance

with paragraph 69, 70, and 72of the SPG.

317. Sited at some considerable distance from the landmark, the proposal would

not dominate or be detrimental to the setting or skyline of Somerset House in

this view, in accordance with paragraph 274. Similarly sited at some distance

away, it is considered that the proposal would preserve the ability to recognise

and appreciate St Paul’s as the SIL, which would remain the pre-eminent

focus.

318. Overall, the proposal would not harm and would make a neutral contribution to

the characteristics and composition of the strategic view and its landmark

elements, including the ability to recognise and appreciate St Paul’s as the

Strategically Important Landmark (“SIL”).

16B.1 and 16B.2: The South Bank: Gabriel’s Wharf viewing platform

319. St Paul’s Cathedral is identified as the sole SIL, whilst other relevant elements

are St Bride’s Church and Temple Gardens.

320. Sited at some distance from the Cathedral in this view, and clearly belonging

to the existing nucleus of tall buildings at New Street Square, the proposal

would preserve the townscape setting of the Cathedral in accordance with

paragraph 280. It would preserve the ability to recognise and appreciate St

Paul’s as the SIL, which would remain the pre-eminent focus throughout the

viewing experience at and between the Assessment Points, and in

architectural treatment the proposal would be clearly read as a separate,

modern entity unrelated to and at some distance from the Cathedral, all in

accordance with paragraph 283 of the SPG.

321. Historic England have identified that the proposal would have a harmful impact

on the setting and significance of the Strand and Temples Conservation Areas,

by virtue of the development’s presence in the view, which they considered to

draw attention away from these heritage assets, thereby harming the character

and appearance of the conservation areas and the ‘perception of the

significance’ of (unspecified) listed buildings.

322. The visual management guidance describes the dominance of the river in the

foreground, with those buildings on the north side providing a rich and intricate

skyline; reference is made to the subtle transition of scale between the

Temples and the more recent commercial development on Fleet

Street/Ludgate (paragraph 278). Paragraph 282 of the SPG notes several

landmarks and historic buildings other than the Cathedral present in the view,

and that the ability to recognise these should be preserved or enhanced.

323. Officers disagree with Historic England’s conclusions and consider that the

proposal would preserve the pre-eminence of the open prospect over the river

and skyline presence of the Temples and other Victorian/Edwardian buildings

defining the Victoria Embankment. Furthermore, the development would form

part of and positively contribute to the established backdrop of larger

commercial/institutional buildings transitioning in scale from that foreground to

Fleet Street and the more recent developments around New Street Square.

324. The proposal’s attractive sweeping form and well articulated elevations would

offer a new high-quality piece of architecture with a skyline presence that would

complement the varied layering of the townscape from this view. Its position

on the skyline, combined with its height and scale, would help integrate the

adjacent 120 Fleet Street within the background skyline, reinforcing the

coherence of a group of similarly scaled modern commercial buildings to the

north of Fleet Street.

325. Overall, the proposal is considered to comply with the test in paragraph 282

and would preserve the settings of the Strand and Temples conservation

areas. It would not harm the characteristics and composition of the strategic

view and its landmark elements, including the ability to recognise and

appreciate St Paul’s as the SIL and Temples.

17B.2 and 7B.1: Golden Jubilee/Hungerford Bridge – crossing the

Westminster Bank

326. St Paul’s is the sole SIL, while given the raised and broad panorama here there

are many landmarks and contributing features, including St Bride’s, the Royal

Courts of Justice and the Old Bailey, amongst others.

327. The SPG describes the River as defining the foreground and middle ground,

enlivened by Waterloo Bridge and the Embankment trees creating a significant

sense of horizontality. It identifies St Paul’s as rising above the general

townscape, including the City Cluster off to the right, while St Bride’s and Old

Bailey are identified as distinctive vertical elements seen against sky as are,

to the Barbican’s trio of towers.

328. The setting of St Paul’s, as the singular most important structure, would be

preserved in accordance with paragraph 301, the proposal being of an

appropriate height, set at some distance away from the Cathedral. It would

strengthen the sense of a smaller cluster of taller built development around

New Street Square, complementing the presence of 120 Fleet Street, forming

a secondary layer of mid-rise development towards the centre of the view. It

would have no impact on Somerset House, in accordance with paragraph 302.

329. The proposal would not obscure or detract from a landmark, discernible at

some distance from the distinct vertical skyline presence of St Bride’s, the Old

Bailey and Barbican Towers ensuring the landmarks and contributing features

would have their settings preserved, in accordance with paragraphs 68-70 of

the SPG.

330. Overall, the proposal would not harm and would make a positive contribution

to the characteristics and composition of the strategic view and its landmark

elements, including the ability to recognise and appreciate St Paul’s as the SIL.

18B.1 Westminster Bridge – Downstream

331. The River dominates the foreground whilst in the middle ground the

prominence of Country Hall and the London Eye capture the view, alongside

the Shell Centre in the background. In the wider prospect, there is a consistent

formal and civic scale character to the buildings enclosing the meander of the

River as Westminster transitions to the City. This has a largely consistent but

lively skyline datum, relived by some more vertical built form, such as the

fleche of the Royal Courts.

332. The proposed high-quality architectural form, particularly with its sculpted

sweep of terracing, would provide a new attractive form which would contribute

interest to the distant skyline, creating a distinctive vertical inflection

appropriate to the wider scale of built form enclosing the River.

333. The proposal would relate well to the setting of those foreground and middle

ground landmarks and would contribute positively to the setting of heritage

assets, in accordance with paragraphs 323-24 of the visual management

guidance. It would respect and enhance the civic nature of those north bank

buildings and would not diminish their role and clarity, in accordance with

paragraph 325 of the SPG.

334. Overall, the proposal would not harm and would make a neutral contribution to

the characteristics and composition of the strategic view and its landmark

elements.

Summary of LVMF Impacts

335. The proposal would preserve the characteristics and composition of relevant

strategic views and their landmark elements. It would preserve the viewer’s

ability to recognise and appreciate St Paul’s Cathedral as the relevant

Strategically Important Landmark. It would ensure that the juxtaposition

between elements, including the river frontage and key landmarks, can be

appreciated in their wider London context. This is in accordance with Local

Plan Policy CS13(1), London Plan Policy HC4, emerging City Plan Policy 2040

S13 and guidance contained in the LVMF SPG.

City of London Strategic Views

336. The City of London Protected Views SPD identifies views of St. Paul’s

Cathedral, the Monument, the Tower of London World Heritage Site and other

historic landmarks and skyline features, which must be assessed in relation to

proposals for new built development. The proposed development site is

located within the western periphery of the City of London, and as such falls

outside of the St Pauls Heights policy area, and is located at a significant

distance from the Tower of London World Heritage Site Local setting study

area.

337. Kinetic views from the Southbank and the river bridges are identified in the

SPD. Heritage significance of relevant historic City landmarks is considered

below within the section on indirect impacts to heritage assets.

Monument

338. The Protected Views SPD identifies views of and approaches to the Monument

which are deemed important to the strategic character and identity of the City.

Views from the Monument:

339. The proposal would be outside the field of view scope of all the Monument

Views except for View 5. The Surveyor to the Fabric of St Paul’s Cathedral has

identified a minor level of harm to the Cathedral’s setting as experienced in

this view as a result of the proposed development.

View 5: North West to St Paul’s Cathedral – Impact

340. From here St Paul’s and St Bride’s Church are identified as the key features.

The visual management guidance at paragraphs 4.12 and 4.13 of the

Protected Views SPD identified other features in this panorama such as St

Mary le Bow, the cupola of the Old Bailey, the BT Tower and St Mary

Aldermanry. The skyline presence of these features would not be obscured or

detracted from by the proposal.

341. Paragraph 4.13 identifies the drum, peristyle and dome alongside the tops of

the western towers. At present the dome is on the whole seen above a horizon

datum as the pre-eminent element on the skyline. The drum, peristyle and

south west towers are, on the whole, shadowed by taller built development

around New Street Square, diminishing the presence of the Cathedral

silhouette on the skyline.

342. The proposal would be almost entirely screened by the implemented scheme

at 120 Fleet Street, with only the very uppermost floors slightly visible above.

Although visually and architecturally distinct from 120 Fleet Street, mitigating

any perception of coalescence, the proposals would slightly increase the

massing adjacent to, but not behind, the gilded finial and pineapple at the top

of the south-west tower of St Paul’s Cathedral. The setback top floors and their

shape would ensure the golden finial remains legible against open sky; the

visibility of the topmost storeys of the proposal near the finial would be so

recessive that, overall, officers consider that the proposals would result in no

additional adverse impact over the implemented scheme at 120 Fleet Street.

343. As a composition, it is considered that the proposals would accord with

paragraphs 4.3 of the Protected Views SPD, in that the proposal would not

obstruct it, nor would it detract from the general open prospect and those

landmark elements as a result of appropriate bulk and massing.

344. Overall, officers consider the proposed development would protect this

significant local view from the Monument, in accordance with Local Plan Policy

CS 13 and emerging City Plan Policy S13 and guidance contained in the

Protected Views SPD.

Views of and Approaches to the Monument:

345. The proposal is not in the defined Immediate Setting of the Monument and

would have no impact on those identified views of/approaches to the

Monument as identified in the Protected Views SPD.

St Pauls Cathedral

St Paul’s Heights and the Processional Approach:

346. The proposal is not located in the defined St Paul’s Heights Policy Area. The

St Pauls Heights policy seeks to preserve the foreground setting of the

Cathedral in strategic riparian views across the Thames from the South Bank

and London Bridges, as longstanding protection to secure an appropriate

setting of St Paul’s Cathedral in Local Views. As demonstrated by verified

views submitted within the THIVA, the viewing experience of St Pauls from

these locations would not be impacted, as a result of the proposals, given the

substantial distance between Hill House and the policy boundary, and the

secondary layer of townscape/built-form which falls in-between the site and

the Policy Area..

347. It would not be visible in views of the Cathedral on approach from Fleet Street

along the Processional Route, by virtue of the development site being located

approximately 112m from the street, and screened by Stonecutter Court

immediately to the south. The kinetic viewing experience of the Processional

Route would therefore be unchanged as a result of the proposal.

Cannon Street views:

348. Views of the Cathedral are highly prominent from Cannon Street. In this long

axial approach from the east, fine and clear views emerge of the South

Transept Portico, Apostles and Western Towers against clear sky, in addition

to the south-west tower, south elevation and dome.

349. Extensive views testing has been undertaken from multiple locations along

Cannon Steet to assess the impact of the proposal on the Cathedral. As

illustrated within View 15 and 15N of the THVIA, the scale of effect arising from

the proposed development would be negligible, since it would be almost

entirely concealed from view by the implemented scheme at 120 Fleet Street,

with visibly limited to a ‘technical degree’ – the line thickness of the wireline -

in regard to the roofline. This means that at this distance, even with

magnification, the proposal would be imperceptible to the human eye. As

such, the proposal would not harm the setting or significance of the Cathedral

in this viewing experience.

St Paul’s Cathedral - Views From the Golden Gallery:

350. From the Golden Gallery of St Paul’s Cathedral, the proposal would be almost

entirely screened by the implemented scheme at 120 Fleet Street, with slivers

of the top floor roof pavilions coming into view beyond 120 Fleet street. As

such, it would preserve the composition and character of these views, not

detract from the general open prospect of the viewing experience, and would

pay special attention to the roofscape, in accordance with the Protected Views

SPD.

Other publicly accessible elevated viewing areas - Views from:

Tate Modern:

351. From this viewing location, the development would be visible alongside other

tall buildings within the New Street Square area at a significant distance to the

west of St Pauls Cathedral. The proposed developed would be largely

screened by Peterborough Court, such that only the layered top floors of on

the southern elevation and the central sweeping volume would be visible.

Alongside the other buildings within the cluster, the development would

contribute to the varied skyline. It is considered the character and composition

of the viewing experience here would be preserved and enhanced.

One New Change:

352. From the public roof terrace, the proposal would entirely screened from view

behind the consented, and implemented, 120 Fleet Street, and as such would

have no impact on the essential character and compositional qualities of this

view, thereby ensuring it would be preserved and enhanced.

120 Fenchurch Street Public Garden:

353. Viewed from the western terrace, the proposal would be predominately

screened from view behind the consented, and implemented, 120 Fleet Street.

Only slight glimpses of the rooftop pavilions, and the north eastern corner

elevation would be visible beyond 120 Fleet Street, however these minor

viewing experiences would not be seen against the dome of St Pauls or its

lantern, and therefore would not result in any harm to the setting and

significance of the heritage asset.

City Landmarks and Skyline Features

354. The proposal would not affect views of the majority of City landmarks and

skyline features in accordance with CS 13 (2). Only two would potentially be

affected by the proposals, as below:

St Andrew Holborn and the City Temple

355. These would have a visual relationship with the proposal in views from

Charterhouse Street (view 24). On the right-hand side of this this view, and to

the right of St Andrews Church, the proposal would form part of the layered

backdrop predominantly obscured by mid-rise commercial budlings in the

midground, notably 6 and 1 New Street Square, which the proposal would sit

behind. Officers consider that the degree of encroachment into the background

of this view would be minimal, with the additional height of the proposal aligning

with the midpoint of the central bay of the tower of St Andrew. City Temple

would to the left-hand side of the view and unaffected by the proposals.

356. As such, the experience of St Andrew as a skyline feature would be

unchallenged by the proposals and preserved in accordance with the guidance

within the SPD. Further assessment of the indirect impact of the proposals on

these two listed buildings is found below.

Other Borough Strategic Views

WCC Draft Metropolitan Views SPD

357. Adopted Westminster City Plan 2019-2040 Policy 40(F) (Townscape and

Architecture) states that new development affecting strategic and local views

(including views of metropolitan importance) will contribute positively to their

characteristics, composition and significance and will remedy past damage to

these views where possible. Whilst in draft, the Metropolitan Views SPD (2007)

is understood to contain those local metropolitan views. Of the 45 identified,

the proposal would be prominent from only V18 – Churches of St Clement

Danes and St Mary-Le-Strand.

358. The Metropolitan Views SPD describes how both churches dominate eastern

views along the Strand, from where the two towers make a ‘delightful and

lasting impression’. The SPD identifies a broad viewing experience zone and

viewing cone from the southern pavement east of Exeter Street, which extends

east/north East into the City of London. Extensive views testing has been

undertaken to assess the impact of the proposal on the viewing experience

identified in the SPD. View 17 of the townscape heritage and visual impact

assessment represents the viewing experience most representative of the

SPD description, with the sequence and composition of both towers legible

and encircled by sky. In this view, both towers remain clearly legible, with only

a fleeting glimpse of the proposal coming into view in the distant background.

The visibility would be limited to the top two floors of the building, behind the

pitched tourelle roof of the Royal Courts of Justice.

359. View 18, taken in winter, represents the most sensitive view to change as a

result of the proposals. In this view, the proposal would infill the sky space to

the south of St Clement Danes and be read receding away from the church’s

southern shoulder, as part of the distant background. The massing has been

carefully designed to step down in height to the south-west in a series of

landscaped terraces, and its southwestern elevation given a sculpted curved

form to break down its overall massing into a series of forms, adding interest

and texture to the background of the view. This is reinforced through the

architectural design, which defines the central ‘sweep’ with cream-coloured

fins, visually dividing the south-west elevation into vertical elements.

360. Overall, it is considered that these prominent focal landmarks in this view

would remain visible and appreciable in accordance with the draft guidance.

The indirect impacts on the settings of the two churches as listed buildings is

discussed further below.

London Borough of Camden:

361. Other than those relevant LVMF pan-London views from Parliament Hill,

Primrose Hill and Kenwood, addressed elsewhere in this report, Camden have

not designated strategic local views of relevance to the CoL.

London Borough of Hackney:

362. Hackney has not identified any strategic local views of relevance to the CoL.

Conclusion on Strategic Views

363. The proposal has been sited amongst an established nucleus of tall buildings

around New Street Square which is an emerging Cluster (Holborn and Fleet

Valley) in the draft City Plan 2040, seeking to consolidate strategic growth in

areas with the least impact on pan-London and strategic views.

364. The proposal would preserve the characteristics and compositions of all

relevant LVMF and other strategic pan-London views.

365. It was also sited and designed to preserve strategic views of and from the

Monument and of the setting and backdrop to St Paul’s Cathedral, especially

from Cannon Street. It would preserve neighbouring borough views and would

preserve views of relevant City Landmarks and Skyline Features. It would also

preserve the experience from existing and emerging elevated public spaces

which are also important to the character of the City.

366. Following rigorous assessment, officers consider that the proposal would

preserve all relevant strategic views in accordance with City Plan policy CS13,

emerging City Plan 2040 policy S13, London Plan Policy HC3 and HC4 and

associated guidance in the LVMF SPG and Protected View SPD.

Heritage

Designated Heritage Assets - Direct Impact

367. The building is not listed or located within a Conservation Area. The proposals

would therefore not result in a direct impact on any heritage asset.

Non-Designated Heritage Asset (NDHA)

368. As part of the consultation process the Twentieth Century Society have raised

an objection to the proposed demolition of the building, and suggest Hill House

should be considered a non-designated heritage asset (NDHA).

369. A detailed assessment of the architectural and historic interest of the existing

building on the Site was undertaken to inform the proposed redevelopment of

the Site and as part of an application for the Certificate of Immunity from Listing

(COI). A COI was granted for Hill House on 20th October 2023 by Historic

England, confirming that the existing building is not of special architectural or

historic interest to meet the criteria for statutory listing.

370. Following this, the existing building has been assessed against the criteria

Historic England have suggested for selecting non- designated heritage

assets, contained in ‘Local Listing: Identifying and Conserving Local Heritage

Advice Note 7’. The criteria comprise: assets type; age; rarity; architectural

and artistic interest; group value; archaeological interest; historic interest; and

landmark status. The assessment is summarised below.

371. In terms of asset type, age, rarity and architectural interest, as a purpose built

commercial building in the late 1970s, Hill House is one of a number of

buildings of this type, and is not considered to be of any intrinsic design or

architectural merit. Furthermore, with the extensive redevelopment of the

immediate surroundings, it relates poorly to and holds no group value with any

of the neighbouring buildings, and it is not considered to relate positively to the

Fleet Street Conservation Area to the south of the Site. It also holds no

archaeological interest of past human activity, and little intrinsic historical

interest owing to its relatively recent construction and the absence of any

notable associations. Finally, as a result of its somewhat squat appearance

and back-street location, officers conclude that the building does not possess

landmark status.

372. Overall, Hill House is considered to have no architectural and historic value

and fails to satisfy the HE criteria for non-designated heritage asset status.

Designated Heritage Assets - Indirect Impact

St Pauls Cathedral (Grade I)

Heritage Significance

373. London’s and one of the Nation’s most famous landmarks, it was London’s first

Cathedral and one of the earliest sites of Christian worship in Britain, now

identified as one of London’s two Strategically Important Landmarks, being

also the seat of the Bishop of London, the mother Cathedral of the national

and international Anglican Church, a ceremonial centre and backdrop of Royal

and State ritual and pomp and the final resting place of figures central to the

national story, a place of national commemoration and celebration. It is the

masterpiece of seminal national figure and architect Sir Christopher Wren (with

input from other notable designers and craftspeople over time) and of the

distinct English Baroque-style. It was central to the adoption of classical

architecture in Britain, and symbolic of the restoration of London post Great

Fire as a major European political, cultural and economic capital.

374. It is of outstanding national and even international heritage significance. That

significance is architectural, historic, artistic, archaeological, evidential and

communal (social, commemorative, spiritual and symbolic). This significance

is inherent in the iconic architectural form and composition, and in its plan form,

fabric and those memorialising fixtures comprising statuette to mausoleums.

Contribution of Setting

375. In terms of setting, for hundreds of years it was the tallest building in London.

It was strategically sited atop Ludgate Hill, a rare topographical moment in the

City of London and one of its highest points, with a commanding position

overlooking the River Thames. Following the Great Rebuilding Act (1667),

Wren had little influence over even the immediate, never mind wider, setting.

This setting has substantially been altered over time, often with the setting of

the Cathedral at its heart, and to various degrees those elements together

make a substantial contribution to significance and an appreciate of it, in

particular the architectural, artistic, historic and communal significance. Those

contributing elements of significance are deemed, in descending order of

importance:

• Those wider strategic pan-London riparian views from the Thames, its

embankments and bridges which are often iconic and London defining,

and where St Paul’s rises above the immediate surrounding townscape,

strategically sited atop Ludgate Hill, and can be seen alongside

contributing landmarks on the skyline, including the Wren churches. These

make a substantial contribution to significance and an appreciation of it.

• The ancient processional route of Royal and State national significance

along the Strand/Fleet Street, a ‘national spine’ of pomp and parade, of

celebration and contemplation, along a route between the heart of

Government in Westminster and commerce in the City, where St Paul’s is

the pre-eminent culmination/destination of a picturesque sequential

townscape experience at the heart of London’s and the Nation’s identity.

This makes a substantial contribution to significance and an appreciation

of it.

• Those wider pan-London views and approaches where the dome offers a

skyline presence in broad identity-defining London panoramas, for

example from those strategic views identified in the LVMF, including

Parliament Hill, Primrose Hill, Greenwich Park, Blackheath and Alexandra

Palace, amongst others, some of which are subject to local designations.

This include old and newer high level appreciations of the London skyline

which allow the Cathedral to be better understood as part of London’s

wider natural and cultural topography, including from the Monument and

higher level public viewing galleries such as the Sky Garden at 20

Fenchurch Street, One New Change and emerging viewing terraces in the

City Cluster. These make a significant to moderate contribution to

significance and an appreciation of it.

• Those more immediate, often incidental, some more planned, townscape

appreciations, which have resulted ad-hoc and some active townscape

curation over the generations, in particular from St Peter’s Walk (south

transept axis), Cannon Street, the Paternoster Square development,

amongst others, where the Cathedral soars above and dominates its

immediate surrounding as the defining skyline presence. This make a

moderate/significant contribution to significance and an appreciation of it.

Impact

376. In terms of the wider riparian setting (setting element 1), from the river, its

embankments and bridges, the proposal would in no instance challenge the

pre-eminence of St Paul’s on the skyline, being of an appropriate scale and

set away from it. It would also not obscure or detract from a landmark which

contributes to the setting of St Paul’s in these views. These impacts are

covered in detail under the relevant strategic LVMF views at paragraphs 137

– 174. It is considered the wider riparian setting in pan-London views would be

preserved.

377. In terms of the Procession Route (setting element 2), by virtue of the proposals

location a significant distance north of Fleet Street, at no point would it obscure

or detract from the pre-eminence of the unfolding composition or on the skyline

presence of the Cathedral this kinetic viewing experience. This element of

setting and its contribution to significance would be preserved.

378. The proposal would be a little more evident in those wider pan-London (higher

level) experiences of St Paul’s (setting element 3) and the more locally

strategic townscape setting (setting element 4). This would manifest in views

from the Cannon Street approach, from the Monument Viewing Gallery and

from the Sky Garden at 20 Fenchurch Street.

379. In views from Cannon Street, the proposal would be fully screened from view

behind the silhouette of the implemented scheme at 120 Fleet Street, and as

such would not result in any additional impact on the setting of the Cathedral

in this important approach. In terms of those pan-London views (setting

element 3), the proposal would not undermine an appreciation of St Paul’s

strategic wider skyline setting from London’s broad cityscape panoramas, as

discussed in the section above. Equally, from the Monument Viewing Gallery,

the proposal is not considered to result in any further erosion of the sky

silhouette of the Cathedral in views west.

380. The proposal would not be visible in townscape views around the close setting

of the Cathedral.

St Paul’s Conclusion of Impact

381. The proposal would preserve the significance and setting of St Paul’s from

those identified local townscape views and higher-level pan-London views -

elements of setting which make a moderate to significant contribution to

heritage significance. Overall, the proposal would preserve the setting and

significance of St Pauls Cathedral and the ability to appreciate it.

St Brides Church (grade I)

Heritage Significance:

382. Church of 1671-8 by Sir Christopher Wren with spire of 1701-3, one of Wren’s

tallest and comprising five octagonal stages of diminishing height. The spire is

one of the most distinctive and memorable on the city’s skyline, appreciated

from within and outside of Fleet Street Conservation Area. The skyline

presence when viewed from the bridges and banks of the Thames makes a

significant contribution to significance, especially where the spire can be seen

as part of the romantic historic skyline around the Temples to Blackfriars and

in association with St Paul’s. The church was gutted in the Blitz and restored

by Godfrey Allen in 1957. The associated excavations by Professor Grimes in

1952-3 comprised the first complete archaeological investigation in England of

a parish church. They revealed that the site of the church had been in use

since the Roman period.

383. It is of outstanding national architectural/aesthetic, artistic, historical,

archaeological and to a lesser extent communal significance.

Contribution of Setting:

384. Elements of setting make a significant contribution to architectural and historic

significance, in particular an appreciation of it. In relative order of contribution,

it is considered that this derives from:

• Pan-London broad riparian views from the River Thames, its embankments

and bridges, including strategic LVMF River Prospect views from Waterloo

Bridge, Gabriel’s Wharf, Hungerford Bridge Southwark Bridge and London

Bridge, where it can be appreciated as a landmark steeple atop the rising

banks of the Thames, denoting the processional route and seen in

complementary juxtaposition with Wren’s masterpiece, St Paul’s. These

make a significant contribution to architectural/aesthetic and historical

significance.

• Local, often glimpsed, sudden and fleeting local views from Fleet Street, St

Bride’s Avenue, Bride’s Passage and Bride Lane allow for the full force of

Wren tower and steeple to be appreciated in an intimate townscape context.

This makes a moderate contribution to architectural and historic

significance, especially an appreciation of it.

• The local topography and change in levels which allow for an appreciation

of the burial site and it marking a climb from the riverside making a modest

contribution to architectural/aesthetic, historical and archaeological

significance.

Impact:

385. At no point would the proposals interface and obscure an appreciation of the

distinctive steeple in those designated strategic LVMF River Prospects.

Similarly in kinetic views from the South Bank, there would be no direct

interface with St Bride’s. Sitting behind Peterborough Court, and extending in

this view to a similar height as 120 Fleet Street, the proposal would nestle into

a secondary townscape layer of tall commercial buildings, preserving the

silhouette of the distinctive steeple on the skyline.

386. Overall, the proposal would preserve the setting and significance of St Bride’s

Church and the ability to appreciate it.

Church of St Andrew Holborn (grade I)

Heritage Significance:

387. Church, formerly mid-fifteenth century, ruinous and dilapidated by the time of

the Great Fire which it escaped. Nevertheless, it was rebuilt to the design of

Sir Christopher Wren in 1686-7, preserving the fifteenth century tower which

Wren refaced in 1703-4. The building was damaged by bombing in the Blitz

and restored by Seeley and Paget. As well as these architects, the church has

associations with a number of important historical figures such as former Prime

Minister Benjamin Disraeli, who was baptised there in 1817, and James

Somerset, the former enslaved African who was central to the significant legal

ruling in 1772 that slavery lacked a firm foundation in English law.

388. Archaeological excavation has revealed evidence for Roman use of the site

and a timber church is documented on the site in 959.

389. It is of outstanding national architectural/aesthetic, artistic, historical,

archaeological and to a lesser extent communal significance.

Contribution of Setting:

390. Elements of setting make a significant contribution to the

architectural/aesthetic, artistic and historic significance. In relative order of

contribution, it is considered that this derives from:

• Neighbouring historic buildings including Holborn Viaduct, Shoe Lane

Bridge and the City Temple (the latter grade II listed) and S.S. Teulon’s

grade II listed Court House, Rectory and Vestry Clerk’s complex of 1868-71.

These close elements of setting form a group and make a high contribution

to the significance of the church.

• To the north, the tranche of historic townscape in the London Borough of

Camden, comprising Hatton Garden and Ely Place, makes a medium

contribution to the significance of the church.

• Otherwise, the setting of the church, particularly to the south east and south,

is now characterised by large office developments which make no

contribution to significance.

Impact:

391. The proposal would affect the wider, neutral setting of the church to the south.

In short views from Charterhouse Street the top of the proposed development

would appear on the skyline above the existing modern buildings to the

southwest of the Church, in particular 1 New Street Square. The extent of

visibility above these is modest. The wider southern setting of the Church is

characterised by large footprint and tall commercial developments, with glass

and metal framed elevations, with which the proposal would have an affinity

and would be read, distinct from the church and the group of historic buildings

in the foreground. In longer views from the north, from Hatton Garden, there

would be no interface between the church and the proposal. Overall, the

historic form of the church would continue to be clearly legible against a

backdrop of modern architecture.

392. As such, the proposals would preserve the significance and setting of St

Andrew Holborn and the ability to appreciate it.

Church of St Dunstan in the West (grade I)

Heritage Significance:

393. Church dating from 1830-3 by John Shaw senior and has a Ketton stone

Gothic tower in the Gothic style and is surmounted by an octagonal stone

lantern. Occupying the site of a church first attested in c.1170, the building

incorporates monuments from the earlier church and statues and masonry

from the nearby Ludgate, demolished in 1760 for road widening, including of

Queen Elizabeth (c.1586) and King Lud and his Sons. The church’s date,

architectural form and surviving monuments are rare in a City context. So too

is the octagonal lantern with its delicate Gothic tracery. This is a significant

presence on the local Fleet Street skyline when viewed from east and west –

forming part of the Processional Route from St Paul’s Cathedral to

Westminster Abbey – and it is identified in the Protected Views SPD as a City

church considered to have presence on the wider skyline.

394. It is of outstanding national architectural/aesthetic, artistic, historic and to a

lesser extent communal significance.

Contribution of Setting:

395. Elements of setting make a significant contribution to the architectural and

historic significance. In relative order of contribution, it is considered that this

derives from:

• Views on approach from the West, from the Strand, and from the east, along

Ludgate Hill, Ludgate Circus and Fleet Street. St Dunstan’s, with St Brides

and the Royal Courts of Justice are key connected landmarks and their lofty

spires are prominent above the varied eclectic Fleet Street townscape

experienced along Fleet Street as well as from the River. This wider setting

with other landmarks contributes to their overall architectural and historic

significance. This makes a significant contribution to significance.

• Pan-London riparian views from the South Bank Queen’s Walk which it

contributes to that wider historic setting of the Temples and Fleet Street

making a moderate contribution to significance.

• Fleeting glimpses in the courts and alleys north of Fleet Street making a

modest contribution to significance.

Impact:

396. The proposed development will not be visible in relation to the Church of St

Dunstan in the West, in local townscape settings, visibility being occluded by

the existing intervening townscape and the curve of Fleet Street.

397. Overall, the proposals would preserve the setting and significance of the

church and the ability to appreciate it.

Church of St Clement Dane (grade I)

Heritage Significance:

398. Church of 1680-82 by Sir Christopher Wren, reusing but refacing fifteenth

century masonry of the west tower, with a spire of 1719 by James Gibbs. The

building is therefore a work of two of the outstanding architects of the age. It

was heavily damaged by bombing in World War Two and restored by W A S

Lloyd in 1955. Upon re-consecration the church became the Central Church of

the Royal Air Force. It is of Portland Stone in Wren’s characteristic English

Baroque manner, with an elegant steeple with a skyline presence. Restored

interior with broad tunnel vault, galleries and groin vaulted aisles, the latter,

uniquely in a Wren church, being continued as ambulatory round east end with

further semi-domed apse added.

399. It is of outstanding architectural, artistic, historic and archaeological heritage

significance, on the whole contained in the external and internal physical

fabric, but with a substantial contribution from setting.

Contribution of Setting:

400. Elements of setting make a substantial contribution to the architectural and

historic significance. In relative order of contribution, it is considered that this

derives from:

• An important architectural and historic landmark on the Processional Route

with a prominent central position on the Strand, where it is appreciated as

an important part of the ‘pomp’ and ceremony of this route with a skyline

presence. This makes a substantial contribution to significance and an

appreciation of it.

• Wider pan-London riparian skyline views from as far west as Westminster

Bridge and also from the South Bank and Waterloo Bridge. These make a

significant contribution to significance and an appreciation of it as part of

central London’s historic skyline.

Impact:

401. In longer views from the west along the Strand, where it is experienced serially

with St Mary Le Stand, the proposal would provide a subtle and layered

backdrop to the background setting of the church.

402. Historic England and City of Westminster Council have identified harm to the

significance of Church of St Clement Danes, by virtue of the proposal infilling

the skygap between it and the implemented scheme at 120 Fleet Street in

views eastward along the Strand, which would create a continuous built

backdrop in these views. Officers acknowledge this conclusion but disagree

as to the impact.

403. While officers acknowledge the proposal would fill in the sky gap in longer

views on approach from the west along the Processional Route of the Strand,

and appear fleetingly behind the spire in some views from the central

reservation, its form and massing is not considered to challenge or undermine

the principal architectural features of the church, namely its ornate tower and

steeple which would still be read clearly In both long and short views, the

proposal would be heavily screened by the large mature trees which line this

route, such that even when not leaf, the skygap would be largely obstructed in

these views.

404. The total height of the development would only marginally, and momentarily,

surpass the horizontal datum of the top stage of the steeple, and the massing

would sweep away from the church having been broken down into a series of

smaller elements. The elevations have been carefully detailed to be visually

recessive and provide vertical texture, to distinguish the two buildings from

each other, and ensure the Portland stone of the church spire would remain

prominent on the skyline in views along the Strand.

405. At closer range, due to the curvature of the road, the development would fall

behind and be screened by buildings on the north of Fleet Street, such that it

would have extremely limited intervisibility with the Church, demonstrating that

the level of impact is fleeting and quickly diminishing in the kinetic sequence

moving east.

406. The steeple’s skyline presence in those wider pan-London riparian strategic

views from the river, its embankments and relevant bridges, the second

element of setting contributing to significance, would be preserved. At no point

would the steeple be obscured, or detracted from, by a proposal set at some

distance from it in these views.

407. Overall, the proposal would preserve the setting and significance of St Clement

Dane and the ability to appreciate it.

Church of St Mary Le-Strand (grade I)

Heritage Significance:

408. Church, of 1714-17, by renowned Georgian architect and landscape designer,

James Gibbs, thought to reflect his experience in Rome, whilst paying tribute

to Wren. It is of Portland Stone and is symmetrically composed with a tower

and steeple rising in 3 diminishing open stages with aedicules in elegant

Corinthian order and distinctive Wren-like flaming urns. It has a main west

front, exceptionally situated on a central island commanding the vista west

along the Processional Route of Royal and State significance, and an

important part of an unfolding, sequential townscape setting of rare London

formality, but in the English Picturesque tradition.

409. Aisleless interior with the apse framed by superimposed orders of coupled

columns and coupled columns carrying balcony over west door. Panelled walls

with pilasters to upper register and coffered ceiling.

410. It is of outstanding architectural, historic, artistic and archaeological heritage

significance, on the main contained in the physical fabric of the exterior and

interior, but with a substantial contribution from setting.

Contribution of Setting:

411. Elements of setting make a substantial contribution to the architectural and

historic significance. In relative order of contribution, it is considered that this

derives from:

• An important architectural and historic landmark on the Processional Route

with a prominent central position on the Strand, where it is appreciated as

an important part of the ‘pomp’ and ceremony of this route with a skyline

presence. This makes a substantial contribution to significance and an

appreciation of it.

• More limited glimpses the steeple from Waterloo Bridge and the Queen’s

Walk, in particular where this is seen in complementary architectural

juxtaposition with Somerset House in the foreground. This make a moderate

contribution to significance and an appreciation of it.

Impact:

412. Historic England and City of Westminster Council have identified harm to this

church. However, as with Church of St Clement Dane, the proposal would have

a transient impact on the kinetic approach towards the church from the

northern pavement of the Strand resulting in a transient, even fleeting,

appearance of the proposal below the shoulder height of the church.

413. It would appear at some distance as a backdrop feature to the church, which

would remain preeminent in the foreground. It would be read in context of the

unfolding layers of monumental institutions of state and commerce which

characterise the viewing experience of the Processional Route, where there is

interactions of the steeple with other skyline features such as the Deloite

Building (New Street Square) and the Royal Courts of Justice. At no point

would it challenge the steeple silhouette. As such, it is considered that this

principal contributing element of setting to significance would be preserved.

414. Those more limited glimpses of the steeple, including in association with

Somerset House, from the River, Waterloo Bridge and the South Bank, would

not be obscured or detracted from, preserving this element of settings

contribution to significance.

415. Overall, the proposal would preserve the setting and significance of St Mary

Le Strand and the ability to appreciate it.

Royal Courts of Justice - Grade I

Heritage Significance:

416. National courtroom buildings of 1874-1883, designed by George Edmund

Street and finished by Arthur E. Street and Sir Arthur Blomfield. High Victorian

Gothic Revival design, combining 13th century English and French

architectural styles. Principally in Portland stone ashlar with red bricks and

granite, marble, and red sandstone dressings. Slate roof. Widespread usage

of ironwork, both structural and decorative.

417. The building is four to five storeys and arranged across two principal blocks,

all the functions arranged around a central, rectangular hall. The list

description notes: ‘the lengthy southern front facing the Strand is divided into

several distinct parts and repeated motifs help to tie together the design into a

unified whole…Although there is an element of calculated asymmetry to the

overall design, there are symmetrical or near-symmetrical groupings. The most

striking is that which identifies the principal courtroom block and the entrance

to the central hall which is gradually stepped back from the street line.(List

Entry Number: 1264258).

418. The building is of very high architectural interest, ‘with a considerable presence

at the heart of London and the centre of the legal district occupied by the Inns

of Court; it is generally considered to be the foremost work of George Edmund

Street, one of Victorian England’s principal architects; its meticulous planning

is accompanied by considerable inventiveness in designing numerous different

interiors including courtrooms, corridors, staircases, libraries and the large and

impressive central hall, all of which retain the majority of their original fittings.

Historic interest: the building is a celebration of the reform of the legal system

in C19 England, by a raft of legislation which aligned the processes of Equity

and Common Law to create a fairer system of justice. Group value: with

numerous listed buildings on the Strand and Carey Street, notably the Church

of St Clement Danes, Strand (Grade I)’(List Entry Number: 1264258).

419. It is of outstanding national architectural/aesthetic, artistic, historical, and to a

lesser extent, communal significance.

Setting:

420. The setting of the Royal Courts of Justice is largely informed by its environs

on the Strand, with the main entrance to the buildings being from the south.

The buildings are within the Strand Conservation Area. There is an element of

group value with the other landmark historic buildings on the Strand, in

particular the two churches – St Clement Danes and St Mary-le-Strand, which

form a group, in views along east to west and vice versa; and to a lesser extent,

the Church of St Dunstan in the West. The listed building’s heritage

significance and landmark quality is best appreciated, however, in close views

from The Strand. The scale of the Courts is similar to that of the Aldwych

buildings which inform the close setting to the west. The overall setting has a

strong group value of a late 19th and early 20th-century civic nature. The wider

setting of the Royal Courts is already informed by several architecturally

contrasting, more modern buildings of a greater height.

421. There is currently no visual or historic relationship with the Site. Existing tall

buildings located in proximity to the Site, in particular 6 New Street Square, are

visible in longer distance views of a small part of the roofline of the Royal

Courts from the west.

Impact:

422. The listed building is best appreciated in close views from the Strand where

visibility of the proposal will be negligible. It would however be visible in the

wider setting of the Royal Courts of Justice, as shown in View 20, where it will

be visible as a negligible and distant addition to the background skyline. It

would also be visible in the backdrop of a small part of the roofline of the Royal

Courts which is visible in views from the Strand (View 17, 19 and A17). In these

views the churches on the Strand form the primary focal landmarks, with a

strong skyline presence, whereas the Royal Courts are less prominent, and

largely obscured by the Church of St Clement Danes.

423. Taller buildings to the east, in particular 6 New Street Square and the emerging

120 Fleet Street, are already glimpsed in some views beyond the roofline of

the Royal Courts. The proposal would introduce a new building of a similar

scale to these tall buildings which characterise the commercial, 21st-century

character of the wider eastern setting of the Royal Courts. However,

intervisibility between the two would be minimal, and would not impact the

ability to appreciate the heritage significance of the Royal Courts.

424. Overall, the proposal would preserve the setting and significance of the listed

building and the ability to appreciate it.

Former Public Record Office (grade II*)

Heritage Significance:

425. The Public Record Office was built in 1891-1896 to designs by Sir John Taylor.

This building was an extension to an earlier building to the east on Fetter Lane,

1853-5 by Sir James Pennethorne. The Taylor addition to this building,

incorporated a 13th century archway of the former Rolls Chapel. The

Pennethorne building is in Bath stone, with ashlar dressings and lead roofs.

Taylor’s extension is in Portland stone, also with ashlar dressings. The earlier

building is of interest for its fireproof construction, with individual modular

document cells of wrought iron within shallow arched brick vaults with cast iron

girders. Both elevations are examples of a Perpendicular Gothic style. The

frontage on Chancery Lane is symmetrical, either side of a central archway. It

was the Public Record Office until 2003, today the building is a library for King’s

College London. The building is of high architectural and historic interest.

Setting:

426. The principal element of setting for The Public Record Office is informed by its

prominent position on Chancery Lane and Fetter Lane, where it is viewed as

a the pre-emanant building in the townscape. The significance of The Public

Record Office is best appreciated in views on approach from the east and west,

and from the interior of its southern courtyard garden, where it can be

experienced largely in isolation from its surrounding townscape. The close

setting to the north and east is informed by large commercial buildings, with

the Rolls Building to the north, and the taller modern New Street Square

buildings to the east, which make a neutral contribution to significance.

Impact:

427. The proposal would be slightly visible looking eastwards when emerging from

the western archway. In this oblique viewing experience of the Public Records

Office, the proposal may be glimpsed beyond the intervening tall buildings

which define the western edge of New Fetter Lane/Fetter Lane. However,

considering the alignment of West Harding Street; the screening of the two tall

buildings which it is flanked by; and the distance Hill House would be set

behind these buildings, glimpses of the proposal would be oblique, fleeting and

dissociated with the listed building. Due to this high level of screening, changes

to this setting would be negligible.

428. As such, the proposal would preserve the setting and significance of the listed

building.

Kings Bench Walk Group – 1, 2, 3, 4, 5, 6 and 7 Kings Bench Walk (grade

I), 3 and 8 North Kings Bench Walk (grade II*), and 9-11 Kings Bench

Walk (grade II)

Heritage Significance:

429. These are a highly significant terrace of buildings within Temples Conservation

Area. They are part of a terrace that defines the east side of Kings Bench Walk,

and were built as chambers in the late 17th century. They are one of the most

complete groups of buildings of that date in London and have high aesthetic,

architectural and historic significance. Although there is a variety in the width,

height and roofs, they have a strong visual unity and uniformity of appearance

with a raised ground floor, central and prominent doorcase, strong cornice line

and brick parapet, hipped mansard roofs and a lower ground floor, constructed

of dark red and brown bricks with red dressings. Their significance is derived

from their special historic and architectural interest, and evidential values due

to their date, design and building, as they were constructed for, and still in use

as legal chambers. There is a distinctive wide York stone pavement to the front

of the terrace with a border of Purbeck setts and mature Plane trees. Kings

Bench Walk is an irregular oblong shape, now used for car parking, which has

a gentle slope down to the River Thames. It is bordered on the west side by 1-

5 Paper Buildings, Inner Temple Library and on the south side by Inner Temple

Garden.

Setting:

430. The principal elements of setting contributing to the significance of these listed

buildings are as follows:

• Each of these individually listed building forms a complementary element of

setting with the other, making a significant contribution to significance.

• The neighbouring buildings and spaces within the Temples immediately to

the west, including Nos. 1 & 2 Mitre Court Buildings, Paper Buildings, the

Francis Taylor Building, and the Inner Library which complement them in

aesthetic, style and scale, illustrate the development of the group and help

to define the sense of intimacy and enclosure prevailing across the Temple.

This makes a significant contribution to significance.

• The open, verdant setting of Inner Temple Garden and the open, riparian

setting to the south, which contrast pleasingly with the framing buildings and

which with them generate that singular sense of place which prevails across

the Temple. This makes a significant contribution to significance.

• The open sky setting framing the group, in particular when there is limited

influence of wider built development, accentuating the self-contained and

distinct integrity and authenticity of the ensemble. This makes a moderate

contribution to significance.

Impact:

431. In long-range views from the south and west from within the Temple, the

existing backdrop of this group, whilst largely of clear sky, is characterised by

fleeting glimpses of existing modern buildings which hint at, but not intrusively

so, the presence of the City beyond.

432. These buildings (existing and consented) are a range of distances from the

Temples, but all are clearly detached from the close setting of the buildings

and read as recessive, background elements which disappear in closer views

of the listed buildings. The proposal would have a similar impact. Its upper

levels would in places be visible above the roofline of the listed buildings, but

it would be seen fleetingly with the other existing modern rooftops and would

disappear from view in the closer views.

433. The careful sculpting of its south elevation, quiet materiality and façade

detailing would all further soften the appearance of the proposal in these views.

And in both views tested (view 21, looking across the gardens, and 22 looking

across the car park at King Bench Walk ) from within the Temple, the proposal

would be heavily screened from view by mature tree cover, even when not in

leaf, such that the development would be difficult to perceive.

434. As such, then, the proposal would form another layer in the backdrop already

characteristic of this element of the setting of the listed buildings. The proposal

would preserve the settings and significance of the listed buildings and the

ability to appreciate it.

Nos. 1-4 and 5 Paper Buildings (grade II)

Heritage Significance:

435. Chambers of 1848. Nos. 1-4 are in a plain, classical design while No. 5,

terminating the row to the south, is of a more striking Tudor style. The group

embody the rich, dignified mix of styles and materials of the Temples, tied

together by a consistent scale and dignified aesthetic. Accordingly, the

buildings have high architectural and historic interest.

Setting:

436. The principal elements of setting contributing to the significance of these listed

buildings are as follows:

• The neighbouring buildings and spaces within the Temples immediately to

the west, north and east, including Nos. 1 & 2 Mitre Court Buildings, Paper

Buildings, the Francis Taylor Building, the Inner Library, Harecourt Buildings

and Temple Gardens which complement them in aesthetic, style and scale,

illustrate the development of the group and help to define the sense of

intimacy and enclosure prevailing across the Temple. This makes a

significant contribution to significance.

• The open, verdant setting of Inner Temple Garden and the open, riparian

setting to the south, which contrast pleasingly with the framing buildings and

which with them generate that singular sense of place which prevails across

the Temple. This makes a significant contribution to significance.

• The open sky setting framing the group, in particular when there is limited

influence of wider built development, accentuating the self-contained and

distinct integrity and authenticity of the ensemble. This makes a moderate

contribution to significance.

Impact:

437. There would be background distant views of the development rising above the

rooftops of the perimeter buildings, where the top quarter (approximately) of

the development would be visible. While the well-preserved roofline which is

predominantly experienced with a clear sky backdrop, officers do not consider

that the proposal would unduly challenge this way of appreciating the

buildings. The development would be experienced as a high-quality

architectural addition to the background skyline, with a tangible sense of

separation between it and the listed buildings. Furthermore, the extent of

intervisibility is limited to the western edge of the gardens. The proposal would

consequently fall out of view for the majority of vantage points, and therefore

preserve the overarching, significant qualities of the setting of the listed

buildings.

438. The proposal would preserve the setting and significance of these listed

buildings and the ability to appreciate it.

Inner Temple Garden (grade II Registered Historic Park and Garden)

Heritage Significance:

439. Inner Temple Garden and Middle Temple Garden have a medieval origin and

evolved from the 16th – 20th centuries and play an important role in defining

the character of the Temples. The gardens are the largest private green space

in the City of London and include mature trees, shrubs, considered planting,

statuary and retain a quiet domestic character and are important for the setting

of surrounding listed buildings. The area is defined by its legal professions

which have evolved over centuries and continues to exist here. In brief, the

significance of the Registered Historic Park and Garden is derived from

successive landscape layouts, varied planting and lawned areas, and its

domestic gated quiet character representing historic and architectural values.

Setting:

440. The principal elements of setting contributing to the significance of this RHPG

are the arcadian but planned character of the registered landscape, in addition

to its connection to the open setting of the River. Of equal contribution, by

virtue of its juxtaposition, is the sense of enclosure derived from the cloister of

buildings which consistently define its edges. The tranquillity afforded by this

landscape also contributes to its experiential quality as rare sanctuary within

inner London, which also contributes to its significance.

Impact:

441. The potential impact on development has been assessed from the footpath in

the southwestern corner of the gardens. There would be glimpsed slivers of

the building rising above the foreground buildings of 1-5 Kings Bench Walk but

this would be discreet and largely experienced between trees from incidental

locations. The proposal however would be the largest built development to rise

above the roof line of 3-6 King Bench Walk, where its massing would be read

rising up from the roofline at the northern end of the terrace. However, the

development would be experienced at some distance away from the close

intimate setting of the terraces and garden, and as the appendix photography

demonstrates, views of the development would be limited to glimpses from

more central aspects within the gardens. Officers consider that the

development would not challenge or dominate the foreground or background

or alter the special, intimate, and tranquil, character of the designated heritage

asset.

442. There would be no harm to the wider setting or significance of the registered

park and garden and its heritage values would be preserved.

Dr Johnson’s House (grade I) and No. 5 Pemberton Row (grade II)

Heritage Significance:

Dr Johnson’s House

443. Late 17th century house, altered in the 18th century and rescued and restored

in 1911-1912 by Alfred Burr who opened it as a museum. A 3-storey building

with a basement and an attic; red brick with rubbed brick window surrounds

and platbands. Restored flush sash windows and a c.1775 front door with

fanlight above. Notably rented by the writer Dr Johnson from 1748 to 1759,

who compiled his famous Dictionary in the attic of the house. Damaged during

WWII but repaired and a new roof added.

444. The building has high architectural interest as an example of a substantial late

C17 house in the City of London with remarkably well-preserved interiors. It

has significant historic interest for the connection with Dr Johnson who

compiled his Dictionary in this house, and for the further historic connections

to his servant Francis Barber.

5 Pemberton Row

445. 5 Pemberton Row is a late 17th/early 18th century house of three storeys, with

a basement and attic, which has been much renovated. The ground floor is

stuccoed, with altered fenestration, although in keeping box sashes across the

front elevation; with a red tiled mansard roof behind a parapet with dormers. It

holds architectural and historic interest as a late 17th/early 18th century house

in the City, albeit much renovated.

Setting:

446. The setting of Dr Johnson’s House is primarily informed by its location at the

west end of Gough Square which is a surviving element of the historic

townscape network of squares and alleys to the north of Fleet Street. Gough

Square forms an intimate and close setting which enhances the ability to

appreciate the character and aesthetic value of the late 17th century house

within its historical urban setting. The close setting of Dr Johnson’s House

within the square, and intimate character of the space, is best appreciated in

the view westwards towards Dr Johnson’s House from within Gough Square.

This close setting of Gough Square is the principal element of setting which

contributes to significance.

447. The rear of the house, which addresses Pemberton Row alongside No.5, is

appreciated within the wider setting to Gough Square which is informed by

much larger-scale, commercial buildings to the north and east; Peterborough

Court is clearly visible in the backdrop of 9 Gough Square at the eastern end.

120 Fleet Street (currently under construction and part of the Future Baseline)

will also be visible in views east from the Square, and from Pemberton Row.

In this viewing experience, the secondary, north, elevation of Dr Johnson’s

House forms a group with the other brickwork elevations, including No. 5, of

similar scale and character; these elements of close setting make a modest

contribution to the significance of the two listed buildings. Otherwise, the

viewing experience is of the contrast between a portion of the low-rise, historic

City and the wider, modern City beyond. This aspect of setting makes a neutral

contribution to significance.

Impact:

448. The proposal would not be visible in key views of Dr Johnson’s House from

Gough Square.

449. In views looking east from Pemberton Row, and from within Gough Square

(away from Dr Johnson’s House), the proposal would be visible, and of a

consistent scale with the existing, and emerging, tall modern commercial

buildings to the north and east - Peterborough Court and 120 Fleet Street.

However, the presence of the proposal on the skyline would not be unduly

dominating, and would preserve the contrast between the modern City

buildings in the background and the close and intimate character of the

ensemble in the foreground.

450. Furthermore, the proposal would form a high-quality architectural addition to

the background skyline within the setting of these buildings, as it directly

responds to the smaller scale of the context with the massing falling away in

the south-western corner, and the architectural expression emphasising

layering through roof terraces which would be softened though extensive soft

landscaping.

451. Overall, the proposal would preserve the settings and significance of the two

listed buildings and the ability to appreciate it.

Wine Office Court Group – (Nos 1-3 and 7, grade II)

Heritage Significance:

452. Victorian offices built from 1868-1870 by John S. Lee for Robert Burt and

Company, a printing company; initially until 1892 the first quarters of the Press

Association. Stock brick building over four storeys, with a three bay plan

although a narrower central bay and round headed arches above entrance. All

windows sashes with glazing bars. Lower floors with tripartite windows

separated by barley-sugar columns with tiny ionic capitals.

453. Historical interest for the association with the Press Association, the link with

which inspired the development of Fleet Street as the historic centre of the

British newspaper industry. Further architectural interest and aesthetic value

as a mid-19th century office building.

Setting:

454. The immediate neighbours of 7 Wine Office Court are large-scale modern

office buildings dating from the 20th century onwards. The element of its

setting which bears relevance to its historic significance, and the ability to

appreciate this significance, is its maintained location on Wine Office Court

and the character of this passageway as a narrow court/alley, typical of its

historic form within the City. Although this passageway has altered, and Wine

Office Court is now surrounded by more modern buildings and truncated from

the more historically representative southern end to the route, this continued

character does nonetheless allow for a historically representative view of the

building in its location. There is also an element of group value with the

buildings to the south, which are now separated by the open space which

connects to Hind Court.

Impact:

455. This group of listed buildings all primarily address Wine Office Court (east).

However, the proposed Development will be visible in views looking north

along the Wine Office Court, where it would be experienced as an additional

layer of modern commercial buildings, which truncate views north up the

passageway. The fabric and character that defines the setting of these

buildings, primarily a sense of compression and tightly enclosed streets, would

be preserved. Local views south along Wine Office Court will be unaltered by

the proposed development.

456. Furthermore, the massing of the building has been designed to respond to this

smaller scale, stepping down in the southwestern corner, in addition to its

elevations which would all feature terraces with high levels of, and high-quality,

soft landscaping. The proposal would therefore add additional visual interest

to this view north, and improve the skyline setting of the listed buildings.

457. There would be no harm to the wider setting or significance of these listed

buildings.

Victoria Embankment group (Hamilton House; Telephone House; No.9

Carmelite Street; Sion Hall; City of London School; and Unilever House,

grade II)

Heritage Significance

458. This dignified group of C19 buildings have strong architectural interest as a

well-detailed and executed series of elevations in a variety of styles and

employing a variety of materials to delightful effect; they have historic interest

for their associations with their original occupants (a mix ranging from

insurance firms to an ecclesiastical college to a school).

Setting:

459. They have strong group value (with the exception of Carmelite House) and

together (also with the Temples and Blackfriars Bridge) form a picturesque

composition with the river. These two elements of setting make a substantial

contribution to significance. Other elements make a neutral contribution.

Impact:

460. In views of the listed buildings from the South Bank, opposite, the tiered

massing and richly articulated south façade of the proposal would form an

unobtrusive background presence, read as a part of a recessive layer of

existing modern development in the background of these views. The pre-

eminence of the listed buildings within this setting would be unchallenged.

Accordingly, the proposal would preserve the settings and significance of

these listed buildings and the ability to appreciate it.

Conservation Areas

Fleet Street Conservation Area

Heritage Significance, Character and Appearance:

461. The character and appearance and heritage significance of the Fleet Street

Conservation Area is summarised in detail in the Character Summary and

Management Strategy SPD (2016), which is a material consideration. It

summaries that core significance and character stem from:

• The focus of Fleet Street, a processional route between Westminster and St

Paul’s of Royal and State significance since the Middle Ages, and its

ceremonial grandeur and commercial bustle created in particular by views

of St Paul’s Cathedral, St Dunstan’s in the West and St Bride’s, some of the

City most notable ecclesiastical buildings.

• The evocative, fine grain network of historic streets, courts, lanes and alleys

either side of Fleet Street, and their contrasting intimacy, and which have

developed over hundreds of years once developed outside the City walls.

• The exceptional richness and variety of architecture of all ages and styles

and the contrast between them, ranging from domestic Georgian to

monumental 20th Century newspaper buildings.

• The long association with the press industry and other literary figures such

as Dr Johnson and Oliver Goldsmith and of course medieval institutions,

namely the Knights Templar, the Whitefriars, the Inns of Court and the legal

sector.

462. The Conservation Area is of outstanding local and national architectural,

artistic, historical and archaeological significance, drawn principally from the

built form and fabric, and to a lesser but significant degree via setting.

Contribution of Setting:

463. Elements of setting make a significant contribution to significance, and views

and vistas deemed integral to that significance are identified in the SPD. The

main contribution comes via the below:

• Those approaches and views along the Processional Route, both east and

west, towards the Strand and the Royal Courts of Justice to the west and St

Paul’s to the East (Note Views 1 and 2 in the SPD, for example). This makes

a significant contribution to significance and an appreciation of it.

• Those sensitive strategic riparian broad prospects from the South Bank

Queen’s Walk which allow an appreciation of the wider skyline of the

Conservation Area in a wider London context, in particular as a picturesque

ensemble of national monuments and landmarks lining the Processional

Route with a skyline presence to London’s River. This makes a significant

contribution to significance and an appreciation of it.

Impact:

464. Most of the Conservation Area’s significance, character and appearance,

would remain ‘untouched’ and undiluted, given its tight-knit urban grain and

often intimate sense of enclosure, which limits the proposals visual influence

over the majority of it.

465. In terms of those approaches east and west along the Processional Route

(setting element 1), due to the location of the development to the north; the

intervening development to the south; and the width to height ratio of Fleet

Street, there would be no alteration to the experience of the route, and the

townscape which defines its southern edge. Furthermore, it would not obscure

or detract from a landmark/monument in either direction on this approach

which complements the wider setting of the Conservation Area. Where the

proposed development would be experienced from within the Conservation

area, in particular within Gough Square and looking north along Wine office

Court, the additional massing is not considered to dominate or overwhelm the

Conservation Area, whose arresting enclosure and strong, coherent and rich

historic context would remain pre-eminent and undiluted.

466. In terms of those wider riparian views from the South Bank (Queen’s Walk),

the proposal would, on the whole, not obscure, distract or detract from a some

of those skyline features of the Conservation Area, in particular St Dunstan in

the West and St Bride’s, allowing this expression of the Conservation Area to

still be read in the context of wider skyline monuments such as the Royal

Courts of Justice and St Paul’s Cathedral. It would form a complementary high-

quality architectural neighbour to St Bride’s, massed in a deferential manner

allowing the distinct vertical skyline presence of the church spire to be

preserved. It would take an appropriate place as part of an established

backdrop of a modern, taller development off Fleet Street and around New

Street Square, adding a high-quality new piece of modern architecture. This

element of setting which makes a significant contribution to significance would

be preserved.

467. Overall, the setting, character and appearance and significance of the Fleet

Street Conservation Area would be preserved.

Temples Conservation Area

Heritage Significance, Character and Appearance:

468. Of ancient origin, the Temples is perhaps the most distinctive City conservation

area and has a character that is not only unique to the City, but rarely found

elsewhere. It has a restrained, dignified, private and often tranquil character,

in pleasant contrast to the bustle of Fleet Street or the Embankment. It

comprises an exceptional collection of outstanding buildings as part of a lush

open landscape setting comprising the Inner and Middle Temples and the

Temple Church. To summarise the outstanding significance of the Temples

derives from:

• It has a distinct and venerable legal quarter of ancient origin resulting in a

collection of outstanding authentic survivals from the 17th, 18th and 19th

Centuries comprising rare legal chambers, domestic quarters and buildings

associated with the lnns of Court.

• An outstanding townscape of collegiate character comprising courts,

squares and streets, and strong sense of domestic human scale, of

complementary architectural styles and materials, all set in the verdant

setting provided by the Inner and Middle Temple Gardens.

• Its connections with the Knights Templars and the focus on the Temple

Church, based on one of the holiest places in the Crusader world, the

Church of the Holy Sepulchre in Jerusalem, it is one of the oldest and most

significant ancient churches in the City.

Contribution of Setting:

469. Elements of setting make a significant contribution to significance and an

appreciation of it, in the form of environmental qualities, in particular views of

and through it, but also of wider intangible qualities. In relative order of

contribution, those elements comprise:

• Strategic pan-London kinetic views from Hungerford and Waterloo Bridges

and the South Bank Queen’s Walk looking north and east, where it is seen

as part of the Victoria Embankment and as part of the wider skyline. These

make a significant contribution to significance and an appreciation of it.

• Those views out of and through the Conservation Area of the sky, in

particular when there is limited influence of wider built development,

accentuating the self-contained and distinct integrity and authenticity of the

Conservation Area ensemble. These make a significant contribution to

significance.

• Views into the Temples which act as ‘portals’ which transition between the

bustle of Fleet Street / the Embankment, accentuating the sharp contrasts

in character and appearance. The peaceful, restrained and often tranquil

intangible qualities of the public realm, and their contrast with the bustle of

the City around it, make a significant contribution to significance and an

appreciation of it.

Impact:

470. There would be no direct, tangible alteration or change to the physical asset,

whose ancient and rare historic fabric would be untouched. In most views from

within the intimate enclosure and tight-knit grain of the Conservation Area, the

proposals would be imperceptible.

471. Historic England contend that the proposal would dominate the skyline when

viewed from the South Bank, in particular from Waterloo Bridge (LVMF 15B.2)

and Gabriel’s Wharf (LVMF View 16B.1), and “draw attention away from these

heritage assets, thereby causing harm to the character and appearance of the

conservation areas and the perception of the significance of the (unspecified)

listed buildings”.

472. Officers disagree and find no conflict with the LVMF as discussed in the section

on Strategic Views above. In views from the Hungerford and Waterloo

Bridge’s, and the South Bank between Waterloo Bridge and Blackfriars Bridge,

via Gabriel’s Wharf, the proposal would be an appropriate backdrop skyline

feature, complementing, and reading part of, a collection of taller modern built

form in and around New Street Square. The open prospect across the breadth

of the River Thames and the arcadian riparian scene created by the enclosing

combination of the Victoria Embankment and Temple Gardens would remain

pre-eminent. Without undue prominence, the high-quality architecture and

tiered landscaped massing would assist the assimilation of the proposal into

this scene, whereas its silhouette would take its place as part of a high-quality

backdrop. It is considered that setting element 1, pan-London strategic riparian

views, would be preserved.

473. In terms of those views out of and through the Conservation Area (setting

element 2), for moments within the Gardens, and Kings Bench Walk, and

Victoria Embankment, the proposal would come into view. While there would

be a change within this element of setting, officers consider that this would be

consistent with the existing context where other modern developments can be

glimpsed over the rooflines of the terraced blocks, particularly the King’s Bench

Walk group. Overall, officers do not consider the proposal would detract or

dominate, and would be experienced as an incidental moment, preserving the

quiet enclosed and unique significance of Temples Conservation Area. It is

considered that setting element 2 would be preserved.

474. In terms of setting element 3, the experience of the transitionary portals and

the intangible qualities of the public realm in contrast with the surrounding

bustle of the modern City, it is considered that these would be unaffected and

thus preserved by the proposals.

475. Overall, it is considered that the proposal would preserve the setting, character

and appearance and significance of the Temples Conservation Area.

Strand Conservation Area (City of Westminster)

Heritage Significance, Character and Appearance:

476. The Strand Conservation Area incorporates the grand early 20th Century

project of improvements to the Strand and the creation of Aldwych and

Kingsway, a grand continental style half circus and boulevards defined by

formal and robust Portland Stone-faced classical architecture of a civic scale,

north towards Lincoln’s in Fields, whilst incorporating the ancient Strand,

Somerset House and part of the Victoria Embankment and the Royal Courts

of Justice to the east. It is of outstanding architectural, historic and artistic

heritage significance, considered to principally derives from:

• The central ‘national spine’ comprising the Strand, an ancient

Processional Route of Royal and State significance, lined by its often

grand and formal architectures of institutions of state, cultural and

commercial significance, with a picturesque townscape with infolding

the vistas of important landmarks, including the Churches of St Mary Le

Strand, St Clement Dane and the Royal Courts of Justice, alongside

rich statute of national significance.

• The Victoria Embankment and Waterloo Bridge as remarkable piece of

urban infrastructural and planning improvements and the iconic London

views they contain.

• Somerset House as a seminal London and landmark of the River

Thames and one of the finest survivals of Georgian London.

• The contrast between the larger formal architectural some of the that

humbler and more informal architectural from a variety of ages.

Contribution of Setting:

477. Elements of setting make a significant contribution to significance, in particular

an appreciation of it. In order of relative contribution these are considered:

• Views into the Conservation Area from west and east in particular, where

the Strand itself forms an integral part of a ceremonial processional route

of Royal and State significance, part of an unfolding sequential

townscape national monuments and landmarks. This makes a significant

contribution to architectural and historic significance.

• More incidental and formal views from the immediate streetscape on

approach from the south (the Embankment) and the north (Covent

Garden/Holborn). This makes a moderate contribution to architectural

and historic significance.

• Those pan-London riparian views from the River Thames, its

embankments and bridges, including identified strategic LVMF views

from the South Bank, Gabriel’s Wharf, Waterloo, Hungerford and

Westminster Bridges (downstream). These make a moderate

contribution to architectural and historic significance.

Impact:

478. As discussed in the sections on St Mary Le Strand, St Clement Dane and the

Royal Courts of Justice, these landmark buildings form part of an emerging

skyline along the Processional Route. For the reasons established there, by

virtue of the proposed development’s diminishing massing, its contoured

architectural form its high quality vertically expressed elevations and its

position in the distant background, officers consider that it would amount to a

fleeting ‘moment’ of new development, and would not obscure or detract from

that picturesque townscape experience. Despite Historic England’s

identification of harm to this element of setting, for the reasons above, officers

disagree and conclude proposal would preserve the contribution of setting

element 1.

479. The proposal would have no influence on those more incidental or formal

localised townscape views through the Conservation Area and setting element

2’s contribution to significance would be preserved.

480. In terms of setting element 3, the skyline presence of the Strand Conservation

Area would appear at a significant distance to the west of the proposal and

would not be obscured or detracted from. For the reasons established under

the Strategic Views section, officers disagree with the view of Historic England

and conclude that the proposal would also not cause harm to those wider

riparian views from the Thames and its embankment, Waterloo, Hungerford or

Westminster Bridge. Overall, it is considered that setting element threes

contribution would be preserved.

481. Overall, it is considered the proposal would preserve the setting, character and

appearance and heritage significance of the Strand Conservation Area.

Whitefriars Conservation Area

Heritage Significance:

482. The heritage significance of Whitefriars Conservation Area is covered in detail

in the Character Summary and Management Strategy SPD (2016), which is a

material consideration. It summarises its significance as stemming from:

• An impressive collection of consistently high quality late Victorian/Edwardian

commercial and institutional buildings on land reclaimed and

comprehensively planned by the Corporation resulting in a more regular grid

plan, a rare more formal townscape in a City context, in contrast to the more

organic, evolutionary Fleet Street environs which it abuts.

• The setting of grand Victorian urban infrastructural, engineering and urban

planning interventions, namely Blackfriars Bridge, Victoria Embankment and

New Bridge Street.

• An important wider context to the Temples and as foreground to St Paul’s

Cathedral from sensitive riparian views.

• A varied assortment of land uses including the former Whitefriars friary

precincts, domestic tenements, industrial works and commercial HQs, in

addition to a historic association with the press and newspaper production.

483. The Conservation Area is of a high level of local and even national

architectural, artistic, historical and archaeological significance, drawn

principally from the built form and fabric of the Conservation Area and its

archaeology, and to a lesser but significant degree via setting.

Contribution of Setting:

484. Elements of setting make a substantial contribution to significance, manifesting

principally in views across and through the Conservation Area from the River,

its embankments and bridges. The main contribution derives from the following

in descending order of contribution:

• Strategic pan-London riparian views from Hungerford and Waterloo Bridges

and from the South Bank Queen’s Walk comprising open river prospects

across the City skyline. These make a significant contribution to architectural

and historic significance, in particular and an appreciation of it.

• Views from the immediate environs of the Temples and Fleet Street

Conservation Areas, in particular from the Victorian Embankment and south

from Fleet Street towards the River which allow for a more enriched

appreciation of a wider historic setting. These make a moderate contribution

to significance and an appreciation of it.

Impact:

485. The Conservation Area comprises land due south of the proposal, sharing no

direct visual interaction from inside the Conservation Area. The proposal would

not be visible in any identified view in the Conservation Area SPD.

486. The proposal would appear in the near wider setting as part of an established

backdrop to the Conservation Area from broad riparian river prospects from

the South Bank Queen’s Walk. From here Whitefriars and the adjoining

Temples Conservation Area command the foreground setting and scale of an

open prospect across the River. Their respective pre-eminent skylines would

be preserved on the whole. Many of the buildings that line the southern

boundary of the Whitefriars Conservation Area fronting the river, are grade II

listed and form a dignified group: Hamilton House; Telephone House; No.9

Carmelite Street; Sion Hall; City of London School; and Unilever House. While

of different periods and styles, each building contributes to a richly textured

townscape, with a distinctive roofscape, which gives this boundary of the

Conservation area its distinguished character and appearance. Where

glimpses of the development would be visible beyond the river front buildings,

the tiered massing and vertically articulated façade would be unobtrusive,

ensuring their pre-eminence within this setting would be unchallenged. Overall,

officer consider that the proposal would successfully integrate into the

established secondary layer of townscape which has emerged to the north of

Fleet Street, and that it would be experienced as a subservient element beyond

the riverfront buildings, and the background of the Conservation Area.

487. From Hungerford and Waterloo bridges, the proposal would assimilate with

that mediation of scale between the Embankment and those taller skyline

structures on raised land to the north of Fleet Street and would not dilute or

overwhelm the Conservation Area in the foreground. As such, setting element

1, wider riparian views, would be preserved.

488. In terms of setting element 2, both views south of Fleet Street, and along the

embankment would be undiluted given the density of intervening development,

and the close grain of the urban fabric which would restrict any views to the

proposed development. As such, it is considered setting element 2 would be

preserved.

489. Overall, the proposal would preserve the setting and character, appearance

and significance of the Whitefriars Conservation Area.

Other Designated Heritage Assets

490. In accordance with paragraph 200 of the NPPF, the assessment of heritage

impact has been extensively scoped, using digital modelling software to

identify heritage receptors through a zone of theoretical visibility. The impact

on these receptors was then checked in a 3D model as part of a desk-based

assessment and accurately detailed with verified photography and site visits

to illustrate the extent of visual influence (field evaluation).

491. As a result of this methodology, potential impacts of the proposal on the

settings of the above heritage assets have been identified and assessed.

492. In respect of other heritage assets, officers have scoped an extensive number.

The definition of setting is the extent to which an asset is ‘experienced,’ which

is not geographically set and can change over time, relating to more than just

a direct visual influence. Given the dense central London location, the site is

within the setting of an enormous number of heritage assets, and it would be

disproportionate to assess them all.

493. In particular, it is considered that the following were found to have no visual

relationship with the proposal and therefore were scoped out of the

assessment:

• Temple Church - Grade I

• Middle Temple Hall – Grade I

• Church of St Sepulchre – Grade I

• Church of St Martin Ludgate - Grade I

• Church of St Andrew by the Wardrobe – Grade I

• The Daily Express building – Grade II*

• Caretakers Lodge – Grade II

• 6 Bolt Court – Grade II

• 146 Fleet Street – Grade II

• Ye Olde Cheshire Cheese PH - Grade II

• 143 and 144 Fleet Street - Grade II

• The Daily Telegraph Building - Grade II

• Mersey House - Grade II

• 8 Red Lion Court – Grade II

• 5 and 6 Crane Court – Grade II

• Middle Temple Gardens Registered Park and Garden (RPG) – Grade II

Conclusion on Heritage:

494. The proposals would preserve the significance (via change in the setting) of

heritage assets and an appreciation of it. As such, they would accord with

Local Plan policies CS12 and DM12.1, emerging City Plan 2040 policies S11

and HE1, London Plan policy HC1, having accounted for and paying special

regard to s.66 (1) of the Planning (Listed Buildings and Conservation Areas)

Act 1990 and the relevant NPPF policies.

Archaeology

495. The City of London is considered an archaeologically sensitive area in its

entirety. In accordance with the City of London Local Plan 2015, all of the City

is considered to have archaeological potential, except where there is evidence

that archaeological remains have been lost due to deep basement construction

or other groundworks.

496. NPPF section 16 and the London Plan (2021 Policy HC1) make the

conservation of archaeological interest a material planning consideration.

497. An Archaeological desk-based assessment was submitted by the applicant.

The Greater London Archaeological Advisory Service (GLAAS) and the City

Archaeology Trust were consulted. The latter confirmed no comments.

498. The assessment concludes that, although the site ties within an area where

Roman remains have been found, only a low potential for post-medieval

remains is now present on the site. This is due to the presence of a double

basement across the majority of the site which would have removed all

archaeological remains of interest.

499. GLAAS responded to confirm that the works are unlikely to have a significant

effect on heritage assets of archaeological interest. GLAAS stated that the

assessment did not include an assessment of the impact on potential

archaeology of the public realm particularly Gunpowder Square however, the

public realm impacts are limited to tree pits and new services and

archaeological remains of interest are likely to be located c 1.5m below ground

level and therefore it is unlikely that the new development would have an

impact on significant archaeology. GLAAS confirmed no further assessment is

necessary and a condition has been recommended.

Public Access and Inclusivity

500. Developments should be designed and managed to provide for the access

needs of all communities, including the particular needs of disabled people as

required by policies CS10, DM10.1, DM10.5 and DM10.8 of the Local Plan,

policies S1 and S8 of the draft City Plan 2040 and policy D5 of the London

Plan. In particular, policy DM10.8 requires to achieve an environment that

meets the highest standards of accessibility and inclusive design in all

development (both new and refurbished), open spaces and streets.

501. Local Plan policy DM 10.8 requires “to achieve an environment that meets the

highest standards of accessibility and inclusive design in all developments

(both new and refurbished)”. A service provider also has an anticipatory duty

under the Act.

502. An access statement has been provided with the application, in addition to an

Equality Statement and Statement of Community Involvement.

503. The application is accompanied by an Access Strategy submitted as part of

the Design and Access Statement. The proposals were subject to review by

City of London Access Group (CoLAG).

504. London Plan policy D5 says that development should be ‘convenient and

welcoming with no disabling barriers, providing independent access without

additional undue effort, separation or special treatment’. The access

statement details points of entry, landings, door types, level thresholds and

the need for manifestation.

505. Consideration has been given to the points of arrival at the site and the main

office entrance amended following comments. An Access Management Plan

(AMP) to for visitors and building users on points of arrival and entrances would

be required and would be secured by condition.

506. Arrival at the site has been considered for a number of travel options. Inclusive

Mobility table 3.7 sets out the recommended limits for walking distance without

a rest and it is noted that a number of the points of arrival exceed these. It is

therefore welcome that an additional two blue badge spaces are proposed

near to entrances. Continuing provision of the three existing Blue Badge

spaces in the area during construction is important and it is recommended that

details are reserved of how this continuous provision will be secured.

507. The provision of places to store mobility scooters is welcome in principle and

should include charging points. Further details of this could be included within

an AMP.

508. The City Walkway provides an opportunity to cross the site at present but does

not have rest points and is not a welcoming, or intuitive route.

509. Wayfinding is of particular significance, including for the relocation of the library

and loss of familiarity which is particularly important for some people with

information &/or sensory processing differences (PAS 5.3.1, 5.4). However, it

is considered that the library entrance will be relocated but will be much more

prominent and legible in the public realm, than the existing, which is welcomed.

510. Pedestrian approaches to the various points of entry accommodate significant

changes in level, and have been the subject of discussion through the design

process. The significant level changes to be accommodated and wayfinding

and legibility needs to be given the highest priority both around, and across

the site. It is recommended that the wayfinding strategy tests scenarios from

points of arrival for a range of people, following the principle of at least ‘two

senses’ (BS 8300 (1) 5.2.3). Principal entrance points, in particular, need to be

clearly legible and it is noted that totems may not be accessible to all people.

This additional consideration of wayfinding for disabled people could form part

of details reserved for wayfinding and signage.

511. Materials throughout the development will be of great importance and this will

need particular consideration for circulation and reception areas, to avoid the

potential for sensory overload from acoustic or visual stimulus (PAS 6463),

details to be secured by condition.

512. The proposals for the Gunpowder Square public realm will include a mix of

both open and more intimate spaces, and maintain 2m pedestrian comfort

levels, which is welcomed. There have been discussions through the design

process regarding the use of contrasting strips within the hard landscaping

which are set counter to intuitive routes. There are concerns about the potential

to perceive these strips as barriers or holes (PAS 6463 note 7 and 12.6).

Barriers to the beds are currently shown as open at the bottom and of variable

height – these should be consistent with AD K and detectable by people with

visual impairments. Details to be secured through condition.

513. Reception and lobby areas to both office and library space incorporate

‘bleacher’ seating. Space should be made to integrate wheelchair spaces

within the body of the seating and this is referenced as the intention for the

library. It should remain central to further stages of design development. Hand

and grab rails should also be provided. This should be provided through

condition details.

514. Reception facilities should be consistent with AD M(2): 3.6 and BS 8300 8.6.2

Routes from the entrance/lobbies should be logical, clearly defined and

unobstructed, with adequate and sufficient circulation space. Reception area

desks should be positioned away from the entrance to minimise noise, with

lowered counter sections, appropriate hearing enhancement systems and the

surface of the reception area should be slip resistant. Details should be

provided through condition.

515. London Plan D5, (B)5 states ‘in all developments where lifts are installed, as a

minimum, at least one lift per core (or more subject to capacity assessments)

should be a suitably sized fire evacuation lift suitable to be used to evacuate

people who require level access from the building’. 6.2.1 further states that

there should be an evacuation lift in addition to fire-fighting lifts. Proposals and

the access statement confirm that all lifts will be more than 1100x1400mm with

appropriately sized landings and back-up lifts are identified across the site in

case of failure. The lift size is not sufficient for users of larger mobility vehicles

and alternative provision should be identified through the AMP, particularly for

library visitors. It is recommended that details of lifts are reserved.

516. It is regrettable that visitors to the library will have to use stairs or a lift to access

many primary functions at mezzanine level as this separates people who need

step-free access and there is potential for queuing at busy times. The AMP

should identify how events will be managed to avoid this happening, and

maintenance for the platform lift to mezzanine level would be secured in the

Section 106.

517. Many platform lifts are not accessible for people with dexterity impairments or

who suffer from fatigue. BS8300 3.22 discourages them other than in

‘exceptional’ circumstances. New generation platform lifts which do not require

continuous pressure are currently proposed and which are more consistent

with standard passenger lift operations. The scheme would not be considered

inclusive without such provision. Therefore details for lifts have been

recommended by condition.

518. There are marked level changes across site and there are areas where ramps

are proposed instead of slopes. However, these will be consistent with AD M(2)

3.53 and AD(K)2.

519. Corridor widths and door openings are confirmed as consistent with AD M(2),

including sufficient door widths and passing places for wheelchairs and will be

subject to detailed design development.

520. Accessible WC (AWC) provision is otherwise provided for the various

functions. There are unisex cubicles only proposed on upper floors although

the government proposal for separate male and female toilets and public

buildings is noted. Ambulant unisex facilities are also included. The absence

of enlarged facilities is regrettable as these are useful to disabled people who

may need a larger space or have bags. Concerns were raised regarding the

distance to AWCs from the entrances although it is noted in the access

statement that there is no more than 40m travel distance, as consistent with

AD M(2) 5.10.h.

Cycle Provision

521. Cycle entrance for the building is via Wine Office Court. Cycle provision will be

consistent with the 5% of larger spaces recommended by London Plan Policy

T5B and London Cycling Design Standards 8.2.1. There are accessible

facilities proposed to support cyclists. Controlled entry points should be

sufficiently wide to accommodate larger bikes and be consistent with guidance

in BS 8300(1) 7.11 and BS 8300(2) 8.3/8.5.3

Changing Places

522. A Changing Places toilet was agreed during development of the proposals and

which will support the public functions of the library and help make it more

accessible to more people. There are few Changing Places facilities within the

City at present and, although not available on a 24 hour basis, this is a key

element of making the scheme more inclusive. Management and operation

should be covered in the AMP and would be secured via Section 106

obligation.

Public realm works

523. Where seating is proposed arm supports should be provided to give options

for left, or right hand side support, as well as options for seating with back

support. The areas of landscape have the potential to offer places for rest and

recovery, consistent with guidance in PAS 6463: Design for the Mind. Details

would be secured through condition.

Gym facilities

524. BS8300 2: 20.8.4 says that ‘Disabled people should have the same access to

all fitness and exercise areas, and types of equipment, as non disabled people’

and this should inform the provision of gym equipment/facilities. Details to be

provided in the AMP through recommended condition.

Public Access and Inclusivity Conclusion

525. Further design details and an Access Management Plan are proposed to be

secured via condition.

526. Overall, and subject to the imposition of conditions, the proposal would accord

with the access policies outlined above.

Highways and Transportation

Public Transport

527. The site has the highest level of public transport provision with a public

transport accessibility level (PTAL) of 6B. There are several stations within

walking distance: City Thameslink (260m), Chancery Lane (500m), Blackfriars

(500m), Farringdon (600m), St Pauls (640m) and Temple (730m). Together

these stations give access to a wide selection of London Underground (LU)

and National Rail services. These stations provide good connection to

destinations across all London.

528. The bus stops located on Farringdon Street, Holborn Viaduct, and Fleet Street

provide access to 10 routes. These stops would provide good access for uses

to travel to / from the site via bus as part of a primary or ‘final leg’ journey.

529. Cycleway 6 (C6) runs approximately 150m east of the site along Farringdon

Street and the site is located close to 4 cycle hire docking stations. The site is

therefore well located to encourage cycling to / from the site.

Trip generation

530. Within the Transport Assessment (TA) a trip generation forecast has been

conducted for the site which identifies the net change in trips that would result

from the proposed development. The assessment has used TRICS travel data

from similar land uses within Greater London.

531. The trip generation assessment considers the AM and PM peak hours but does

not consider the MID peak hour. The trip generation assessment identifies that

the proposed development as a whole would generate 976 trips during the AM

peak (8:00-9:00) and 1,156 trips during the PM peak (17:00-18:00). When

considered against the existing site and associated trip generation (also

calculated via TRICS), this is an increase of +635 trips during the AM peak

and +786 trips during the PM peak.

532. The restaurant trip rates rely on a singular TRICS site owing to a lack of

representative sites within the TRICS database. It is acknowledged that this

limitation is unavoidable, and the trip rates applied are accepted. No downward

adjustment of ‘linked trips’ commonly associated with retail uses has been

made and is therefore considered a robust approach.

533. The mode shares presented for the site would appear to underestimate the

likely mode share for cyclists (4.1% for office and 1.9% for retail). Whilst this

low cycle mode share is not agreed, it is insignificant when considered against

the assessments of other modes, as a lower cycle mode share would inflate

all other modes proportionally and therefore represents a ‘worst-case’

assessment for these other modes (footways / public transport).

534. Given the accessibility of the site in relation to local public transport services

and when considering the projected mode share of trips, it is considered that

this additional level of activity could be absorbed by the existing Transport

network, subject to appropriate mitigation and improvements to local footway

conditions.

Public Footpath, Public Realm Alteration and Access

535. Local Plan Policy DM 16.2 states that: “The loss of a pedestrian route will

normally only be permitted where an alternative public pedestrian route of at

least an equivalent standard is provided having regard to:

• the extent to which the route provides for current and all reasonably

foreseeable future demands placed upon it, including at peak periods;

• the shortest practicable routes between relevant points.

536. The proposal will result in the loss of City Walkway through the site. However,

as noted elsewhere within this report, the existing route through the building is

of limited benefit, it begins and terminates mid-block and does not logically

follow the pedestrian desire lines. The existing route is also of limited quality,

with a lack of overlooking (natural passive surveillance) and lighting, which

makes the current route unattractive.

537. To offset the loss in principle of this functional route, enhancements to

Gunpowder Square have been proposed, to create much-improved public

realm park, subject to S278 Agreement, along the key pedestrian desire line

between New Street Square and Fleet Street. It is considered by officers that

this trade-off is acceptable.

538. The outline of the building is proposed to change as part of this application and

a Pedestrian Comfort Level (PCL) assessment has been undertaken to assess

the forecasted impacts of the proposals on pedestrian comfort in cognition of

the proposed public realm improvements. The PCL assessment refers to a

previous 2022 study undertaken by Momentum, which investigated the

pedestrian impacts of the proposed amendment of the existing City Walkway.

This previous study identified that there would be no discernible impact on

pedestrian comfort levels as a result of the proposals, with comfort levels

ranging from B to A+.

539. The proposed development is forecasted to generate an uplift of 2,962 two-

way daily trips beyond the levels originally forecasted by the 2022 study

(4,317); equivalent to an increase of 69%.

540. The 2022 study identified that the lunchtime peak period was the busiest period

on the surrounding streets. The applicant has undertaken an updated PCL

assessment of this lunchtime period as part of the TA. The footways assessed

and considered most relevant are those surrounding the Site and include Little

New Street (south footway), Shoe Lane (west footway), and Printer Street

(east footway) where the new entrances are located for the library and gym /

auditorium space. Wine Office Court was not assessed in these updated

scenario tests as it was recognised within the 2022 study as having a comfort

level of A+ in both existing and future scenarios.

541. The results presented by the applicant indicate that there is anticipated to be

no change in the pedestrian comfort level of the assessed footways along Little

New Street (comfort level of ‘A’) and Shoe Lane (comfort level ‘A-‘). There will

be a slight reduction in the pedestrian comfort level for Printer Street from an

‘A’ to an ‘A-‘, which is considered immaterial and is still within an acceptable

and comfortable range. However Officers consider that footways should be

considered in more detail as part of the proposed Section 278 works including

updated pedestrian counts should be undertaken.

542. The results of the PCL assessment should be considered in addition to the

more holistic public realm design improvements that would be delivered by the

scheme. The removal of the existing City Walkway, in combination with the

public realm and landscape strategy of the proposed development, will result

in a positive and beneficial impact on pedestrians and users of the space,

which would also include users not directly associated with the proposed

development.

Car Parking

543. The proposed development will be car-free and the existing car parking area

converted to create space for cycle parking. As a result, all vehicle trips

generated by the development will be associated with delivery and servicing

or disabled drivers.

Disabled Car Parking

544. Allocated space within the site has not at this point been made for the provision

of disabled motor vehicle parking. It is acknowledged that local disabled

parking is available on the local highway as mentioned in the submitted

Transport Assessment. There is one existing disabled parking space located

to the front of the site on Little New Street. It is proposed by the applicant that

two further disabled parking spaces could be provided on Little New Street,

adjacent to the existing bay. The applicant has also committed to providing

these spaces with Electric Vehicle charging capabilities. Officers consider this

acceptable and the final provisions would be subject to the S278 process and

agreed through discussions at the relevant time with CoL Highways.

Servicing

545. It is proposed to provide an on-site service yard at the south-eastern corner of

the site, with access from Shoe Lane. The service yard would be provided at-

grade and has been designed to provide space for simultaneous delivery

activity within 2 loading bays. Sufficient manoeuvring space is provided to

enable entry and exit from the servicing yard in forward gear by vehicles

including a 7.5 T Box Van, the CoL 7.5 m refuse vehicles and a 10m electric

refuse vehicle, which form part of the existing waste management teams’

vehicle fleet (as demonstrated by the Swept Path Analysis provided).

546. This is a significant improvement from the existing site provision, whereby

larger vehicles have insufficient space to enter and exit the site in forward gear

(resulting in reversing manoeuvres from the highway).

547. It is forecasted by the applicant that the development would generate a

demand of 103-104 deliveries per day, which would be an increase in

deliveries to the site of 68-69 deliveries per day. Of these 104 servicing trips,

it is estimated that approximately 96 would be associated with the office

element, 6 would be associated with the retail element, and 2 would be

associated with the library / gym uses.

548. To mitigate the impacts associated with the forecasted servicing demand, the

applicant has committed to consolidate deliveries. A consolidation reduction

factor of 50% has been applied, which would result in 49 deliveries per day (or

a net increase of 14 trips when compared to the existing scenario). It is worth

noting that this moderate increase in servicing trips would be off-set by the

removal of the existing car park.

549. The Applicant commits to restricting servicing activity between the peak

network hours of 07:00-10:00, 12:00-14:00 and 16:00-19:00. On the basis of

deliveries being undertaken during daytime hours only (i.e. 05:00-07:00,

10:00-12:00, 14:00-16:00 and 19:00-22:00), there would be 9 servicing hours

across the day. Applying a vehicle dwell time assumption of 20 minutes per

delivery, the two loading bays provided have a theoretical capacity for 54

deliveries by vehicles per day. This theoretical servicing capacity does not

however include for cargo bike deliveries, which would be permitted to occur

within the restricted peak periods and would serve to provide additional

servicing capacity.

550. The applicant commits to the production of a detailed Delivery and Servicing

Plan (DSP) to be secured by condition / obligation. The detailed DSP will set

in place the specific management tools that would be employed by Facilities

Management to ensure servicing is suitably managed to ensure no

unnecessary on-street servicing occurs. The DSP also presents the

opportunity to promote and action consolidation at the development, as well

as promoting green servicing options such as last mile cargo cycle logistics,

and electric servicing vehicle use.

551. The development with the production of a detailed DSP meet London Plan

policy T4 and Local Plan Policy 16.1 requirements and are considered

acceptable.

Cycle Parking

552. London Plan Policy T5 (Cycling) requires cycle parking be provided at least in

accordance with the minimum requirements set out within the plan. Policy T5

(Cycling) requires cycle parking to be designed and laid out in accordance with

the guidance contained in the London Cycling Design Standards and that

developments should cater for larger cycles, including adapted cycles for

disabled people.

553. The proposed development will deliver a minimum of 750 long-stay cycle

parking spaces at basement 2 level, accessible from a wide staircase with

cycle channels enabling two-way movement, as well as suitably sized lifts. This

meets London Plan standards. The cycle provision will comprise:

• 5% Accessible cycle parking spaces;

• 3% Sheffield stand spaces;

• 10% Folding cycle lockers; and

• 82% Two-tier cycle stands.

554. The proposals will deliver 113 short-stay cycle parking spaces as a minimum,

meeting London Plan standards, as well as the reprovision of the existing 24

cycle parking spaces located on Wine Office Court. The short-stay cycle

parking will be provided both internally within the building and externally to

complement the existing provision on Wine Office Court. The internal short-

stay cycle parking comprises 50 spaces at upper ground floor level for use by

visitors, which offers a sheltered, secure and managed facility. The 50 internal

short-stay spaces will be divided between 16 Sheffield stand spaces and 34

two-tier stand spaces. The remaining additional external short stay spaces

would total 63.

555. The applicant commits to the production of a full Travel Plan (to be secured by

condition / obligation) which would encourage the uptake of cycling as a mode

of travel to / from the site.

Travel Plans

556. The City is an extremely busy area, and this development would lead to a large

increase in numbers traveling to and from the site with an expected uplift in

jobs of over 2,000 people.

557. In this instance we would seek to mitigate the impact on this development by

requesting a Workplace Travel Plan be put in place, this will not be required to

cover the gym / library areas of the site as the proposals for these elements

do not meet the thresholds to be required. Travel Plans are an effective tool

for managing visitors, volunteers and employees at a site by helping to

promote sustainable transport and raising awareness of their benefits.

558. If planning permission is granted a Workplace Travel Plan would need to be

secured as a section 106 planning obligation in order to meet London Plan

policy T4 and Local Plan Policy 16.1. The travel plan would need to be

approved by the CoL prior to completion of the proposed works. This would

include a requirement for a Travel Plan Co-ordinator to be appointed no less

than 3 months before occupation.

559. Transport for London encourages applicants to use the TRICS database for

trip generation predictions. We will require the applicant to undertake a TRICS

after study and provide TfL and the CoL with the results on completion of the

development. We will seek to secure the necessary after surveys and results

by Section 106 agreement as part of the Travel Plan review and monitoring

process.

Management of Construction Impacts on the Public Highway in the local area

560. The applicant has submitted an Outline Construction Logistics Plan (CLP)

which indicates that the construction programme would last for approximately

45 months with an indicative start date of February 2026. It is envisaged by

the applicant that a temporary loading bay pit lane arrangement will be

provided on Little New Street adjacent to the Site to enable construction works.

561. It is noted that the Principal Contractor for the proposals has not yet been

appointed and so all information provided in the outline documents is indicative

in nature (as is common practice for outline planning documents).

562. No vehicle movement forecasts are provided by the applicant at this stage. It

is however expected that the proposals would generate a significant amount

of demolition and construction traffic owing to the works required. As a result,

the proposed works could have a significant impact on the operation of the

public highway in the local area if the impacts are not managed effectively. The

primary concern is public safety it must be ensured that construction traffic

does not create (or add to existing) traffic congestion or impact on the road

safety or amenity of other highway users. The proposal is also likely to lead to

a variety of amenity issues for local people (e.g. noise, vibration, air quality).

563. A preliminary Construction Logistic Plan (CLP) has been submitted in support

of the planning application. This provides useful information to describe the

proposed works and how they would be undertaken. It also provides useful

information to describe how the impacts associated with the construction

period would be mitigated. It lacks detail but is a good example of what is

required at this stage in the process. A more detailed CLP should be prepared

once a Principal Contractor has been appointed, which will need to be in line

with Transport for London’s Construction Logistics Plan Guidance.

564. This should consider the following points:

• Construction vehicle routes to and from the site will need to make the most

efficient use of the highway network in the Central London Area. Such

routes will require discussion with CoL Highways.

• The proposed works are likely to generate a significant amount of workers

on the site at any given time. It would be expected that the Principal

Contractor to prepare travel planning guidance to encourage workers to

use sustainable transport instead of private motor vehicles.

• Various highways licences would need to be obtained from the CoL prior

to works commencing on site (e.g. temporary parking bay suspensions,

scaffolding licence, hoarding licence, crane licence etc).

• Traffic congestion is already a significant problem in the CoL, particularly

during morning and afternoon/evening peak periods, therefore it is

expected construction vehicle movements to be scheduled to avoid 0800

to 0930 and 1600 to 1830 hours on Monday to Friday.

• Details will be required to describe how pedestrian and cyclist safety will

be maintained, including any proposed alternative routes (if necessary),

and any Banksman arrangements.

• The site would be registered with the Considerate Constructors

Scheme. It would be expected for the proposed works to be undertaken

in accordance with the best practice guidelines in TfL’s Standard for

Construction Logistics and Cyclist Safety (CLOCS) scheme.

565. The CoL needs to ensure that the development can be implemented without

being detrimental to amenity or the safe and efficient operation of the highway

network in the local area. Therefore, if planning permission is granted a CLP

should be secured via condition to ensure the construction and demolition of

the site is in accordance with The London Plan Policy T7 and DM16.1 of the

Local Plan. This would provide a mechanism to manage / mitigate the impacts

which the proposed development would have on the local area. The CLP

would need to be approved by the CoL prior to works commencing on site.

Highways Boundary

566. Alterations to the highways boundary have not been identified at this stage.

567. The applicant identifies proposed Hostile Vehicle Mitigations measures on the

public highway however it is questioned whether these are required on security

grounds. The principle of obstructing the highway is resisted unless can be

justified and would be considered further as part of a Section 278 Agreement.

Over Sailing and Basement Alterations

568. Undersailing and oversailing of structures has not been identified at this stage

and therefore it is assumed that there are no requirements for the introduction

of (or changes to) any under / over sailing licenses.

S278 Agreement

569. All works on the public highway shall be undertaken by the City’s Term

Contractor.

570. The applicant is required to enter into a Section 278/38 Agreement of the

Highways Act 1980, prior to the occupation of the site for the following works,

but not limited to:

• Repaving of all the adjacent footways in Little New Street, Pinter Street,

Gunpowder Square, Wine Office Court and Shoe Lane

• Resurfacing of the carriageways at the locations

• Reinstatement of Road Markings

• Installation of all the public realm works within the public highway, as per

the planning approval, including, implementation of landscaping, trees,

planters, planting, seating, relocation of the existing cannon in Gunpowder

Square, installation of public art and any other associated works

• Improvements to drainage

• Improvements to lighting

• Improvements to safety per ATZ observations received for the application

• Removal of bollards

• Further analysis for footways as part of the proposed Section 278 works

including updated pedestrian counts should be undertaken.

571. The applicant has proposed planters with balustrade to accommodate the

changes in levels between Shoe Lane and Wine Office Court. The details of

its construction will be addressed during the detailed design of the S278 project

and subject to feasibility.

572. The implementation of the additional disabled bays is subject to public

consultation.

573. The applicant is required to submit the details of the threshold levels at the

highways boundaries, prior to the commencement of construction works.

574. The applicant is required to submit a condition survey of the adjacent highways

prior to the commencement of any construction works.

575. Any part of the proposed development requiring works to the public highway

following construction works will be secured through planning to repair any

damage to transport infrastructure, landscaping and to reinstate all affected

transport network links, road and footway surfaces.

576. Should planning permission be granted the following S106 planning

obligations and conditions, along with a S278/38 which would need to be

secured:

• A condition to secure a Construction Logistic Plan (CLP). The Section 106

agreement shall state that the CLP shall be approved prior to any works

starting on site and the approved plan shall be followed, unless otherwise

agreed with the Highway Authority. It should also restrict HGV movement

to and from the site to with in the hours of 9:30 to 16:30 Monday to Friday,

8 till 13:00 Saturdays and fully restrict movement on Sundays and Bank

Holidays unless agreed with the CoL in advance.

• A Section 106 planning obligation to secure a Workplace Travel Plan (TP)

for the development. The Section 106 agreement shall state that the TP

shall be approved prior to the first occupation of the site and the approved

plan shall be followed, unless otherwise agreed with the Highway

Authority. The Section 106 agreement shall require the applicant to

undertake a TRICs after survey and to provide TfL and CoL with a copy of

the results as part of the travel plan review and monitoring process.

• A S278/38 to secure a financial contribution to cover the cost of public

highway and public realm improvement works in the general vicinity of the

site. These works would include but are not limited to enhancements to

the public highway around the site on Little New Street, Pinter Street,

Gunpowder Square, Wine Office Court and Shoe Lane.

• A condition requiring the provision of 750 long stay cycle parking spaces,

113 short stay cycle parking for the entire development, designed to

London Cycle Design Standards and the ongoing retention of these

facilities, details of which will need to be submitted and approved, and

approval should be reserved by condition.

• A Section 106 planning obligation to secure a Delivery and Servicing Plan

(DSP). The Section 106 agreement shall state that the DSP shall be

approved prior to the first occupation of the site and the approved plan

shall be followed, unless otherwise agreed with the Highway Authority. A

daily servicing vehicle cap should be applied to the proposals, limiting the

daily maximum to 49 vehicles.

Response to TfL Comments

577. Many of the comments offered by TfL have been addressed within this report.

For clarity, the key items are discussed further below.

578. Concerns raised by TfL regarding the trip generation methodology adopted are

not agreed for the following reasons:

• The majority of retail has been accounted for in full (823sqm) and just

320sqm of office / retail / café has been ‘excluded’. On the basis that this

equates to more than 50% of the total potential retail provision, it is

considered that this approach adequately captures the trip generation of the

proposed retail, given that a significant portion will, in reality, form ‘linked’ or

‘pass-by’ trips.

• It is agreed that trips to the gym would largely be linked or pass-by trips as

part of existing network trips (or linked to the proposed office use).

• The library use would be a (reduced) replacement of an existing use.

579. The applicant has committed to providing EV charging capabilities for the on-

street disabled bays proposed.

580. The cycle parking proposals algin with London Plan requirements and LCDS

compliant cycle parking would be secured by condition.

581. A financial contribution towards cycle hire facilities is considered a reasonable

request and should be discussed as part of the Section 106.

582. Conditions would be secured linked to comments made with respect to the

DSP, CLP, and Cycle Promotion Plan.

Transport conclusion

583. The proposals are acceptable in transport terms subject to the necessary

conditions and obligations as discussed above along with a S278/38

agreements.

Environmental Impact of Proposals on Surrounding Area

584. Local Plan policy DM10.1 requires the design of development and materials

used should ensure that unacceptable wind impacts at street level and in the

public realm be avoided, and to avoid intrusive solar glare effects and to

minimise light pollution. Policy 10.7 is to resist development which will

noticeably reduce daylight and sunlight to nearby dwellings and open spaces.

Draft City Plan 2040 Strategic Policy S8 and Policy DE2 requires development

to optimise microclimatic conditions addressing solar glare, daylight and

sunlight, wind conditions and thermal comfort.

Daylight, Sunlight and Overshadowing

585. Policy D6(d) of the London Plan states that the design of development should

provide sufficient daylight and sunlight to surrounding housing that is

appropriate for its context.

586. Local Plan Policy DM10.7 ‘Daylight and Sunlight’ seeks to resist development

which would reduce noticeably the daylight and sunlight available to nearby

dwellings and open spaces to unacceptable levels, taking account of the

Building Research Establishment (BRE) guidelines.

587. Draft City Plan Policy DE7 states that development proposals will be required

to demonstrate that the daylight and sunlight available to nearby dwellings and

open spaces is appropriate for its context and provides acceptable living

standards taking account of the Building Research Establishment’s guidelines.

588. Paragraph 3.10.41 of the Local Plan indicates that BRE guidelines will be

applied consistent with BRE advice that ideal daylight and sunlight conditions

may not be practicable in densely developed city centre locations. Policy HS3

of the Draft City Plan states when considering on the amenity of existing

residents, the Corporation will take into account the cumulative effect of

development proposals.

589. Local Plan Strategic Policy CS10 seeks to ensure that buildings are

appropriate to the character of the City and the setting and amenities of

surrounding buildings and spaces.

590. The BRE guidelines “Site layout planning for daylight and sunlight - A guide to

good practice” (2022) present the following methodologies for measuring the

impact of development on the daylight and sunlight received by nearby existing

dwellings and any existing non-domestic buildings where the occupants have

a reasonable expectation of natural light:

• Daylight: Impacts to daylight are measured using the Vertical Sky

Component (VSC) method: a measure of the amount of sky visible from

a centre point of a window; and the No Sky Line (NSL) method, which

measures the distribution of daylight within a room. The BRE advises that

this measurement should be used to assess daylight within living rooms,

dining rooms and kitchens; bedrooms should also be analysed although

they are considered less important. The BRE Guide states that diffuse

daylighting of an existing building may be adversely affected if either the

VSC measure or the daylight distribution (NSL) measure is not satisfied.

• Sunlight: Impacts to sunlight are measured using Annual Probable

Sunlight Hours (APSH) for all main living rooms in dwellings if they have

a window facing within 90 degrees of due south. The guidelines consider

kitchens and bedrooms to be less important, but that care should be

taken to not block too much sun from these rooms.

Interpreting results

591. In undertaking assessments, a judgement can be made as to the level of

impact on affected windows and rooms. Where there is proportionately a less

than 20% change (in VSC, NSL or APSH) the effect is judged as to not be

noticeable. Between 20-30% it is judged to be minor adverse, 30-40%

moderate adverse and over 40% major adverse. All these figures will be

impacted by factors such as existing levels of daylight and sunlight and on-site

conditions. It is for the Local Planning Authority to decide whether any losses

result in a reduction in amenity which would or would not be acceptable.

592. A Daylight, Sunlight and Overshadowing Assessment has been submitted to

consider the potential effect on the daylight and sunlight amenity within existing

neighbouring residential properties, as well as overshadowing to relevant

existing neighbouring amenity space. These assessments have been

undertaken in accordance with the BRE Guidelines (2022).

593. An independent review was undertaken by GIA consultants.

594. The potential daylight and sunlight impacts have been assessed on the

following existing neighbouring properties;

• Pemberton House (residential);

• Dr Johnson’s House, 17 Gough Square (museum);

• 16 St Johnson’s Court (The Curator’s Cottage) (residential);

• 7 Wine Office Court (residential);

• 3 Wine Office Court (residential);

• 2 Wine Office Court (residential);

• 1-23 Bolt Court (residential); and

• 148 Fleet Street (residential).

595. Included within the existing baseline condition are two neighbouring sites

(currently under construction) to the east of the Site at Stonecutters Court (ref:

18/00878/FULMAJ) and 120 Fleet Street (ref: 21/00538/FULEIA) therefore this

baseline condition provides the ‘worst-case’ in terms of the baseline levels of

light received by the key properties being assessed.

596. The following properties fully meet BRE criteria for daylight and sunlight

assessment:

• Dr Johnson’s House - 17 Gough Square;

• 16 Johnsons Court(The Curator’s Cottage);

• 3 Wine Office Court;

• 2 Wine Office Court; and

• 148 Fleet Street.

597. Therefore the results for Pemberton House, 7 Wine Office Court and 1-23 Bolt

Court are discussed further below.

598. A further Climate Based Daylight Modelling (CBDM) was undertaken for

Pemberton House.

599. Daylight has been assessed for both Vertical Sky Component (VSC) and No

Sky Line (NSL), these are complementary assessments for daylight: VSC is

the measure of daylight hitting a window, NSL assesses the proportion of a

room in which the sky can be seen from the working plane. Daylighting will be

adversely affected if either the VSC of the NSL guidelines are not met.

600. The BRE criteria state that a window may be adversely affected if the VSC

measured at the centre of a window is less than 27% and less than 0.8 times

its former value (i.e. experiences a 20% or more reduction.) In terms of NSL,

a room may be adversely affected if the daylight distribution (NSL) is reduced

beyond 0.8 times its existing area (20% or more reduction).

Pemberton House

601. This residential building is located immediately to the west of the Site, and

separated only by Gunpowder Square. City records show 39 properties at this

address.

602. Of the 163 windows assessed serving 89 rooms, the majority of windows (94)

would meet BRE criteria when assessed against the VSC daylight

methodology, and the 69 windows that would not meet criteria which would

comprise:

• The majority of windows would experience minor impacts with a total of 34

windows experiencing a VSC alteration between 20.1% - 30%,

• A total of 24 windows would experience more moderate alterations

between 30.1% - 40%,

• The remaining 11 windows would experience major VSC alterations in

excess of 40%.

603. Of the 35 windows experiencing moderate and major impacts, 16 windows

appear to serve bedrooms, which are recognised as having a lower

requirement for light compared to other uses. The BRE Guidelines note that

“… bedrooms should also be analysed although they are less important”. In

addition, half of these rooms are served by three windows each therefore are

considered to receive additional light.

604. The 19 windows remaining experiencing moderate to major impacts, these

appear to serve nine living spaces, all of which are multi-glazed (aside from

one kitchen) having two or three windows and therefore are considered to

receive additional light. In addition, of these nine living spaces, five experience

moderate impacts to windows with two of these rooms served by windows with

minor impacts. Although these 19 living spaces are not BRE-compliant, this is

already the case in the existing condition due to the surrounding levels of

existing obstruction. In addition, the absolute changes in the VSCs recorded

for these living room windows are considered small (between c. 1.5%-6%, avg.

3%), which translate into high percentage changes due to the low existing

values. This applies for all the windows which do not comply with BRE, as the

absolute alterations would be considered to be small (between c. 1% and 6%,

avg. 2.6%).

605. For NSL, 69 of the 89 (78%) rooms meet criteria for this assessment, and for

the 20 rooms which did not meet BRE, these comprise:

• Nine rooms would experience NSL alterations between 20.1%-29.9%

• Four rooms would experience alterations between 30.1%-39.9%

• The remaining seven rooms experience NSL alterations in excess of 40%

however four of these consist of bedrooms which are considered less

sensitive for the assessment.

606. The east elevation of Pemberton House has a very narrow separation distance

from the Site, therefore it is considered that any significant development on

Site would result in greater impacts to daylight and many windows have low

daylight levels in the existing scenarios. However, it is noted in the assessment

that the apartments served by the windows in this façade are all dual-aspect.

607. The CBDM results demonstrate that many of the single-aspect habitable

rooms within Pemberton House were already below the suggested lux target

for their respective uses in the existing scenario. Therefore it is considered that

there is unlikely to be a material change in quality of light within the rooms.

608. Pemberton House is the only neighbouring property that has windows

orientated within 90⁰ due south of the Site and relevant for sunlight

assessment. A total of 61 out of 65 (94%) windows meeting BRE criteria for

annual sunlight. The four affected windows have low existing annual sunlight

levels between 6%-7% (against a BRE target value of 25%) which are further

reduced to between 0%-1%. The impacted windows serve rooms that are

multi-aspect.

609. All windows assessed will meet BRE criteria for winter sunlight.

610. Considering the impacts against the contextual factors summarised above, the

impacts to and retained levels of daylight and sunlight are commensurate of

what would be experienced within a dense urban environment.

7 Wine Office Court

611. A residential property directly to the south-west of the Site. City records show

six properties at this address.

612. A total of 21 windows have been assessed against the VSC daylight

methodology, 17 of which will meet BRE criteria for this assessment (81%).

The four windows, affecting three rooms, experience minor VSC alterations

between 20.1%-30%. All four windows have low existing VSC levels between

2.57% and 3.12% (against a BRE target value of 27%) with that absolute VSC

value reducing no more than 1% in the proposed scenario. In addition, two of

the three rooms are served by two windows therefore considered to receive

additional light, with one of these other windows as BRE compliant.

613. For NSL, one room on the fourth floor will experience a minor NSL alteration

of 23.98% (against a BRE target value of 20%). The remaining three rooms

located on basement level (identified as a bedroom), third floor and fourth floor

experience more moderate NSL alterations between 32.32% and 34.92%.

However it is considered that the rooms have low existing NSL values between

6.3% and 14.7% which are reduced to between 4.1% and 9.8% in the

proposed scenario.

614. There are no windows within 7 Wine Office Court that face within 90⁰ due south

of the development site relevant for sunlight assessment.

615. Therefore, given that the impacted windows and rooms have low existing

levels of daylight and alterations are considered disproportionate to the actual

impact, the impacts are considered acceptable.

1-12 Bolt Court

616. All windows meet BRE criteria for VSC. One room falls short of guidance for

NSL, experiencing a minor alteration of 24.49% (against a BRE target value of

20%) however it is noted that the windows for the VSC are BRE compliant for

this room.

617. The affected window serving this space is setback within eaves of the roof,

therefore blinkered by the projection of the roof all along one side which would

limit the available light.

618. There are no windows within 1-23 Bolt Court that face within 90⁰ due south of

the development site relevant for sunlight assessment.

619. Given that all of the windows assessed against the VSC daylight methodology

fully meet BRE criteria and one room experiences a minor alteration to NSL,

the impacts are considered acceptable.

Overshadowing

620. Overshadowing of amenity spaces is measured using sunlight hours on the

ground (SHOG). The BRE guidelines recommends that the availability of

sunlight should be checked for open spaces including residential gardens and

public amenity spaces.

621. The assessment considers seven separate amenity areas to the west of the

Site in the existing scenario. The assessment shows that sunlight received will

satisfy the BRE guidance for all existing amenity areas considered. Therefore

these spaces experience no change in the proposed scenario. Therefore the

potential effect on overshadowing from the proposed development is

considered acceptable.

Daylight, sunlight and overshadowing conclusion

622. With regard to impacts on daylight and sunlight to nearby residential