LSC.07

Planning Statement

Lewisham Shopping Centre and Adjacent Land, Lewisham

Landsec Lewisham

Limited

18TH OCTOBER 2024 Q200103

Table

Table

Table

Table

Table

Appendix

Appendix

Appendix

Appendis

Appendix

1 Introduction

1.1 This Planning Statement has been prepared by Quod on behalf of Landsec Lewisham Limited (‘Landsec’) (‘the Applicant’) in support of a hybrid planning application, part detailed and part outline (the ‘Application’), submitted to the London Borough of Lewisham (‘the Council’) for the comprehensive redevelopment of Lewisham Shopping Centre and adjacent land (‘the Site’).

1.2 Landsec is involved in unlocking some of the most technically complex regeneration sites at the heart of communities across London and England. Its goal is to reconnect these sites with the local community and transform them into places where people want to live, work and spend time.

1.3 Landsec’s vision is to implement development plan policy, to create a new town centre for Lewisham and a new neighbourhood through a contemporary mixed-use development that is entirely compatible with the unique historical nature of the Site, taking inspiration from local businesses and the community.

1.4 This will be delivered through a viable strategy and is in accordance with the government’s policy to ‘get Britain building’. In particular, the application accords with the following government planning policy statements:-

- “Delivering economic growth is the number one mission as we face the most acute housing crisis in living memory.

- The government’s radical plan is not only to get the homes we desperately need but to also drive the growth, create jobs and breathe life back into our towns and cities.

- Our cities and towns are at the heart of modern Britain. They are the engine rooms of our economy, fantastic places to live and work, and vibrant destinations for leisure and tourism.

- Sustained ‘turbocharged’ economic growth is the only route to improving the prosperity of our country and the living standards of working people

- If we have targets that tell us how many homes we need to build, we next need to make sure we are building in the right places. The first port of call for development should be brownfield land, being explicit in policy that the default answer to brownfield development is yes.

- Given our relatively low densities, there is scope in many areas for increases. While such increases should take account of local character, existing character should not be used to block sensible changes which make the most of an area’s potential, and which can create sustainable, well-designed and productive places to live and work.

- There is not only a professional responsibility but a moral obligation to see more homes built, there is no time to waste, it is time to get on with building 1.5 million homes”

1.5 Lewisham Town Centre is the heart of the Borough. Since its opening in 1977 Lewisham Shopping Centre has been its major shopping and leisure destination. Its design, as a self-

contained, car orientated ‘island’ reflects the period that it opened. However there is an opportunity for the centre to play a far greater role in a modern, integrated town centre, with a transformed environment and wider range of uses.

1.6 This will support the Government’s objectives to “get Britain building again, to build new homes, create jobs, and deliver new and improved infrastructure”, the Mayor of London’s emerging Growth Plan including a focus on the foundational economy and town centres, and Lewisham Council’s long term investment and vision for the Town Centre to be “restored as the heart of South East London” including planned investment in the market and a Cultural and Business Hub in the current library.

1.7 The site is part of Lewisham’s ‘Central Growth Corridor’, a designated ‘Town Centre’ and an ‘Opportunity Area’. Intensifying the use of such scarce brownfield land, by having shops, services and active uses at ground floor level with residential space above, is absolutely critical to ensuring its economic success, at the same time providing much-needed new homes. This is all the more important given London’s significantly increased housing target and the ‘brownfield first’ approach. It is one of the key locations for investment which can bring new homes, jobs and economic activity to Lewisham and its residents.

1.8 Landsec will create a place which brings together the Site’s natural environment and unique past with new buildings and public realm of the highest quality whilst retaining those buildings of intrinsic quality, and those that can be viably reused

1.9 These proposals come at a time when the Government, has called for Britain to get building. Delivering economic growth is the number one mission for our country, and the planning system is central to achieving this This is an opportunity for Lewisham Town Centre to play its part, securing its own economic growth for the borough and beyond.

1.10 Landsec and its project team has worked closely and collaboratively with the Council, the Greater London Authority (‘GLA’) and other key stakeholders and the community over the last four years to develop the application proposals submitted for planning approval within the Application.

1.11 Together, the economic effects of this application, and the transformation they represent, will help Lewisham town centre grow to be an exemplary integrated town centre of Metropolitan significance. It will preserve the great character of the area and existing assets such as the market; it will build on improvements and developments the council has already overseen; it will integrate and connect communities, facilities, and transport; and it will invigorate the town centre with high quality public realm, greater quality and variety of town centre uses including leisure, and enable more people to live in the heart of Lewisham.

1.12 Delivery of this mixed-use development will bring with it a wide range of public benefits as each phase comes forward and brings new residents, workers and visitors to the area. This is a significant opportunity for the London Borough of Lewisham, the Lewisham community, as well as London more widely.

1.13 The Applicant seeks hybrid planning permission (part detailed and part outline) for the following development (the ‘Proposed Development’) at the Site:

Hybrid planning application for the comprehensive, phased redevelopment of land at Lewisham Shopping Centre and adjacent land, comprising:

Full planning application (within Phase 1a) comprising the demolition of existing buildings, structures and associated works to provide a mixed-use development including the erection of a Co-Living building (Sui Generis) up to 23 storeys in height (Plot N1), and a residential building (Class C3) up to 15 storeys in height (Plot N2), associated residential ancillary spaces as well as town centre uses (Class E (a, b, c, d, e, f, g (i, ii)); and Sui Generis) together with public open space, public realm, amenity space and landscaping, car and cycle parking, highway works and the formation of new pedestrian and vehicle accesses, existing shopping centre interface works (the ‘Phase 1a Finish Works’), service deck modifications, servicing arrangements, site preparation works, supporting infrastructure works and other associated works.

Outline planning application (all matters reserved) for a comprehensive, phased redevelopment, comprising demolition of existing buildings, structures and associated works to provide a mixed-use development including:

▪ The following uses:

▪ Living Uses, comprising residential (Class C3) and student accommodation (Sui Generis);

▪ Town Centre Uses (Class E (a, b, c, d, e, f, g (i, ii)) and Sui Generis);

▪ Community and Cultural uses (Class F1; F2; and Sui Generis);

▪ Public open space, public realm, amenity space and landscaping works;

▪ Car and cycle parking;

▪ Highway works;

▪ Formation of new pedestrian and vehicular accesses, permanent and temporary vehicular access ramps, service deck, servicing arrangements and means of access and circulation within the site;

▪ Site preparation works;

▪ Supporting infrastructure works;

▪ Associated interim works;

▪ Meanwhile and interim uses; and

▪ Other associated works.

1.14 The Proposed Development is explained further in Sections 9 and 10 of this Planning Statement.

1.15 The Application is a phased development. Phase 1a includes the Detailed component of the planning application as well as outline components, whilst Phases 1b, 2a, 2b, and 3a and 3b are applied for in outline.

1.16 The Application is an Environmental Impact Assessment application for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017

1.17 The Application is also referred to the GLA as an application of Potential Strategic Importance (PSI) in line with the development triggers set out in the Mayor of London Order 2008

1.18 This Planning Statement covers the principal planning considerations raised by the Proposed Development and matters raised by the Council, the GLA, the Council’s independent Design Review Panel (‘DRP’), local groups and the community as well as other key stakeholders including Transport for London (‘TfL’) during the pre-application process.

1.19 It is considered that the Application is supported by national, regional and local planning policy and is in accordance with Section 38(6) of the Planning and Compulsory Purchase Act 2004 The Proposed Development is in accordance with the Development Plan and planning permission should be granted. In addition, the Proposed Development will deliver a number of significant public benefits.

1.20 The tilted balance, presumption in favour of sustainable development also applies in Lewisham because the Council cannot currently demonstrate a five year housing land supply, and the Housing Delivery Test results require it. Planning permission should therefore be granted without delay.

1.21 The Proposed Development complies with the National Planning Policy Framework (“the Framework”) as a whole, and specifically against polices set out within the following sections Section 5: Housing; Section 6: Building a strong and competitive economy; Section 7: Ensuring the vitality of town centres; Section 8: Promoting healthy and safe communities; Section 9: Promoting sustainable transport; Section 11: Making effective use of land; Section 12: Achieving well-designed places; Section 14: Meeting the challenge of climate change; and Section 16: Conserving and enhancing the historic environment

1.22 This Planning Statement is structured as follows:

▪ Section 2 – Planning Application Documentation – confirms the full suite of documentation and their authors;

▪ Section 3 – Government Planning Reforms – summarises recent Government statements and proposed policy changes to deliver economic growth;

▪ Section 4 – Landsec’s Vision – explains the Applicant’s company aspirations and detailed vision for the future of its asset, Lewisham Shopping Centre;

▪ Section 5 – The Site & Surrounding Area – includes a description of the Site, surrounding area and relevant planning history;

▪ Section 6 – The Development Plan and Comprehensive Development – sets out a summary of the Development Plan and its requirements for a comprehensive approach to development;

▪ Section 7 – The Proposed Development - Summary – summarises the headline elements of the Application;

▪ Section 8 – The Planning Application Structure – summarises the approach and structure of the Application, including the approach to phasing and interim works;

▪ Section 9 – The Proposed Development, Detailed Component – sets out the elements of the Proposed Development which are being applied for in detail;

▪ Section 10 – The Proposed Development, Outline Component – sets out the elements of the Proposed Development which are being applied for in outline;

▪ Section 11 – Pre-Application Engagement – describes the extensive pre-application engagement carried out including details of community engagement, pre-application meetings with the Council, the GLA and other key stakeholders including TfL, as well as DRP;

▪ Section 12 –Town Centre First Approach – sets out the non-residential uses proposed and considers this in the context of the planning policy requirements for the Site;

▪ Section 13 – Economic Development – confirms the numerous number of employment opportunities that will be delivered as a result of the Proposed Development;

▪ Section 14 – C3 Housing – assesses relevant housing policies which seek to boost the supply of housing, the need for housing and the contribution of the Proposed Development, as well as policies relating to affordable housing and housing mix;

▪ Section 15 – Co-Living – assesses the proposed Co-Living use against the relevant policy context;

▪ Section 16 – Student Accommodation – assesses the proposed purposed built student accommodation against the relevant policy context;

▪ Section 17 – A Well-Designed Place – considers the compliance of the Application with regards to the principal policies on design and placemaking;

▪ Section 18 – Detailed Component Assessment – assesses Buildings N1 and N2 against key planning policies and supporting guidance;

▪ Section 19 – The Re-Use of Buildings – considers the options for demolition against the London Plan requirements for whole life carbon and circular economy policies;

▪ Section 20 – Environmental Planning Considerations – considers other key planning considerations regarding transport, energy and sustainability, heritage, flood risk, microclimate, daylight and sunlight, air quality, and noise;

▪ Section 21 – Planning Obligations and Community Infrastructure Levy – provides a summary of the main legislation, policy and guidance relating to planning obligations and Community Infrastructure Levy;

▪ Section 22 - Public Benefits and The Planning Balance – considers the key planning benefits of the Application and their relevance when applying a planning judgement to the acceptability of the Application; and

▪ Section 23 – Conclusions – conclusions are drawn.

2 Planning Application Documentation

2.1 This section lists the documentation that comprises the hybrid planning application. This Planning Statement is to be read alongside the planning application documents.

Reference

Document

Author

LSC.01 Application Form Quod

LSC.02 Community Infrastructure Levy Form Quod

LSC.03 Application Drawings

LSC.03.A Application Drawings Volume 1 - Existing/Demolition Plans SEW, Mae, Archio

LSC.03.B Application Drawings Volume 2 - Parameter Plans SEW

LSC.03.C Application Drawings Volume 3 - Masterplan Drawings for approval SEW

LSC.03.D Application Drawings Volume 4 - Masterplan Drawings for Information SEW

LSC.03.E Application Drawings Volume 5 - Highways Plans SLR

LSC.03.F Application Drawings Volume 6 - Phase 1a Finish Works Plans SEW

LSC.03.G Application Drawings Volume 7 - Landscape Drawings SEW

LSC.03.H Application Drawings Volume 8 - Plot N1 Drawings Mae

LSC.03.I Application Drawings Volume 9 - Plot N2 Drawings Archio

LSC.04 Drawing Schedule SEW

LSC.05 Design Code SEW

LSC.06 Development Specification Quod

LSC.07 Planning Statement Quod

LSC.08 Design and Access Statement

LSC.08A Volume 1 - Masterplan SEW

LSC.08B Volume 2 - Plot N1 Mae

LSC.08C Volume 3 - Plot N2 Archio

LSC.08D Volume 4 Appendices

Appendix 1 Access Statement David Bonnett Associates

Appendix 2 Lighting Assessment WSP

Appendix 3 Fire Statement Jensen Hughes

Appendix 4 Ventilation Approach WSP

LSC.09 Vol 1 Environmental Statement Volume 1 - Main Report Plowman Craven

LSC.09 Vol 2 Environmental Statement Volume 2 Townscape, Heritage and Visual Impact Assessment Montagu Evans

LSC.09 Vol 3 Environmental Statement Volume 3 - Technical Appendices Plowman Craven

SEE SEPARATE ES TAB FOR INDIVIDUAL CHAPTERS

LSC.10 Environmental Statement Non Technical Summary Plowman Craven

LSC.11 Housing Statement Quod

LSC.12 Financial Viability Assessment Quod

LSC.13 Transport Assessment SLR

Appendix 1 Construction Method Statement/Logistics Plan and Environmental Management Plan (including site waste SLR / RPM

Reference

Document

Author management plan and Structural Survey/Demolition Statement)

Appendix 2 Delivery & Servicing Plan SLR

Appendix 3 Car Parking Management Plan SLR

LSC.14 Framework Travel Plan SLR

LSC.15 Statement of Community Involvement Something Collective

LSC.16 Sustainability Statement and Breeam Pre-assessment Bioregional

LSC.17 Circular Economy Statement Bioregional

LSC.18 Whole Life Carbon Assessment Bioregional

LSC.19 Energy Strategy and Overheating Statement WSP

LSC.20 Internal Daylight and Overshadowing Report Point 2

LSC.21 Operational Waste Management Strategy SLR

LSC.22 Economic Growth Statement Quod

LSC.23 Flood Risk Assessment Expedition

Appendix 1 Sustainable Drainage Strategy Expedition

LSC.24 Foul Sewerage and Utilities Assessment WSP

LSC.25 Tree Survey/Arboricultural Assessment Plowman Craven

LSC.26 Health Impact Assessment Quod

LSC.27 Equality Impact Assessment Quod

LSC.28 Built Heritage Statement Montagu Evans

LSC.29 Town Centre Assessment Study Quod

LSC.30 River Impact Assessment Expedition

LSC.31 Co-living Operational Management Strategy Urban Bubble

3 A New Policy Context - Government Planning Reforms

Introduction

3.1 The Prime Minister, the Ministry of Housing, Communities & Local Government (‘MHCLG’) and the Deputy Prime Minister and Secretary of State for Housing, Communities and Local Government have all recently and collectively called for Britain to get building. Delivering economic growth is the number one mission for our country.

3.2 We summarise the policy statements below to ensure that decision makers have the most up to date policies to hand when determining planning applications.

3.3 There is a significant weight of expectation to boost housing output now, to optimise brownfield land and get on with building 1.5 million homes.

Planning reform

3.4 The King’s Speech and briefing papers, delivered on 17th July 2024, set out the Government’s intent to get Britain building, andto accelerate thedelivery of high-quality housing. It recognises that “the current planning regime acts as a major brake on economic growth” and that more housing that communities need must be unlocked as an enabler of growth, “how not if” homes are to be built1 .

3.5 Angela Rayner made a statement to the House of Commons on the 30th July 20242 as Deputy Leader and Secretary of State for Housing, Communities and Local Government

3.6 The Secretary of State’s statement set out the government’s plan to get Britain building, confirming that ‘delivering economic growth is our number one mission’, setting out ‘a radical plan to not only get the homes we desperately need but to also drive the growth, create jobs and breathe life back into our towns and cities’

3.7 The Secretary of State confirmed that ‘we’re facing the most acute housing crisis in living memory; 150,000 children in temporary accommodation; nearly 1.3 million households on social housing waiting lists; under 30s less than half as likely to own their own home, compared to in the 1990s; and total homelessness at record levels’.

3.8 The Secretary of State explained the national increase in housing delivery making it clear that the government will intervene where there is persistent failure to deliver new homes.

1 The King’s Speech Briefing Papers 2024

2 Secretary of State statement to the House of Commons, 30th July 2024

3.9 The Secretary of State also issued a ministerial statement ‘Building the homes we need’3 to address the issues that we face, setting out the following policy objectives:-

▪ ‘Sustained economic growth is the only route to improving the prosperity of our country and the living standards of working people’.

▪ ‘Nowhere is decisive reform needed more urgently than in housing’.

▪ ‘We are in the middle of the most acute housing crisis in living memory. Home ownership is out of reach for too many; the shortage of houses drives high rents; and too many are left without access to a safe and secure home’.

▪ ‘Reforms to fix the foundations of our housing and planning system – taking the tough choices needed to improve affordability, turbocharge growth and build the 1.5 million homes we have committed to deliver over the next five years’.

▪ ‘Updating the standard method and raising the overall level of these targets – from around 300,000 to approximately 370,000’.

▪ ‘If we have targets that tell us how many homes we need to build, we next need to make sure we are building in the right places. The first port of call for development should be brownfield land, and we are proposing some changes today to support more brownfield development: being explicit in policy that the default answer to brownfield development should be yes’.

▪ ‘There is no time to waste. It is time to get on with building 1.5 million homes’.

3.10 On the same day, the Secretary of State wrote4 to all local authority leaders and chief executives in England confirming the following:-

▪ As the Prime Minister explained on the steps of Downing Street, ‘the government’s work is urgent, and in few areas is that urgency starker than in housing’

▪ ‘As a nation we find ourselves in a dire situation given the depth of the housing situation’.

▪ Examples of this crisis are record numbers of homeless children placed in temporary accommodation; waiting lists for social housing; and lack of affordability of home ownership

▪ ‘There is not only a professional responsibility but a moral obligation to see more homes built’.

3.11 Most recently the Government has issued a policy paper on ‘Brownfield Passport: Making the Most of Urban Land’5 This paper includes important government policy statements which we summarise below.

▪ Our cities and towns are at the heart of modern Britain. They are the engine rooms of our economy, fantastic places to live and work, and vibrant destinations for leisure and tourism.

3 Ministerial Statement Building the homes we need, 30th July 2024

4 Secretary of State letter to all local authority leaders and chief executives in England, 30th July 2024

5 Policy paper Brownfield Passport: Making the Most of Urban Land, 27 September 2024

▪ The government wants to see our cities and towns flourish, which means making sure there are enough homes to support further growth – and that these homes are affordable.

▪ The government wants our urban centres to grow in a way which delivers long-term prosperity, with sustainable patterns of development, meaning that homes are close to jobs, and take advantage of places with good connectivity.

▪ Sustained economic growth is this government’s most important mission because it is the only route to improving the prosperity of our country and the living standards of working people.

▪ The government has been clear that the first port of call for development should be brownfield land.

▪ It is with these goals in mind that the government has proposed some immediate changes to national planning policy, including being explicit that the development of brownfield land should be regarded as acceptable in principle.

▪ Making the most of urban brownfield land through the planning system matters for multiple reasons. The government wants to deliver the homes and other development the country needs in a way that draws as much as possible on existing infrastructure and access to jobs. And it is clear that many parts of our cities and towns could be put to better use: transforming derelict sites that are a blot on communities into valued parts of the urban fabric, and pursuing higher density, well-designed development in suitable and sustainable locations. This makes sense not just for social and environmental reasons, but for economic ones too, given that bigger cities drive greater productivity.

▪ Many of our urban areas have been developed at a relatively low density, especially compared with cities and towns in parts of continental Europe; no square kilometre in England has more than 25,000 inhabitants, when cities such as Barcelona and Paris have more than double that. This can have important downsides, limiting the population catchment for shops and other local services, as well as constraining economic potential by acting as a barrier to jobs and labour.

▪ Given our relatively low densities, there is scope in many areas for increases. While such increases should take account of local character, existing character should not be used to block sensible changes which make the most of an area’s potential, and which can create sustainable, well-designed and productive places to live and work.

3.12 The Secretary of State’s statement to the House of Commons and written correspondence demonstrate a clear direction of travel of the Government.

Reforms to the Framework

Sustainable Development

3.13 The existing Framework sets out the Government’s planning policies for England and how these should be applied. As a material consideration the Framework is given the greatest weight and should be read as a whole6

6 Framework para 3

3.14 The Framework confirms that the purpose of the planning system is to contribute to the achievement of sustainable development, including supporting infrastructure and the provision of homes. The objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs. Achieving sustainable development means that three overarching aims are achieved interdependently through improving the economic, social and environmental conditions of the area7. Securing these objectives delivers public benefits which significantly weigh in favour of permitting new development.

3.15 The Framework recognises that the provision of new homes is an integral part of sustainable development and establishes a presumption in favour of it at its heart so that it is pursued in a positive way, granting planning permission without delay. Decision makers at every level are expected to approve applications for sustainable development where possible8

3.16 The Framework has been revised and consulted on, to deliver the Government’s policy to get Britain building. The updated Framework is expected to be published either at the end of 2024, or start of 2025.

Brownfield Land

3.17 The Government’s clearly stated policy is to prioritise brownfield land. Section 11 (Making efficient use of land) has been strengthened in respect of brownfield first principes, applying substantial weight as they are “acceptable in principle” policy.

Decisions should: give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, proposals for which should be regarded as acceptable in principle, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land.

3.18 These proposals will therefore carry significant weight in the planning balance and are acceptable in principle.

Housing

3.19 The Secretary of State has set out an increase in national housing delivery from 300,000 homes per year, to 370,000 homes per year.

3.20 The importance of providing sufficient housing is manifest within the Framework, especially on brownfield land where there is an identified shortage of land to meet existing and future housing needs.

3.21 The reform reinstates the requirement to demonstrate a 5-year housing supply. The Government proposes to delete the exemptions introduced by the previous Government which advised that housing numbers were advisory starting points; local authorities did not need to

7 Framework para 8 and 38

8 Framework para 38

plan for density uplifts where they would be out of character; and that local need should be met ‘as far as possible’

3.22 There are however significant challenges that remain.

London

3.23 MHCLG recognise that “More important than setting a deeply ambitious but credible target is of course meeting it”9. For the proposed reforms to be deliverable and effective, the disconnect between identifying “economic needs” and “delivery” of development to meet those needs will be addressed. This is particularly important in London.

3.24 As part of the reforms, MHCLG have recently stated the following:-

The Government is clear that recent delivery in London has fallen well short of what is needed, and that is why we are committed to working in partnership with the Mayor of London and the GLA to turn this around - including by optimising density and through Green Belt review10

3.25 It must not be forgotten that the Panel of Inspectors who examined the current London Plan in 2019 criticised the approach then taken in deriving housing targets for London and individual boroughs.

3.26 The London Plan Panel Inspectors reported11 that the London Plan failed to meet “by some margin” the identified annual need of 66,000 homes in London. The Panel reported that because housing targets were so far below the assessed need this was a “major concern”12 As a result, the Panel considered “whether we should determine that it does not meet the tests of soundness and so should be withdrawn”. Despite these concerns, the Panel recognised the negative effects of delaying adoption. The Panel therefore urged boroughs “to use all the tools at their disposal”13 to ensure that homes are built.

3.27 For many reasons, this has simply not happened including macro and micro development economics, mechanistic controls applied by development plans and guidance, the impact of design standards and regulatory controls, and the complexity of bringing forward a reducing pool of development sites leaving complex sites which already have viable existing uses on them.

3.28 There is now however an obligation for all housing proposals on brownfield land in sustainable locations to do more, to be optimised and respond to the direction from the Government.

3.29 The Government has therefore introduced a new standard method for housing need which is a material consideration for any planning application, albeit there are local plan review transitional arrangements in the longer term.

9 MCLG Our plan to get Britain Building Again, 5th August 2024

10 MHCLG Press, 31st July 2024

11 London Plan Inspector Report to the Mayor of London, October 2019, paragraph 175

12 Paragraph 177

13 Paragraph 178

3.30 In London, there is a proposed increase for the London Plan from c.54,000 homes capacity per annum (albeit derived from an actual need of 66,000 homes14) to 80,693 homes per annum which the government considers is deliverable.

3.31 Put into context, London has only delivered an average of 38,000 homes per annum in the three years to 2022/23 (67% of the minimum required), and this is expected to reduce further with updated data. To date, in 2024, only 9,000 homes have been ‘approved’ at Stage 2 of the GLA referral process, therefore the delivery figures are expected to get much worse.

3.32 For Lewisham, the government’s new assessment results in an annual housing increase from 1,667 homes per annum to 2,470 homes per annum (Table 4.1, London Plan), an increase of 803 homes every year.

3.33 To reinforce Government expectations, the Secretary of State has now written to the Mayor of London15 identifying the following key objectives: -

▪ The new Standard Method produces an ambitious but deliverable figure for London of nearly 81,000 homes.

▪ To achieve it, output in the capital will have to increase markedly from the current average of 37,200 homes per year (2019 to 2023).

▪ The government does expect London to take steps to boost its output

3.34 The Secretary of State’s statement to the House of Commons and written ministerial and policy objections are material considerations which carry great weight. They should be applied now alongside a step change in the delivery of homes to deliver economic growth and get Britain building.

4 Landsec’s Vision

Landsec

4.1 Landsec is a market leader in optimising, reimagining and growing development in London and the UK. Its retail business is significant and extensive. Landsec is also the market leader in retail innovation and adaptation. It has been at the forefront of meeting and forecasting retail shopping needs for many years. Landsec recognises that reshaping the size and mix of its retail footprint enables the reimagining of historic retail models such as the 45 year-old shopping centre at Lewisham. By reinventing the retail model into something new, fit for the next 40 years and beyond, Landsec can maintain the vitality and viability of Lewisham Town Centre.

4.2 Landsec’s portfolio is diverse and comprises a mix of offices, homes, retail, and cultural spaces. For instance, Landsec has transformed Victoria into a vibrant new destination through developments such as Nova and The Zig Zag Building. Elsewhere, Landsec’s work at muchloved shopping centres such as Westgate Oxford, Bluewater in Kent, Trinity Leeds and St David’s in Cardiff has established Landsec as the partner of choice for retailers and local authorities.

4.3 Landsec aims to lead in critical long-term issues – from diversity and community employment to carbon reduction and climate resilience. Landsec is committed to becoming a net zero carbon business by 2030 and is currently on site with the UK’s first net zero carbon commercial building in London.

4.4 Landsec is passionate about driving positive change for people, communities and society as a whole. Rethinking the future of Lewisham Shopping Centre presents a significant opportunity to contribute to the long-term wellbeing of local people by thinking carefully about jobs, skills, business, health, and the environment, creating and implementing social value.

Town centre diversification

4.5 Landsec supports the Council’s ambition for growth and renewal across the borough and within Lewisham Major Town Centre, the principal town centre. As the owner of Lewisham Shopping Centre which, alongside third-party land, comprises the principal site allocation (LCA 2) and development opportunity for Lewisham Town Centre, it is best placed to bring forward the comprehensive development of the Site.

4.6 During 2020 Landsec undertook a detailed review of its Urban Regeneration portfolio in response to structural change nationally in the retail sector. Town centres and the way we shop have been rapidly changing due to the growth of online shopping.

4.7 The retail sector is going through its biggest upheaval since the 2008 financial crash which instigated structural change well before the global pandemic. COVID-19 has accelerated the change The Arcadia Group (Topshop, Dorothy Perkins, Burton and Miss Selfridge); Debenhams; Monsoon; Aldo; Antler; Oasis and Warehouse; Debenhams; Cath Kidston; Laura

Ashley; and Peacocks are just a few established high street retailers who have gone into administration and left the high street.

4.8 How town centres, including Lewisham, are used by local people and retailers will now change forever. Landsec’s assessment included its landholdings in Lewisham and included a feasibility study to rethink the future of the 45-year-old shopping centre.

4.9 Landsec engaged various stakeholders who responded with an overriding desire for change –the community wanted a cleaner, safer town centre with a redesigned shopping centre, and more pedestrian areas with a greater mix of uses including those that would support a nighttime economy. Lewisham Council and the GLA both agreed that the comprehensive redevelopment of the shopping centre will be central to achieving the vision and objectives for Lewisham town centre. Both fully support the principle of development in this context

4.10 Town centres and the way we shop have been rapidly changing due to the growth of online shopping. Reinvention will not detract from Landsec’s ambition to secure a vibrant and vital future for Lewisham. This ambition will have to be achieved in a new and innovative way, supported by a flexible development plan and planning application. Landsec’s new vision seeks to balance several strategic planning issues such as long term vacant floorspace; demand for new commercial floorspace; economic regeneration; development economics; housing need; design and climate change.

4.11 Landsec’s vision is the sustainable and mixed-use transformation of the shopping centre to reintegrate the place within its surrounding fabric, weaving the old and the new to create a layered living neighbourhood above a vibrant and high performing commercial hub. To secure Lewisham’s future, healthy living and flexible working will come together around a diverse leisure and retail offer that caters to all. New connecting opportunities will enable the Site to open and bring nature in. The place-shaping process has been inclusive and informed by public engagement to build upon what already makes the place special, and ensure the place grows organically over time.

4.12 The Lewisham Local Plan promotes comprehensive wholesale redevelopment of the shopping centre and adjacent land, designating the Site for 2,150 homes and 60,291sqm of town centre floorspace Landsec propose to deliver this policy ambition with this planning application.

4.13 With retailers consolidating their portfolios to reduce store numbers as the growth of online shopping continues to rise, combined with weakening consumer confidence, and increases in business rates, there is an estimated >25% oversupply of retail space in the UK

4.14 Vacant retail space, such as that which exists across Lewisham town centre at present, has significant socioeconomic consequences for communities. Urban areas with high vacancy rates may lead to lower footfall and therefore lower retail sales. This can be uninviting to new retailers and investors who are less likely to invest in new spaces such as offices, homes, leisure and retail facilities. This downward cycle can have further social repercussions if it then impacts employment and local economic stimulation. This is particularly relevant for Lewisham Shopping Centre where there is significant vacant floorspace (20,708sqm) as well as within the town centre overall.

4.15 New developments need to reflect new trends and behaviours, such as the need to work flexibly or to have a net positive environmental impact. These connected communities should include residential, medical, leisure and entertainment facilities, as the net requirement for existing retail space declines.

4.16 The creation of well-designed, thoughtful and aspirational mixed-use developments can empower communities to reconnect, through the spaces and places provided and through a real sense of ownership and purpose. The process of repurposing retail space in Lewisham will undoubtedly deliver a product – be it town centre living or social space – which will provide the Lewisham community with amenities which are valuable, needed and useful.

4.17 Landsec’s vision is based upon the foundations set by national planning, the London Plan and the Lewisham Local Plan which support adaptation and diversification of town centres to respond to the anticipated needs. By taking a positive approach to growth, management and adaptation, town centres are expected to grow and diversify in a way that can respond to rapid changes in retail and leisure needs allowing a suitable mix of uses including housing. It is recognised that residential development plays an important role in ensuring the vitality and viability of our town centres.

4.18 The London Plan allocates New Cross/Lewisham/Catford as an opportunity area for 13,500 homes and 4,000 jobs. It recognises that Lewisham will grow in function and population and has the potential to become a town centre of Metropolitan importance. Public realm and environmental enhancements of the town centre are proposed to assist the continued transformation of Lewisham into a ‘high performing’ and ‘vibrant’ retail hub with excellent leisure services.

4.19 Lewisham was the London Borough of Culture for 2022, delivering a year-long programme of activities that placed culture at the heart of its communities. To celebrate, the borough curated a year of arts, cultural events and activities. The borough is home to a number of arts and cultural organisations, of which many are based in the town centre. Landsec have drawn inspiration from these programmes and promote a significant cultural component as part of their proposals.

4.20 Lewisham is a diverse borough with residents who have stories from around the world, Landsec want to make the town centre a place where this diversity is celebrated. In addition, Landsec is committed to strengthening Lewisham’s evening economy by providing opportunities to create a more active town centre later in the day.

4.21 These principles have been applied to this planning application.

Lewisham Shopping Centre

4.22 Lewisham Shopping Centre has been at the heart of the town centre for 45 years and is in need of renewal. It was opened in 1977 as the Riverdale Centre, the largest building in Lewisham Town Centre. Over the years, whilst Landsec has maintained the centre shopping to a high standard, the inward facing shopping mall has suffered from a lack of permeability, changing shopping patterns and a deterioration of the external building fabric around the shopping mall. In particular long term vacant floorspace at Lewisham House, Riverdale Hall and the Leisure Box has affected the vitality and viability of the town centre as a whole.

The Vision

4.23 Landsec’s vision for Lewisham Shopping Centre is set out below:

Located as the heart of Lewisham Town Centre, the sustainable and mixed-use transformation of Lewisham Shopping Centre will re-integrate the place within its surrounding fabric, weaving the old and the new to create a layered living neighbourhood above a high performing and vibrant commercial centre.

To secure Lewisham’s future, healthy living and flexible working will come together around a diverse leisure and retail offer that caters for all.

Increased opportunities for new connections will open the site up to bring the nature in. The place-shaping process will be inclusive and informed by public engagement to build upon what already makes the place special, and ensure the place grows organically over time.

4.24 This vision draws on the need for structural change in our town centres to maintain and enhance vital and viable town centres; the views of those consulted since 2020; and the clear policy direction set out in the local plan, London Plan and national planning policy.

4.25 To create a finer context to this vision, Landsec has created seven place ‘pillars’. These are explained further below.

Rooted

4.26 Landsec propose to respect the Site’s history and ground any proposal in its vibrant community. Where practical, feasible and viable buildings/facades are retained which have architectural character. Landsec has liaised with Lewisham Council, Lewisham Market, and its traders to discuss, how as a neighbour, any future development can enhance its operation. Landsec is proposing meanwhile uses across the Site including the possibility of reusing the car park’s rooftop for a beneficial use.

Connected

4.27 Landsec will repair the place’s relationship with its surrounding context opening the Site and restoring the urban fabric of the town centre, meshing the place with the rest of the town centre by creating east-west routes and high-levels of pedestrian porosity. Landsec will liberate the ground floor to enable north-south pedestrian movement linking to the station and to establish legible gateways along Molesworth Street and the High Street with east west connections.

Mixed Use

4.28 A diverse mix of uses is proposed to support and intensify the High Street and enhance Lewisham Town Centre. Landsec will introduce significant new forms of living into the town centre to diversify the High Street beyond the retail and improve vitality and viability ensuring pedestrian activity throughout all hours of the day, supported by a new food and beverage street and cultural quarter. Tall buildings will support growth recognising that the town centre is the most suitable location for height, and the borough’s most sustainable location. Retaining and consolidating an attractive retail offer along Lewisham High Street to tie the place in with the rest of the town centre is important. Landsec are proposing a range of uses behind the

high street, including commercial, community and culture, relating to town centre renewal and Lewisham’s transport hub.

Green

4.29 Landsec is creating generous open space that marks the arrival from the Ravensbourne River and welcomes nature into the Site. Landsec propose permeable laneways through the Site and offer 0.4 urban greening and 346% biodiversity net gain with opportunities to experience nature on the upper levels (communal and private amenity). A new park is proposed for the town centre, supported by a new Northern Square, Easten Terrace and the New Model Market.

Healthy

4.30 Landsec consider that social belonging and physical wellbeing should be at the heart of the place. Landsec therefore propose to nurture health and wellbeing through land use and public realm design. This will be achieved by supporting active transport by providing a pedestrianfocused public realm and ample cycle facilities. Landsec will provide community facilities to support social wellbeing.

Flexible

4.31 Landsec is proposing a flexible, phased masterplan framework that grows the place organically and over time. The approach enshrines flexibility to meet new, emerging and currently unknown town centre needs.

4.32 To achieve this vision, a balanced and flexible approach is proposed. To achieve a successful ground floor, with active and animated frontages, some existing floorspace will have to be removed to make way for new streets and green spaces. Buildings will get taller to limit the amount of built footprint at ground floor, creating new spaces that are publicly accessible and engaging, for public benefit, and the overall viability of the scheme will be considered as a whole when maximising the delivery of affordable housing on site

5 The Site & Surrounding Area

5.1 This section of the Planning Statement sets out information regarding the Site and the surrounding area.

The Application Site

5.2 The Application Site comprises the Lewisham Shopping Centre and adjacent land. It extends to 6.93ha and represents the largest development site in Lewisham Town Centre.

5.3 The extent of the Hybrid application is shown at Figure 5-1.

5-1 Extent of Application Site

5.4 The principal addresses within the application Site are enclosed below

▪ Lewisham Shopping Centre

▪ Lewisham House, 25 Molesworth Street;

▪ Riverdale Hall and The Leisure Box;

▪ 72-82 Lewisham High Street;

Figure

▪ 120 to 132 Lewisham High Street;

▪ 142 to 160 Lewisham High Street;

▪ Lewisham Model Market; 196 Lewisham High Street;

▪ 208 to 212 Lewisham High Street; and

▪ The grade level car park to the rear of 208 to 212 Lewisham High Street.

5.5 Not all properties within the Planning Application boundary are owned by the Applicant.

5.6 The Detailed Component of the application extends across the majority of the north-eastern part of the Lewisham Shopping Centre, behind the existing retail frontage along Lewisham High Street at no.2 and 50-70 Lewisham High Street. The Outline Component extends across the remainder of the shopping centre, Lewisham House, and some properties fronting Lewisham High Street to the south

5.7 The Site is designated within Lewisham Town Centre, New Cross/Lewisham/Catford Opportunity Area and is designated for redevelopment within the development plan.

5.8 The Site benefits from an excellent Public Transport Accessibility Level (‘PTAL’) rating – 6B, which reflects the close proximity to Lewisham Station (170m to the north), and extensive bus network with stops along Lewisham High Street and Molesworth Street. The Site is not designated within a conservation area, nor does it contain any statutorily listed heritage assets.

5.9 A number of listed buildings lie in close proximity to the Site, namely the Grade II listed Clock Tower located on the junction of Lewisham High Street and Lee High Road (15m to east), the Grade II Church of Stephen and War Memorial which sits 100m to the north-east on St Stephen’s Grove, and the Grade II Church of St Saviour and Saints John Baptist and Evangelist, the adjoining Presbytery, and the former Prudential Building, which sit approximately 25m to the south-eastern corner. The Site sits in close proximity to several nondesignated heritage assets including the locally listed The Joiners Arms (66 Lewisham High Street) and 180-190 Lewisham High Street (Primark).

5.10 The Site is located within the Lewisham and Catford/Rushey Green Archaeological Priority Area (‘APA’) designated by the Council to have a potential to contain remains of medieval settlement which grew up beside the Ravensbourne River. The Site does not form part of any statutory or non-statutory nature conservation site.

5.11 As shown in Figure 5-2, the Site falls partly within Flood Zones 2 and 3 reflecting its proximity with the Ravensbourne River to the west, and the River Quaggy culvert which runs parallel to Lewisham High Street.

5.12 Lewisham Shopping Centre has been at the heart of the town centre for 45 years and needs renewal.

5.13 Lewisham Shopping Centre was opened in 1977 as the Riverdale Centre, the largest building in Lewisham Town Centre. The centre comprised 70 shops set over 3 floors, an 800-space car park, offices, a large internal service road and a disused leisure centre.

5.14 The disused Leisure Box (4,410sqm) has been shut for at least 21 years, previously offering sports facilities such as gymnastics, a five-a-side football, and badminton as well as an indoor crown green bowls court, bar area and function rooms but now largely dilapidated. On the ground floor is the former Riverdale Hall (1,714sqm), the Obelisk pensioners day centre and Spotlights bar. The Hall previously hosted a variety of events including an Elvis Presley exhibition, a Christmas ice rink, tea dances, antiques markets, and a Saturday morning cinema club. Next to this is Lewisham House (12,100sqm), an office building, which comprises long term vacant floorspace and has been subject to a number of permitted development proposals for conversion to residential use since 29th July 2015, all of which have now expired.

5.15 These areas of long term vacant floorspace total 20,708sqm and are mainly within the northern part of the shopping centre. There is also vacant floorspace distributed across the rest of the Shopping Centre, albeit to a lesser amount. By virtue of its cumulative effect, these vacancies create a sense of redundancy and reduce the vitality and viability of the Lewisham Town Centre.

Figure 5-2 Flood Map for Planning

Lewisham Shopping Centre

5.16 The design of the shopping centre (as a covered mall) results in a 100% plot ratio which offers limited opportunities for permeability and urban greening. It is an inclusive and enclosed environment solely reliant on retail occupancy and customer footfall to generate vitality and vibrancy. There is limited natural passing trade. Without sustained long term retail occupancy, there is no reason for the local community to visit the centre due to its inward facing nature and limited offer beyond retail.

5.17 Landsec has tried to keep the centre as occupied as possible, however this has its challenges due to the restructuring of the retail sector and in the long term is not a sustainable solution for Lewisham. Covid has created a greater issue by accelerating the structural change in retail, and through the loss of many high street retailers has removed current and future tenants. The existing shopping centre, by way of its configuration, mix and environment is not attractive to retailers.

5.18 Lewisham Shopping Centre comprises c.30,000sqm of town centre floorspace. Within the application boundary there is 20,708sqm of vacant floorspace, and 3,830sqm of short term lets16, totalling 24,538sqm. The vast majority (90%) of the shopping centre floorspace is at ground floor. Approximately 83% of shopping centre floorspace is or has most recently been used for retailing use. There is a very limited amount of food and beverage offering within the centre.

5.19 Vehicle access to the multi-level car park and the roof level service yard is taken via vehicular ramps from the junction of Molesworth Street and Rennell Street to the north, and Molesworth Street to the south. The centralised service deck extends across part of the shopping centre podium deck, with goods loaded and unloaded to the retail units below via this arrangement. The service deck extends partly beneath Riverdale Hall at first floor level. The shopping centre has five pedestrian access points taken from Salisbury Yard (via Rennell Street) to the north west, Lewisham High Street to the north east and east, and Molesworth Street to the south and west.

Existing Floorspace

Baseline

5.20 The existing town centre floorspace within the Site has been derived from various sources including a Landsec commissioned Ruxton Survey (2018); planning and CIL records held on the Council’s website; GOAD plans; Valuation Office Agency records; and physical site surveys and inspections undertaken in 2023.

5.21 As not all the buildings within the Site are owned by the Applicant, the information provided within this section of the Planning Statement and the planning application forms and CIL forms represent an informed estimate of floorspace, until such time as all buildings can be accurately surveyed and measured.

5.22 The information gathered serves the following function:-

16 Defined as having rental terms of 24 months or less.

▪ To provide baseline information to inform the determination of the planning application in respect of development within the planning application boundary (the ‘Application Boundary’).

▪ To provide baseline information to inform the determination of the planning application in respect of development within the wider Site Allocation LCA 2 designation within the Lewisham Local Plan, the ‘LCA 2 boundary’.

The Application Boundary

5.23 The existing floorspace within the Application Boundary is summarised in Table 5-1 below.

Table 5-1 Existing Floorspace within the Application Boundary

5.24 A full breakdown of this floorspace is set out in Appendix 1 (Schedule of Existing Floorspace)

Demolition by Component

5.25 The floorspace to be demolished to facilitate the detailed and outline components of the Application is presented in Table 5-2

17 Defined by Lewisham Local Plan Main Town Centre Uses Retail development (including warehouse clubs and factory outlet centres); leisure, entertainment and more intensive sport and recreation uses (including cinemas, restaurants, drive-through restaurants, bars and pubs, nightclubs, casinos, health and fitness centres, indoor bowling centres and bingo halls); offices; and arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities). See also National Planning Policy Framework.

18 Defined as temporarily let for 24 months or less

19 This includes all vacant and short-term let floorspace including Lewisham House, Riverdale Hall, Leisure Box and shop units

20 Figure excludes Lewisham House of c.12,100sqm. The existing floorspace is carried across within the proposed floorspace for Plot N3 which comprises the retained elements of Lewisham House and the extended built form. Floorspace to be demolished + retained + Lewisham House totals 72,644sqm.

Table 5-2 Demolition of existing town centre floorspace within each component

Demolition of Existing Town Centre Floorspace Gross sqm Detailed 3,921sqm Outline 52,037sqm TOTAL 55,958sqm

5.26 The properties proposed for demolition are identified on the parameter plans (Parameter Plan 03 - Demolition and Retention Plan - Level 00; 01; 02 and above)

R19 LCA 2 Boundary

5.27 The existing floorspace within the emerging local plan (‘R19’) Site Allocation LCA 2 is summarised in Table 5-3 below.

Table 5-3 Existing floorspace within the boundary of Site Allocation LCA 2

Existing Floorspace Gross sqm Town centre floorspace Within Application Boundary

Retained floorspace outside of the Application Boundary (but within R19 Site Allocation LCA 2)

R19 LCA 2 Development Capacity

5.28 The indicative capacity for R19 Site Allocation LCA 2 Lewisham Shopping Centre is summarised at Table 5-4

Table 5-4 R19 Site Allocation LCA 2 Site Capacity

LCA 2 Site Capacity Gross sqm Town centre floorspace21 60,291sqm TOTAL 80,388sqm Residential 2,150 homes

Land within R19 Site Allocation LCA 2

5.29 The following premises fall within Site Allocation LCA 2, but sit outside of the Application Boundary:-

▪ Lewisham Market. Home to a range of stalls selling fruit, vegetables, food and clothing, it has been running since 1906.

▪ Lewisham Model Market, opened in the 1950s selling model toys it closed in the 2000s, re-opening to host ‘Street Feast’ offering pop up drinking and dining experiences.

21 The inclusion of employment (20,097sqm) was removed as part of the R19 EIP.

▪ 2 Lewisham High Street;

▪ 50 to 70 Lewisham High Street;

▪ 86 to 118 Lewisham High Street;

▪ 162 to 194 Lewisham High Street;

▪ 198 to 206 Lewisham High Street; and

▪ Land to the rear of 96 to 112 Lewisham High Street

Existing and Proposed Town Centre Floorspace

5.30 The following conclusions can be drawn from the enclosed figures and the Proposed Development (explained in Sections 7-10), for the Application Boundary:

▪ Existing town centre floorspace 73,482sqm, less vacant and short term lets equates to existing 45,261sqm, which we call sustainable occupation.

▪ The existing sustainable occupied town centre floorspace at 45,261sqm equates broadly to the floorspace proposed by the application 49,404sqm2223, in fact positively there is an increase.

▪ The existing town centre floorspace 73,483sqm compared to that proposed 49,404sqm results in a reduction of 24,079sqm.

5.31 The following conclusions can be drawn from the enclosed figures and the Proposed Development (explained in Sections 6-8), for the R19 LCA 2 boundary:

▪ The proposed R19 Site Allocation LCA 2 town centre floorspace capacity of 60,291sqm broadly compares to the proposed floorspace of 62,618sqm24 within the LCA 2 boundary (there is a 2,327sqm increase).

▪ The existing town centre floorspace within the R19 LCA 2 boundary equates to 86,124sqm which when compared to that proposed (62,618sqm) results in an overall reduction of 23,566sqm, which is less than the current town centre floorspace that is currently vacant or in a short-term let arrangement (28,221sqm).

Planning History

5.32 The majority of the Site’s planning history relates to the shopping centre function to which there has been no previous application seeking the comprehensive redevelopment of the Site.

5.33 In respect of Lewisham House, the following decisions are relevant: -

▪

▪

DC/15/090552 - Prior approval application for change of use from office use (Class B1(a)) to residential (Class C3) to create 230 units. Approval Granted: 11th March 2015

DC/15/092471 - Prior approval application for change of use from office use (Class B1(a)) to residential (Class C3) to create 237 units. Approval Granted: 29th July 2015.

22 Proposed town centre uses are defined within the DSF.

23 Application Boundary Proposed: 49,404 [46,666sqm DSF (inc. 4,435sqm retained)) + detailed 2,738sqm]

24 LCA 2: 62,618 [49,404sqm + LCA 2 retained 13,214sqm]

▪

DC/17/105087 –Prior approval for the change of use from office use (Class B1a) to residential (Class C3) to create 237 units. Approval Granted: 29th March 2018.

▪ DC/21/120369 - Prior approval for the change of use from office use (Class B1a) to residential (Class C3) to create 218 units. It was determined in May 2021.

Surrounding Area

Other

5.34 The Site is bound to the west and south by Molesworth Street (A21), the east by Lewisham High Street and the commercial units which sit outside of the application boundary, and to the north by Rennell Street (A20).

5.35 West of Molesworth Street is the railway line, beyond is a mix of green space (Cornmill Lane) and residential and commercial buildings at varying heights up to six storeys set around the Ravensbourne River. Immediately to the north of the Site on the opposite side of Rennell Street is a cluster of tall buildings to the south-east and west of Lewisham Station which have been built-out over the last decade. The cluster of tall buildings range in height with the tallest on Connington Road extending up to 35 storeys, Lewisham Gateway 30 storeys, Lewisham Exchange 30 storeys and Lewisham Retail Park 25 storeys, discussed further below.

▪ Former Tesco’s Car Park, 209 Conington Road (Watkins Jones) (ref. DC/17/101621, as amended by DC/21/121768) to the north of the Site obtained detailed planning permission in January 2020 for a residential-led, mixed use development comprising 365 homes across buildings up to 34 storeys.

▪ Lewisham Gateway (Lewisham Gateway Developments Limited) (ref: DC/06/62375, as amended by DC/18/105218) to the north of the Site secured outline planning permission in May 2009 for the comprehensive mixed use redevelopment of the Gateway site up to for 57,000sqm of residential floorspace (approximately 800 residential units) across buildings up to 30 storeys. This development has been completed.

▪ Lewisham Exchange, Former Carpetright (Threadneedle) (ref. DC/17/102049) to north of the Site obtained detailed planning permission in March 2019 for a residentialled, mixed use development comprising 242 homes across buildings between 16 and 30 storeys.

▪ Lewisham Retail Park (Legal and General) (ref. DC/16/097629) to the north-west of the Site secured detailed planning permission in March 2019 for a residential-led, mixed use development comprising 536 homes across buildings up to 24 storeys.

▪ Axion House, Silver Road (London Square) (ref. DC/18/109972) to the west of the Site obtained detailed planning permission in May 2020 for a residential-led, mixed use development comprising 141 homes across buildings up to 16 storeys. The permission has been implemented and the development is currently under construction.

▪ Thurston Point, Jerrard Street (Charterhouse Properties) (ref: DC/10/76005, as amended by DC/15/092614) to the north-west of the Site obtained detailed planning permission in March 2012 for a residential-led, mixed use development comprising 406 homes across buildings up to 17 storeys.

▪ Sherwood Court, Thurston Road (Trademark Homes) (ref. DC/12/80762, as amended by DC/15/093176) to the north-west of the Site obtained detailed planning permission in

March 2015 for a residential-led, mixed use development comprising 168 student bedspace across two buildings up to 13 storeys. This development has been completed.

5.36 Lewisham Station is served by the London Underground DLR which runs between Bank and Lewisham, and national rail services that runs between London Charing Cross and London Victoria to Dartford, Gravesend, Hayes and Sevenoaks. Lewisham Station is located approximately 170m from the Site.

5.37 To the north-east on the other side of Lewisham High Street is Lewisham Police Station and several commercial buildings at heights up to five storeys. To the east of Lewisham High Street is a row of retail and commercial buildings up to three storeys.

5.38 Whilst the immediate surrounding area is subject to a mix of commercial and retail uses that support Lewisham’s town centre designation, the majority of major development in recent years have been residential-led to which there is an established and emerging cluster of large scale, contemporary residential buildings.

6 The Development Plan and Comprehensive Development

Introduction

6.1 This section of the Planning Statement considers the objectives of the development plan in respect of the Lewisham Town Centre and, specifically the Site and the requirement for comprehensive development set out in policies of the development plan and how the masterplan has sought to respond to the principles.

6.2 Section 38(6) of the Planning and Compulsory Purchase Act 2004, taken with Section 70(2) of the Town and Country Planning Act 1990 (“TCPA 1990”) requires the determination of a planning application to be made in accordance with the plan unless material considerations indicate otherwise.

6.3 The need for proposals to adhere to the development plan will be strengthened following the coming into force of the Levelling Up and Regeneration Act 2023, which amends Section 38(6) so that applications will need to be determined in accordance with the development plan unless material considerations “strongly” indicate otherwise.

The Development Plan

6.4 The Development Plan for the Site comprises the London Plan (March 2021) (‘London Plan’); and the Lewisham Local Development Framework, which comprises the Core Strategy Development Plan Document (June 2011) (‘LCS’), the Lewisham Site Allocations Local Plan (June 2013) (‘LSALP25’), the Lewisham Town Centre Local Plan (February 2014) (‘LTCLP’) and the Lewisham Development Management Local Plan (November 2014) (‘LDMLP’).

6.5 The Council is in the process of preparing a new Local Plan. The Regulation 19 Submission Version Local Plan (January 2023) (‘R19’) was subject to independent examination in the summer of 2024. Adoption is expected to take place in 2024/2025 at which point the R19 will carry full weight. At the point of submission, and in accordance with Framework paragraph 48, the R19 is awarded the appropriate weight in this planning statement on the basis that the examination has been completed, but theInspectors and Council have yetto report and consult on any further modifications and the Inspector’s report has yet to be published.

6.6 There are 10 current local Supplementary Planning Documents (‘SPD’) which support the Local Plan, including the A21 Development Framework; the Planning Obligations SPD; and the River Corridors Improvement Plan SPD.

6.7 There are more than 20 adopted and draft Mayoral Supplementary Planning Guidance (‘SPG’) and London Planning Guidance (‘LPG’) documents which provide supplementary detail and guidance on policies in the London Plan. They cover relevant topics including affordable housing and viability, housing, alternative residential uses (e.g. Large-Scale Purpose-Built Shared Living), social and green infrastructure, town centres, culture and the night-time

25 The LSALP does not relate to Lewisham Town Centre

economy, character and context, sustainable design and construction, play and informal recreation, and planning for equality and diversity.

6.8 The National Planning Policy Framework (the ‘Framework’) is an important material consideration, carrying significant weight. It provides the national context for planning in England, including Central Government’s economic and housing policy objectives and promotion of high-quality design. The Framework was last updated in December 2023 and has been out to consultation in respect of further revisions seeking to apply greater weight to the optimisation of brownfield land, and the application of the presumption in favour of sustainable development We have set out these revisions at Section 3 of this statement.

The London Plan (2021)

6.9 The London Plan identifies the Site within the New Cross/Lewisham/Catford Opportunity Area for at least 13,500 homes and 4,000 jobs by 2041. It is identified as a location with significant development capacity to accommodate new housing, commercial development and infrastructure (of all types), linked to existing or potential improvements in public transport connectivity and capacity. The London Plan states that the Mayor will both directly assemble land for development and support boroughs, Housing Associations and other homebuilders to do so. This may be through direct investment or through supporting compulsory purchase of appropriate land. He will also focus resources on areas where land suitable for development is not coming forward.

6.10 Lewisham26 is proposed to grow in function and population and has the potential to become a town centre of Metropolitan importance. The London Plan notes that the town centre retail and commercial functions are being intensified, rationalisation of the public highway will create improved pedestrian routes, and significant residential developments surrounding the town centre are underway, including Lewisham Gateway (located to the north of Rennell Street, to the north of the Site). The potential for further growth in Lewisham will be supported by the arrival of the Bakerloo line at Lewisham Interchange. This will bring enhanced access to central London and encourage the delivery of employment, leisure, service and community uses that serve the local and sub-regional population. Public realm and environmental enhancements of the town centre and surrounding employment, mixed-use and residential redevelopments will continue to be delivered and will assist the continued transformation of Lewisham into a high performing and vibrant retail hub with excellent leisure services.

6.11 Lewisham is identified as Major Town Centre, with nighttime economy classification of NT3, low commercial growth, high residential growth potential and a strategic area for regeneration27 .

6.12 The London Plan defines28 Metropolitan Centres as serving wide catchments which can extend over several boroughs and into parts of the wider Southeast. Typically, they contain at least 100,000 sqm of retail, leisure and service floorspace with a significant proportion of high-order comparison goods relative to convenience goods. These centres generally have very good

26 London Plan paragraph 2.1.18

27 London Plan Table A1.1 - Town Centre Network

28 London Plan Annex 1 Town Centre Network

accessibility and significant employment, service and leisure functions. Many have important clusters of civic, public and historic buildings.

6.13 Major Centres are defined as typically being found in inner and some parts of outer London with a borough-wide catchment. They generally contain over 50,000 sqm of retail, leisure and service floorspace with a relatively high proportion of comparison goods relative to convenience goods. They may also have significant employment, leisure, service and civic functions.

6.14 London Plan Policy SD9 (Town Centres) supports boroughs taking a proactive and partnership-based approach to bring sites forward for redevelopment, supporting land assembly in collaboration with local stakeholders including, where appropriate, through the compulsory purchase process

The Lewisham Local Plan

6.15 The adopted Lewisham Local Plan comprises the LCS; LSALP; LTCLP; and LDMLP.

LCS

6.16 The LCS29 recognises Lewisham Town Centre as the borough’s most important commercial centre and its largest shopping area, and benefits from excellent public transport accessibility. It refers to the Council’s aspiration for Lewisham to achieve Metropolitan Town Centre status through its potential for increased retail capacity and the provision of new housing, along with public realm and environmental improvements.

6.17 Lewisham Town Centre will be designated as a Major Town Centre and will be further developed so that it achieves Metropolitan status (by 2026); accommodates up to 40,000sqm of additional retail floorspace and 4,300sqm of additional leisure floorspace by 2026; accommodate up to 2,600 additional homes (by 2026).

LTCLP

6.18 The LTCLP is a Development Plan Document which establishes the plan area boundary and spatial strategy for Lewisham Town Centre; Policy Areas where development is expected to be focused and recognises key development sites; and includes a suite of policies that are relevant to all development proposals across the entire town centre.

6.19 The LTCLP sets out a vision of acting together to make Lewisham the best place in London to live, work and learn30; and a further nine objectives31 ranging from improving the vitality and viability of Lewisham town centre; delivering new homes; applying consistently high standards of design; carefully phased and co-ordinated development to create a cohesive place and a sustainable community; maximised job opportunities by ensuring the retention and reprovision of employment generating uses, the enhancement of training opportunities and the redevelopment of key sites throughout the town centre for a range of non-residential uses; encourage healthy lifestyles through the maintenance, protection and improvement of the

29 LCS paragraph 6.15, and Spatial Policy 2

30 LTCLP vision, paragraph 2.1

31 LTCLP paragraph 2.2

supply of publicly accessible open space and incorporation of additional recreational and open space as part of new developments; encourage patterns of development which support walking, cycling and the use of public transport; mitigate and adapt to the risks arising from air pollution and climate change delivering energy efficient and low carbon development; and enabling appropriate levels of education, community and leisure facilities that keep pace with proposed growth

6.20 Finally Objective 9 seeks to ensure that partners in the public, private and third sectors continue to work together to ensure that the forecast growth in the town centre is carefully monitored, managed and delivered throughout the plan period.

6.21 The Site is identified with the LTCLP boundary, the Lewisham Town Centre boundary and the retail centre32

6.22 The Site falls within one of six policy areas, specifically the ‘Central Policy Area’, which comprises Lewisham Shopping Centre, ‘Site 9’ (Land north of Lewisham Shopping Centre) and ‘Site 10’ (Land south of Lewisham Shopping Centre). These sites are identified at Figure 4.3 in the LTCLP.

6.23 Policy LTC2 seeks to create a cohesive and complete town centre experience contributing positively to the delivery of the vision and the objectives. LTC2 requires applicants to:

(a) demonstrate how the proposal will support the delivery of the town centre vision and the objectives of both the town centre and the individual Policy Areas;

(b) demonstrate how the proposal for a site has been informed by the current, emerging and future context of the site and surrounding area;

(c) ensure that the proposal is in no way detrimental to the successful current or future implementation of other nearby sites or their ability to meet the LTCLP vision or objectives.

6.24 Part 2 of LTC2, requires proposals to address how an individual site relates to the wider area, and where appropriate, applications must be supported by a masterplan across multiple sites to demonstrate the acceptability of an individual scheme.

6.25 Supporting paragraph 4.17 and 4.18 recognise that the individual sites identified in Figure 4.3 are of great importance to the successful delivery of the objectives for each of the Policy Areas and also for the vision and objectives of the whole LTCLP. However, it is the successful delivery of all sites and the cumulative impact of every development that will fulfil the LTCLP vision and objectives. As seen in Figure 4.3, the town centre location contains a large number of sites in close proximity to each other. The highly accessible nature of the town centre means that policy demands higher density development than the surrounding residential areas.

6.26 Policy LCT8, and Figure 5.6, relate to Lewisham Central Policy Area which includes Lewisham Shopping Centre and the street market; land directly adjoining the north (including the Citibank

32 LTCLP figure 1.3

Tower (now known as Lewisham House) and south of the Lewisham Shopping Centre, Molesworth Street and Lewisham High Street.

6.27 The supporting text33 acknowledges that the owners of Lewisham Shopping Centre are keen to develop and improve the offer available; and that land north of the Lewisham Shopping Centre will play a crucial role in achieving regeneration objectives for the town centre and plays an important townscape role.

6.28 Policy LCT8 identifies the following key principles within the Central Policy Area:

▪ 1. (a) as the Lewisham Shopping Centre is managed, refurbished and redeveloped over time, ensure every opportunity is taken to improve the number and nature of the east –west connections across the Lewisham Shopping Centre area.

▪ 1. (b) create a more coherent and pleasant environment which meets the needs of both pedestrians and vehicles.

▪ 2. Deliver a positive reduction in flood risk.

▪ Site 9, 3. Redevelopment of land to the north in sections or phases, will be encouraged in conjunction with more comprehensive improvements to the Lewisham Shopping Centre to provide retail (A1 – A3) and/or leisure use on the ground floor with commercial, leisure and/or residential use on the upper floors; active frontages; new connections; enhancements to the existing public realm and setting ofthe Lewisham Shopping Centre; more intensive office use or residential conversion of the Citibank Tower would be favourably considered by the Council. Any proposal should include recladding of the building and improved environmental performance; and new development should be mindful of future aspirations both on site and on nearby sites including required connections.

▪ Site 10, 4. Comprehensive redevelopment of the Beatties Building and model market; the beginning of the commercial and retail heart of Lewisham town centre, while respecting the height, mass and bulk of local surroundings. It should create a new southern anchor for Lewisham High Street to encourage customers to travel the full length of the High Street; buildings should make the best use of the corner site and provide enclosure and active frontages to both Molesworth Street and Lewisham High Street as positive public space.

6.29 The LTCLP recognises that Lewisham Shopping Centre will be redeveloped. It specifically promotes redevelopment of the Leisure Box and Riverdale Hall for commercial uses at ground floor and residential above and supports residential conversion of the Citibank Tower (Lewisham House). TheLTCLP seeks the comprehensive redevelopment of the Central Policy Area.

6.30 Other policies of the LTCLP can be summarised below.

6.31 LTC9 Growing the local economy part (b) seeks a greater component of residential development in the town centre within the overall mix of uses. Policy LTC10 (Mixed use) seeks an appropriate mix of compatible land uses, encouraged vertically and horizontally in Lewisham town centre. In particular, residential development located above ground floor retail

33 LTCLP paragraph 5.47

and commercial uses will be supported. Policy LTC11 (Employment uses) seeks to retain or re-provide employment floorspace (Class B) unless the buildings have been vacant for 2 years. Policy LTC13 Student housing is supported in the town centre. Policy LTC14 (Town centre vitality and viability) promotes a need to sustain and enhance the viability and vitality of the town centre through a greater mix of ground floor uses which may include cafés, bars and other evening economy uses (in conformity with Policy LTC17). Policy LTC15 confirms that the Council will continue to promote Lewisham Market as an essential part of the retail centre and encourage ancillary facilities in order to maintain its viability. Finally, Policy LTC16 (Retail areas) confirms that within the primary shopping frontage, as defined in Figure 6.1, the Council will strongly resist any change of use involving the loss at ground floor level of Class A1 shops. Exceptions are (a) whether the proposal will not harm the retail character of the shopping frontage (b) where the proposal will generate a significant number of pedestrian visits (c) the re-use of vacant floorspace. Normally 70% of the units should be Class A1 retail.

LDMLP

6.32 The LDMLP relates to development management policies and does not designate the Site for a specific use.

Regulation 19 (‘R19’) Local Plan

6.33 The ‘R19’ was subject to independent examination in the summer of 2024. Quod, on behalf of Landsec, made representations to the draft R19 and attended the examination in public. Adoption is expected to take place in 2024/2025 at which point it will carry full weight. At this point in time, however, the R19 is an emerging plan which is close to adoption, which therefore carries some weight. Paragraph 48 of the Framework 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).”

6.34 Given the status of the R19 (i.e. been subject to examination and close to adoption) it is considered that some weight should be applied to the policies in the R19. As such, this statement references the key draft policies in the R19 throughout.

6.35 R1934 states that the character of Lewisham Major Centre and its surrounds is strongly informed by its shopping and leisure destinations, as well as its highly active public places, including the rail interchange and market. However, whilst public realm improvements have been delivered through the redevelopment of larger sites over recent years, much of the town centre remains fragmented and disconnected from its surrounding neighbourhoods There

34 R19 Section 14, paragraph 14.2

remain areas with poorer quality public realm, particularly on Lewisham High Street. There are significant site redevelopment opportunities, including the 1970s built shopping centre and multi-storey car park, which alongside planned public transport improvements, will allow the character of Lewisham to be ‘reimagined’

6.36 As a result, LCA 2 (Lewisham Major Centre and surrounds) requires development proposals to contribute to a coordinated process of transformational improvement to the town centre and its environment Development proposals will be required to help facilitate, and must not prejudice, the delivery of strategic transport infrastructure necessary to ensure the centre can effectively serve, and benefit from, a wider sub-regional catchment and to support Opportunity Area objectives

6.37 Central Area Site Allocation 2, referred to as Lewisham Shopping Area, but incorporating all land bound by the High Street, Rennell Street, and Molesworth Street, comprises 6.38ha. The site allocation seeks comprehensive mixed-use redevelopment comprising compatible main town centre, commercial, community and residential uses. Redevelopment of existing buildings and reconfiguration of spaces to facilitate a street-based layout with new and improved routes, both into and through the site, along with public realm and environmental enhancements.

6.38 This allocation, which includes Lewisham House, recognises that the site forms the heart of Lewisham Major centre. Site Allocation LCA 2 sets out that comprehensive redevelopment of the shopping centre, alongside the delivery of a significant amount of new housing on upper floors, will enhance the quality of the town centre and help it to achieve Metropolitan centre status. It confirms that redevelopment will provide opportunities to deliver modern retail and employment space, and that redevelopment will provide opportunities to deliver modern retail and employment space, leisure, cultural and community facilities, to support the long-term vitality and viability of the town centre. Site Allocation 2 acknowledges that development can also enable transformative public realm enhancements to improve connections throughout the wider town centre area and secure the long-term future of the market.

6.39 To meet the objectively assessed needs of the Council, R19 proposes the deliver 2,150 homes within the LCA 2 allocation and 60,291sqm of town centre floorspace.

6.40 The R19 sets out that landowners should work in partnership and in accordance with a masterplan, to ensure the appropriate co-ordination, phasing and balance of uses across the site, in line with Policy DM3 (Masterplans and comprehensive development).

6.41 Policy DM3 requires proposals to demonstrate that they will not prejudice the future development of other parts of the site and adjoining land, or otherwise compromise the delivery of the site allocation and outcomes sought for the wider area. Proposals must address how the development site relates to neighbouring properties and the surrounding area, particularly in contributing to the delivery of the spatial strategy for the Borough. Policy DM4 (Land assembly) confirms that the Council will support land assembly to achieve comprehensive development.

Development Plan Principles

6.42 The Development Plan for the Site comprising the London Plan, LCS, LTCLP and LDMLP, seeks a comprehensive approach to town centre development, as summarised below. The R19, when adopted, will continue this objective.

6.43 Lewisham Town Centre is a strategically important location.

6.44 Lewisham Town Centre, and the Site within it, is strategically important to the growth requirements of London. It is designated within the London Plan as an Opportunity Area for significant transformational change to deliver new homes and job opportunities. It is a designated Major Town Centre, with the potential to be re-designated as a Metropolitan Town Centre. These centres serve wide catchments; contain retail, leisure and service floorspace; have good accessibility; and significant employment, service and leisure functions.

London Plan

6.45 London Plan Policy SD1 (Opportunity Areas, Table 2.1) identifies the Site within the strategically important New Cross/Lewisham/Catford Opportunity Area which seeks to deliver 13,500 homes and 4,000 jobs by 2041 where the Mayor will seek to both directly assemble land for development and support boroughs through compulsory purchase of appropriate land.

6.46 London Plan Table A1.1 (Town Centre Network) designates the Site as a Major Town Centre, with Potential for Metropolitan classification. London Plan Policy SD9 (Town Centre) supports boroughs taking a proactive and partnership-based approach to bring sites forward for redevelopment, supporting land assembly in collaboration with local stakeholders including, where appropriate, through the compulsory purchase process.

6.47 The London Plan recognises that public realm and environmental enhancements of the town centre and surrounding employment, mixed-use and residential redevelopments will continue to be delivered and will assist the continued transformation of Lewisham into a high performing and vibrant retail hub with excellent leisure services.

Lewisham Plan

6.48 Since June 2011, the LCS has proposed transformative change for Lewisham Town Centre, with an objective to achieve Metropolitan status. Lewisham Town Centre is recognised as the borough’s most important commercial centre and its largest shopping area, and benefits from excellent public transport accessibility. The potential to achieve increased retail capacity and the provision of new housing, along with public realm and environmental improvements are critical policy objectives.

6.49 LCS paragraph 6.15, and Spatial Policy 2, recognise that the Council’s aspiration for Lewisham to achieve Metropolitan Town Centre status will be realised through the potential for increased retail capacity, new housing, along with public realm and environmental improvements.

6.50 The LTCLP identifies the importance of a range of objectives that, acting together, comprise a successful town centre to make Lewisham the best place in London to live, work and learn through improving vitality and viability; applying consistently high standards of design; a cohesive place; maximised job opportunities; encourage healthy lifestyles; improvement of the supply of publicly accessible open space; and encouraging patterns of development which support walking, cycling and the use of public transport

6.51 The LTCLP identifies the Site within the Central Policy Area and promotes it for development and the creation of a cohesive and complete town centre experience

6.52 LTCLP LCT 2 seeks to create a cohesive and complete town centre experience through the successful delivery of all sites, taking into account the cumulative impact of every development that will fulfil the LTCLP vision and objectives, ensuring that an individual proposal is in no way detrimental to the successful current or future implementation of other nearby sites or their ability to meet the LTCLP vision or objectives.

6.53 LTCLP LC8 proposes a more coherent and pleasant environment which meets the needs of both pedestrians and vehicles.

6.54 LTCLP LC8 (Site 9) encourages redevelopment of land to the north in conjunction with more comprehensive improvements to the Lewisham Shopping Centre. New development should be mindful of future aspirations both on site and on nearby sites including required connections.

R19

6.55 The R19 consolidates the Lewisham Local Plan and designates the Site within Site Allocation 2, which binds all the land within the High Street, Rennell Street, and Molesworth Street (an area of 6.38ha).

6.56 The R19 recognises that whilst public realm improvements have been delivered through the redevelopment of larger sites over recent years, much of the town centre remains fragmented and disconnected from its surrounding neighbourhoods, and a comprehensive approach will allow the character of Lewisham to be ‘reimagined’, particularly the redevelopment of existing buildings and reconfiguration of spaces to facilitate a street-based layout with new and improved routes, both into and through the site, along with public realm and environmental enhancements.

6.57 The R19 recognises that opportunities to deliver modern commercial floorspace and housing above this, will support the long-term vitality and viability of the town centre. Development can also enable transformative public realm enhancements to improve connections throughout the wider town centre area and secure the long-term future of the market.

6.58 R19 LCA 2 (Lewisham Major Centre) requires development proposals to contribute to a coordinated process of transformational improvement to the town centre and its environment. Development proposals will be required to help facilitate, and must not prejudice, the delivery of strategic transport infrastructure necessary to ensure the centre can effectively serve, and benefit from, a wider sub-regional catchment and to support Opportunity Area objectives.

6.59 The R19 Central Area Site Allocation 2 seeks comprehensive mixed-use redevelopment; compatible main town centre uses; transformative public realm enhancements; improvement in connections throughout the wider town centre area; landowners must work in partnership and in accordance with a masterplan, to ensure the appropriate co-ordination, phasing and balance of uses across the site, in line with Policy DM3 (Masterplans and comprehensive development). It proposes 2,150 homes and 60,291sqm of town centre floorspace to meet the objectively assessed needs of the borough.

6.60 R19 Central Area Site Allocation 2 development guideline 12, requires redevelopment options for the plots of land that do not fall within the ownership of the Lewisham Shopping Centre to be explored, to better integrate them into a comprehensive scheme for the wider site allocation.

This includes retail units along Lewisham High Street, and the Lewisham House block where the principle of land use has already been established through the prior approval process.

6.61 R19 Policy DM3 (masterplans and comprehensive development) requires proposals to demonstrate that they will not prejudice the future development of other parts of the site and adjoining land, or otherwise compromise the delivery of the site allocation and outcomes sought for the wider area. Proposals must address how the development site relates to neighbouring properties and the surrounding area, particularly in contributing to the delivery of the spatial strategy for the Borough.

6.62 The R19 Policy DM4 (land assembly) confirms that the Council will support land assembly to achieve comprehensive development where that is necessary.

6.63 A comprehensive approach to development is explicitly required by the Development Plan if the policy objectives that are set out by the plan are to be achieved. This approach is established clearly within each Development Plan Document.

Summary

6.64 We consider that a comprehensive approach is required to achieve the principal policy objectives of enhancing the potential for Metropolitan classification; town centre vitality and viability; a cohesive and complete town centre experience; new homes; new commercial floorspace; applying consistently high standards of design; transformative public realm enhancements; improved and managed publicly accessible open space; improved patterns of walking, cycling and the use of public transport improved connections throughout the wider town centre area; reconfiguration of spaces to facilitate a street-based layout with new and improved routes; the character of Lewisham to be ‘reimagined’; the long-term future of the market; and the regeneration of the Site in a more coordinated way.

6.65 We consider that a comprehensive approach has been taken by Landsec as is expected by the Development Plan in accordance with the plan, and in particular LTCLP LCT 2, LC8 and the R19 (LCA2, Central Area Site Allocation 2, Policy DM3 and Policy DM4) in respect to the formulation of a planning application and emerging proposals. There are also many public benefits which will be realised from this approach.

6.66 There are no material considerations which would weigh against this approach

7 The Proposed Development - Summary

7.1 Within this section of the Planning Statement, we explain the overall proposed quantum of development across both the detailed and outline components

7.2 This is indicative in respect of housing numbers and student bedspaces as the Development Specification controls the outline component by floorspace (GEA sqm) rather than housing and student accommodation numbers. Where this is indicative, we have identified the metric with an Asterix (*) For the detailed component the metric is housing numbers and co-living bed spaces.

▪ Up to 1,719* homes (C3)

▪ Up to 661* Student beds (Sui Generis)

▪ Co-living homes (Sui Generis) 445 beds

▪ Town centre uses35 46,666sqm, of which at least 18,781sqm will be retail uses and 1,751sqm will be community and cultural uses within a new shopping centre.

▪ There will be a minimum of Class E(a) retail floorspace (GEA) per phase as follows: Phase 1 (inc detailed phase) 693sqm; Phase 2: 2,737sqm; and Phase 3: 15,351sqm.

▪ At least 11,885sqm of open space, parkland and public realm comprising at least the Park (5,255 sqm), the Northern Square (3,360 sqm), the Eastern Terrace (1,970 sqm), and the New Model Market (1,300 sqm).

▪ A reduction in car parking spaces from 836 (including 28 blue badge parking bays) to 60 (all blue badge parking bays).

▪ An urban greening factor of up to 0.4

▪ A biodiversity net gain of around 346%

▪ 125sqm of playspace within Phase 1a (including doorstep, local and youth play areas), with a further 4,079sqm* within the subsequent phases subject to a delivery plan)

▪ c. 770 FTE construction jobs (in any given month over the 10 year duration of the construction phase).

▪ 1,590 - 2,600 FTE jobs on-Site once the development has been completed (a net increase of 900 – 1,910 jobs).

▪ 15 new tall buildings up to 35 storeys in height.

35 Defined within the Development Specification

8 The Planning Application Structure

8.1 Within this section of the Planning Statement, we set out the structure of the Application and describe its detailed and outline components.

The Planning Application Boundary

8.2 The extent of the Site, for which planning permission is sought, is identified by the planning application boundary as indicated by the red line in Figure 5-1.

8.3 The Site area extends to 6.93ha.

The Detailed and Outline Components

8.4 The Application is a hybrid planning application with part being applied for in detail (the Detailed Component) and part being applied for in outline (the Outline Component).

8.5 The Applicant is seeking detailed planning permission for parts of Phase 1a which comprises the demolition of existing buildings, structures and associated works to provide a mixed-use development including the erection of a Co-Living building (Sui Generis) up to 23 storeys in height (Plot N1), and a residential building (Class C3) up to 15 storeys in height (Plot N2), associated residential ancillary spaces as well as town centre uses (Class E (a, b, c, d, e, f, g (i, ii)); and Sui Generis) together with public open space, public realm, amenity space and landscaping, car and cycle parking, highway works and the formation of new pedestrian and vehicle accesses, existing shopping centre interface works (the ‘Phase 1a Finish Works’), service deck modifications, servicing arrangements, site preparation works, supporting infrastructure works and other associated works.

8.6 Outline planning permission is sought for the rest of the Site, with all matters reserved, for a comprehensive, phased redevelopment, comprising demolition of existing buildings, structures and associated works to provide a mixed-use development including:

▪ The following uses:

▪ Living Uses, comprising residential (Class C3) and student accommodation (Sui Generis);

▪ Town Centre Uses (Class E (a, b, c, d, e, f, g (i, ii)) and Sui Generis);

▪ Community and Cultural uses (Class F1; F2; and Sui Generis);

▪ Public open space, public realm, amenity space and landscaping works;

▪ Car and cycle parking;

▪ Highway works;

▪ Formation of new pedestrian and vehicular accesses, permanent and temporary vehicular access ramps, service deck, servicing arrangements and means of access and circulation within the site;

▪ Site preparation works;

▪ Supporting infrastructure works;

▪ Associated interim works;

▪ Meanwhile and interim uses; and

▪ Other associated works.

8.7 The land subject to the Detailed and Outline Components of the Application is illustrated in Figure 7-1 below and Parameter Plan 01(Planning Application Boundary).

8.8 The Detailed Component extends to an area of 1.50ha and is shown hatched in pink in Figure 8-1. The Outline Component extends to an area of 5.43ha and covers the remainder of the area within the planning application red line boundary as also shown in Figure 8-1.

Figure 8-1 Planning Application (Detailed and Outline Components)

Demolition Works

8.9 The Application will require an amount of demolition works to facilitate the new buildings and spaces. A description of the demolition works is set out in Sections 9 and 10 of this Planning Statement and assessed against development plan policy in Section 19

Application Controls

8.10 The Detailed Component is controlled by the description of development, planning conditions including detailed drawings and the s.106 legal agreement.

8.11 The Outline Component is subject to specific development parameters controlled by the Parameter Plans, Design Code and the Development Specification. These are known as the ‘Controlling Documents’. The Outline Component is controlled by the description of development, planning conditions, and the s.106 legal agreement. The planning conditions will require adherence with the Controlling Documents.

8.12 The Outline Component will be subject to future Reserved Matters Applications for matters of access, appearance, layout, scale and landscaping.

8.13 An illustrative masterplan has been developed to illustrate how the outline proposals could be delivered at the Site. The illustrative masterplan represents one way of how the reserved matters could come forward in the future. For the avoidance of doubt, the Detailed Component shown in the illustrative masterplan does represent how the Detailed Component will be delivered.

Phasing Considerations

8.14 The Application is a phased development.

8.15 Phase 1a is applied for in detail. This includes Plots N1 and N2 (and supporting infrastructure), some access works, and existing shopping centre interface works (the Phase 1a Finish Works). Phases 1b, 2a, 2b, and 3a and 3b are applied for in outline. The Phases at Level 00 are shown on Figure 8-2 below:

8.16 Due to the phasing of the Proposed Development, there are certain elements of the development (and particularly Phase 1a) which on ‘day one’ completion will be in one physical condition but will later change to accommodate parts of the development which will come forward subsequently (i.e. when Phase 3 comes forward).

8.17 This section of the Planning Statement describes the approach to planning for interim and permanent development within the Proposed Development. Whilst we focus on Phase 1, similar issues may arise in later phases as a product of the need to keep the shopping centre operational and available to the public during the phased regeneration. This is for the benefit of the shopping centre itself, but also for the benefit of the wider town centre and to maintain vitality and viability. As such, a similar approach is likely to be needed for subsequent phases, and the principles set out below will therefore holistically.

Phase 1a Finish Works (Works to Plot N2)

8.18 Plot N2 is part of Phase 1a and is therefore part of the Detailed Component. It is the first plot to manage the complex role of delivering the development in its permanent form, while providing a connection to the remaining existing shopping centre during the construction works Plot N2 will need to provide a revised entrance and part of the shopping mall which will allow the shopping centre to continue to operate (and to allow customers to move north and

Figure 8-2 Lewisham Shopping Centre Phasing Strategy (Phases shown in black, Plots shown in green)

south through the site) during the construction phase and through to when the works are completed and the development is occupied. This revised structure will need to remain in place unless and until it is demolished/replaced or amended when Phase 3 is brought forward. At this stage, the final form of the entrance and this part of the mall is not known, as Phase 3 is applied for in outline, nor is it known when the Phase 3 works might be delivered (albeit a realistic scenario is tested in the Application). The mechanism below has been devised to cater for this situation and the delivery of these “Phase 1a Finish Works”.

8.19 The area affected by these issues is shown in Figure 8-3 below.

8.20 As explained above, it is critical to keep the shopping centre and town centre in operation during the construction works.

8.21 The “Phase 1a Finish Works” are required to connect the existing shopping centre and public realm into the permanent and completed finished state of building N2. It is envisaged that these Phase 1a Finish Works will be replaced or amended when the reserved matters for Phase 3 are submitted in due course. This is to ensure that when the final design of Phase 3 is known, there will be an appropriate interface with building N2.

8.22 The Phase 1a Finish Works will be dealt with as follows, and the process will be set out in the Section 106 agreement for the scheme:

▪ the detailed planning permission for Phase 1a includes the Phase 1a Finish Works;

▪ these works are shown indrawing refs. 0386-SEW-ZZ-00-DR-A-PL7200, 0386-SEW-ZZ01-DR-A-PL7201 and 0386-SEW-ZZ-ZZ-DR-A-PL7210);

▪ in due course, when reserved matters applications are being prepared for Phase 3, if there are works which will replace any of the Phase 1a Finish Works, the details of those

Figure 8-3 Phase 1a Finish Works (outlined in blue)

works will be designed and submitted for approval in full alongside the reserved matters for Phase 3:

▪ the reserved matters application will be submitted with a comprehensive set of plans and design statements which will show how the reserved matters and any full applications for works which replace the Phase 1a Finish Works fit together;

▪ the Section 106 agreement will also set out a list of principles that any such replacement works must follow, so that the planning authority can be satisfied that a high quality scheme will be delivered for the end state

Works to “finish” the Elevation to the shopping centre building following demolition for Phase 1

8.23 When the demolition works are undertaken to the north/western part of the shopping centre structure in preparation for Phase 1, and especially phase 1b, there will be a need for an endwall to be constructed to the retained part of the shopping centre, pending its redevelopment. This end-wall elevation will be in the outline element of the permission as its precise extent and design cannot be evaluated until various surveys have been resolved post permission

8.24 The planning application accommodates this by the description of development including “demolition” and “associated works”. The construction of the elevations will therefore have the benefit of planning permission as an “associated work” following the partial demolition of the north western part of the shopping centre. The treatment of the end-wall will be dealt with by a planning condition requiring the submission of the details of the proposed elevation for approval by the Council, such details to be submitted prior to the occupation of phase 1a or 1b as appropriate.

8.25 The potential extent of the existing shopping centre that may need such elevations is shown in Figure 8-4 below (yellow line)

8-4 Elevation Finish Works (outlined in yellow)

Figure

Phase 1 Public Realm

8.26 A number of considerations affect the design and delivery ofthe permanent public realm design for Phase 1, including:

▪ The precise extent of public realm which can be completed and made accessible with the occupation of Phase 1a cannot be finalised now as the construction requirements of Plot N3 are not yet defined.

▪ The initial design of the public realm along phase boundaries may not be able to accord exactly with the permanent design as, for example, half a water feature could not come forward.

▪ The Phase 1 public realm abuts elements of the masterplan outside of phase 1a which will have some flexibility in plan and so which may vary when the reserved matters for those parts come forward

▪ There may be requirements to temporarily accommodate play space or blue badge parking to support Phase 1, before it is re-provided in its final state in later phases.

8.27 A flexible scheme is therefore needed to deal with these uncertainties during the delivery of the Phase 1 public realm, which provides the local planning authority with the confidence that the quality of the public realm will be maintained throughout any such changes.

8.28 The proposed process is as follows:

▪ The Phase 1 public realm is applied for in outline in the hybrid planning application.

▪ The description of development includes “associated interim works”.

▪ A “Phase 1 Public Realm Scheme” (Drawing ref. 0386-SEW-ZZ-00-DR-L-PL6080) has been submitted with the hybrid application for approval. The Scheme sets out the final design intent for the whole of the Phase 1 public realm and has been drawn up to the level of detail that would be expected of a detailed planning application. The Design and Access Statement (Phasing Section) also identifies an indicative phasing plan for the delivery of the public realm works

8.29 Extracts of the Phase 1 Public Relam Scheme and Phasing Plan are included in Figures 8-5 and 8-6 below:

8.30 Some areas within the Phase 1 public realm will be delivered in their final condition with occupation of Phase 1a These permanent works will be fully in accordance with the Public Realm Scheme, save for any minor variations that may have been agreed, and will be formalised through a reserved matters application.

8.31 Some areas within the Phase 1 public realm will be delivered with occupation of Phase 1a, but will be delivered in an interim condition to allow for phased construction of the public realm so as to deal with areas where the final end-state of the public realm is not yet known. These interim works will be submitted for approval pursuant to the “Phase 1 Public Realm Delivery Plan” (see below). Then, when the Phase 1b reserved matters are subsequently designed and approved, these areas of interim public realm will be replaced with the permanent public realm works approved in the Phase 1b reserved matters

Figure 8-5 Phase 1 Public Realm Scheme

Figure 8-6 Phase 1a and Phase 1b Public Realm Phasing

8.32 Those areas within the Phase 1 public realm which will be delivered with occupation of Phase 1b, (in accordance with the Public Realm Scheme save for any amendments which may be agreed) will be included in the Phase 1b reserved matters application.

8.33 Those areas within the Phase 1 public realm which will be delivered with occupation of Phase 3b (in accordance with the Public Realm Scheme save for any amendments which may be agreed to fit with the final design of the reserved matters for Phase 3b) will be included in the reserved matters application for building W1. The interim condition for this area shall be approved pursuant to the “Phase 1 Public Realm Delivery Plan” (see below) prior to occupation of Phase 1b.

8.34 To ensure that residents have access to public realm during the construction phase, a Section 106 obligation is proposed to require that prior to the occupation of any building within Phase 1a:

▪ a “Phase 1 Public Realm Delivery Plan” shall be submitted for approval, with this Plan setting out the detail of the works and landscaping to be delivered in conjunction with the delivery of the buildings in Phase 1a, together with details of any interim works pending movement of hoardings, etc.

▪ For Phase 1a, the Public Realm Delivery Plan will confirm the Public Realm (either in temporary or permanent form), which includes connections to High Street and Rennell Street and has routes through it, will be made available for public use prior to occupation of Phase 1a (save for any temporary changes e.g. hoardings that may be permitted pursuant to the Construction Management Plan).

▪ A Reserved Matters application will be made for the permanent phase 1a public realm in those areas identified in the phasing plan included in the Scheme.

▪ The Phase 1 public realm works will be delivered in accordance with the approved Delivery Plan and the reserved matters approval.

8.35 A similar Section 106 obligation is proposed to require that prior to the occupation of any building within Phase 1b:

▪ The “Phase 1 Public Realm Delivery Plan” shall be updated and submitted for approval setting out the detail of the works and landscaping to be delivered in conjunction with the delivery of the buildings in Phase 1b, together with details of any interim works pending movement of hoardings, etc.

▪ A Reserved Matters application shall be submitted for the permanent Phase 1b public realm in those areas identified in the phasing plan included in the Scheme.

▪ The Phase 1 public realm works will be delivered in accordance with the approved Delivery Plan and the reserved matters approval.

8.36 Finally, the Section 106 obligation would require that prior to the occupation of the final building in Phase 3b:

▪ Reserved matters shall be submitted for the balance of the Phase 1 Public Realm

▪ The Phase 1 public realm works will be delivered in accordance with the approved Delivery Plan and the reserved matters approval

8.37 These matters will be discussed with the Council further during the determination of the Application.

9 The Proposed Development – Detailed Component

9.1 Within this section of the Planning Statement, we explain the proposed development within the Detailed Component of the Application.

Introduction

9.2 The Application seeks detailed planning permission for Phase 1a comprises Building N1 and Building N2; supporting infrastructure; a new existing shopping centre entrance feature(‘Phase 1a Finish Works’); together with highways access works.

Demolition Works

9.3 To facilitate the delivery of the detailed component, demolition will be undertaken to a number of buildings.

9.4 These buildings (including their address(es)) are scheduled below in Table 9-1.

Table 9-1 Buildings to Be Demolished to Facilitate Phase 1a

9.5 In addition to the standalone units / buildings in Table 9-1, there will be an element of Lewisham Shopping Centre circulation / mall space that will be demolished to facilitate the delivery of Phase 1a. This measures 447sqm.

9.6 The total extent of demolition required to facilitate Phase 1a equates to 16,392sqm. A reference plan highlighting the extent of this demolition is provided at Appendix 2 (Plan of Extent of Demolition for Phase 1a).

The Proposals

9.7 The Detailed Component proposed within Phase 1a includes:

▪ Building N1 – A 445 room Co-Living (Sui Generis) building;

▪ Building N2 – A 119 home residential (Class C3) building;

▪ Infrastructure to support Building N1 and Building N2;

▪ A new existing shopping centre entrance feature (‘Phase 1a Finish Works’); and

▪ Highways access works.

Building N1

9.8 Building N1 comprises a 445 room Co-Living (Sui Generis) building.

9.9 The building is formed of two principal elements at upper levels. The tallest element measures 23 storeys (including rooftop plant and mezzanine level within ground floor). At lower levels, the two elements are connected, which ensures that all residents will have a single point of entry at ground floor level and comparable access to the building’s excellent amenity provision. Building N1 enjoys frontage to Lewisham High Street, with this element measuring 4 storeys.

9.10 Building N1 is a standalone structure which will have no physical connection with any other building within the completed Proposed Development.

9.11 Co-Living is a managed, highly amenitised, residential tenure. The UK housing market is challenged with a lack of homes for the growing population, with the public and private sector looking for ways to ease the supply versus demand pressure. Co-Living is a product that has emerged in recent years, particularly in London, to help tackle the housing crisis by offering a new rental product to sit alongside existing products, in turn increasing the housing offer to existing and prospective residents. Co-living represents an expanding trend in modern managed rental housing, particularly for single renters. This segment, historically poorly served by traditional rental markets, now finds a viable and attractive option though Co-Living.

9.12 The principal appeal of Co-Living for residents lies in its all-inclusive price, professional management and greater flexibility in tenancy durations. It is emerging as an ideal solution for those who don’t want to live alone but require greater privacy and an upgrade from Houses in Multiple Occupation (HMOs).

9.13 Co-Living buildings are thoughtfully designed to balance private and communal spaces. This creates an ethos of sleeping in your bedroom, but living in the building. Residents have access to their own private studios, which are then complemented by a variety of shared amenities.

Building N1 will offer these shared amenities, including co-working spaces, expansive cooking and dining facilities, along with lounge areas for relaxation and social interaction. The shared access to significant internal and external amenity means that Co-Living is a completely different model for residential living

9.14 Building N1 has been designed thoughtfully to ensure that it maximises the living conditions for its residents The provision and layout of the supporting amenity spaces in particular has been curated using best practice, including drawing on the approach taken in successful CoLiving schemes operational in London, plus the experience of the Applicant’s architectural and technical advisory team (including leading Co-Living management operators, Urban Bubble). The design of Building N1 has also been influenced by – and responds successfully to – key guidance, including the Mayor’s recently published Large-Scale Purpose-Built Shared Living LPG (February 2024)

9.15 The principal entrance to the Co-Living use will be provided at ground floor level with access gained from the Northern Square. A secondary access point is provided to the rear, through the dedicated service yard which is to be gated at both ends for security purposes (gates closed during the night period with fob access for residents).

9.16 Three Class E / Sui Generis units are also proposed at ground floor level to strengthen the town centre first approach of the building and the Proposed Development as a whole. One of the units sits at the entrance to the Site from Rennell Street, one fronts Lewisham High Street, whilst the third fronts on to the Northern Square.

9.17 In terms of the Sui Generis units, these units will be able to accommodate the following categories (to align with the Outline Component):

(a) as a theatre,

(b) as an amusement arcade or centre, or a funfair,

(e) for the sale or display for sale of motor vehicles,

(f) for a taxi business or business for the hire of motor vehicles,

(k) as a retail warehouse club being a retail club where goods are sold, or displayed for sale, only to persons who are members of that club,

(l) as a night-club,

(p) as a public house, wine bar, or drinking establishment,

(q) as a drinking establishment with expanded food provision,

(r) as a hot food takeaway for the sale of hot food where consumption of that food is mostly undertaken off the premises,

(s) as a venue for live music performance,

(t) a cinema,

(u) a concert hall,

(v) a bingo hall,

(x) a dance hall

9.18 Further information relating to Co-Living is provided within Appendix 3 (Co-Living: Summary of Need and Benefits)

9.19 The Applicant has identified an opportunity for early delivery of public art within the Proposed Development at Building N1. The proposed location (the west facing elevation of Building N1) is a prominent location fronting the Northern Square. A significant piece of public art in this location will animate at the ground and plinth levels. Further detail regarding the Application’s approach to public art is contained within the Design and Access Statement (Volume 1). It is proposed that the approach to public art selection (through community engagement), installation and maintenance will be controlled via planning condition.

Building N2

9.20 Building N2 comprises 119 homes of residential (Class C3) accommodation, provided within two blocks. The tallest element is 15 storeys (including 2 levels of mezzanine at ground and first floor and roof access at the upper most storey).

9.21 Building N2 has an important location within the wider site and the Proposed Development It has an important relationship with Building N1 to the north, Building E1 to the south, Lewisham High Street to the east and the future heart of the Proposed Development to the west.

9.22 As a result of this, Building N2 is a building with multiple roles, which has in turn created its form and function.

9.23 First, the building plays a town centre role. Class E / Sui Generis floorspace is provided at ground floor level (with additional mezzanine space) and at first floor level. Appropriate town centre uses will occupy these spaces, potentially retail at ground floor (and mezzanine) with potentially a food and beverage use at first floor level.

9.24 To align with Building N1 (and the Outline Component) the Sui Generis units will accommodate the following categories:

(a) as a theatre,

(b) as an amusement arcade or centre, or a funfair,

(e) for the sale or display for sale of motor vehicles,

(f) for a taxi business or business for the hire of motor vehicles,

(k) as a retail warehouse club being a retail club where goods are sold, or displayed for sale, only to persons who are members of that club,

(l) as a night-club,

(p) as a public house, wine bar, or drinking establishment,

(q) as a drinking establishment with expanded food provision,

(r) as a hot food takeaway for the sale of hot food where consumption of that food is mostly undertaken off the premises,

(s) as a venue for live music performance,

(t) a cinema,

(u) a concert hall,

(v) a bingo hall,

(x) a dance hall

9.25 Secondly, the building will play a residential role. The residential accommodation will be provided on Level 1 (4 rooms), Level 1 Mezzanine (9 rooms), Levels 2-7 (13 rooms per floor) and Levels 8-11 (7 rooms per floor). On the lower levels, appropriate ancillary supporting spaces will be provided. A series of residential amenity spaces will be provided above at ground floor mezzanine, first floor and first floor mezzanine levels.

9.26 The residential entrance is provided at ground floor level with access gained from the Northern Square. A secondary point is provided through the dedicated service yard which is to be gated for security purposes (gate closed during the night period with fob access for residents).

9.27 Once built, part of the western edge of Building N2 will be physically connected to the existing shopping centre. In addition, a new shopping centre entrance arrangement is also proposed alongside Building N2 (the ‘Phase 1a Finish Works’) which also forms part of the Detailed Component

Phase 1a Finish Works

9.28 As previously explained, The Detailed Component includes a new shopping centre entrance arrangement - the ‘Phase 1a Finish Works’.

9.29 This new feature will measure 345sqm GEA (310sqm GIA).

9.30 The purpose of the Phase 1a Finish Works is to provide an enhanced pedestrian retail entrance to the northern end of the existing shopping centre for the duration of Phases 1 and 2 (and their sub-phases).

9.31 Once Phase 3 is delivered, the Phase 1a Finish Works may be removed and Building N2 will physically connect to the new shopping centre. The process for this is explained at Section 8 of this Statement.

Landscaping

9.32 The Detailed Component includes hard and soft landscaping. This is summarised as follows:

▪ Permeable block and concrete block paving, 4no. trees and an element of climbing planting in the Building N1 service yard;

▪ Green roofs at Level 2, Level 3 and Level 9 of Building N1;

▪ Natural stone flag paving, small trees in free-standing planters and additional soft landscaping in the Building N1 Level 8 external terrace;

▪ Permeable resin bound gravel, small trees in free-standing planters and additional soft landscaping in the Building N1 Level 2 external terrace;

▪ Permeable concrete block paving in the Building N2 service yard; and

▪ Permeable concrete block paving plus permeable resin bound gravel, trees and additional soft landscaping in the Building N2 upper level external terrace.

9.33 Further detail regarding the size of the external amenity spaces within Buildings N1 and N2 is provided below.

9.34 The delivery of landscaping within Phase 1 as a whole is dealt with in Section 8 of the Statement.

Highway Works

9.35 Some highway works are submitted for detailed approval and these are identified on the following drawings prepared by SLR:

▪ 184420/PD02/01 – Detailed Application Site Access;

▪ 184420/PD02/02 – Southern Service Route;

▪ 184420/PD02/03 – Southern Ramp Access;

▪ 184420/PD02/04 – Service Deck;

▪ 184420/PD02/06 - Proposed Molesworth Street Crossing; and

▪ 184420/PD02/07 – Temporary Southern Ramp

9.36 The detailed works comprise the following:-

▪ Removal of the northern ramp access to the shopping centre;

▪ Creation of a two-way southern ramp on Molesworth Street including the southern servicing egress route;

▪ Creation of a two-way southern ramp on Molesworth Street including the southern servicing egress route;

▪ Access to the north-east of the Site (Detailed Component of the Application);

▪ Egress from the north-east of the Site (Detailed Component of the Application);

▪ Access from High Street to the southern part of the Site (Outline Component of the Application); and

▪ Relocation of the existing toucan crossing on Molesworth Street.

9.37 These works will complement the highway works which form part of the Outline Component which will be subject to reserved matters applications at a later date, explained in the following section

Key Details

9.38 An overview of the quantum of land uses sought for approval for the Detailed Component is presented in Table 9-2 below.

Table 9-2 Detailed Component Proposed Uses and Amount of Development

9.39 The proposed residential mix is set out below in Table 9-3

Table 9-3 Detailed Component Residential Mix (Home and Habitable Room)

9.40 The proposed non-residential units within Building N1 and Building N2 are all located at ground floor and have been designed to accommodate a range of flexible uses capable of responding to changing demand and market conditions appropriately in the future

9.41 The proposed amenity space for the Detailed Component is set out below in Table 9-4

Table 9-4 Detailed Component Amenity Areas

Building

Private

(balconies, private terraces or gardens)

Private

9.42 Building N2 utilises a balcony strategy founded on good design and assessment work, reflecting the buildings location within the Site in terms of proximity to other elements of the Proposed Development and the environmental conditions.

9.43 The proposed playspace within the Detailed Component, which also forms part of the total amenity space calculations set out in Table 9-4 above, is set out in Table 9-5 below. The playspace is provided in connection with Building N2.

Table 9-5 Detailed Component Playspace (Associated with Building N2)

9.44 The proposed building heights are confirmed below in Table 9-6

Table 9-6 Detailed Component Building Heights (Heights Include Roof Plant and Lift Overruns)

9.45 Neither Building N1 or Building N2 incorporates a basement level within the Proposed Development (albeit there is an element of retained existing basement under part of the Building N1 plot).

9.46 The proposed car parking within the Detailed Component is set out below in Table 9-7.

Table 9-7 Detailed Component Car Parking

9.47 The proposed cycle parking within the Detailed Component is set out below in Table 9-8

Table 9-8 Detailed Component Cycle Parking

10The Proposed Development – Outline Component

10.1 Within this section of the Planning Statement, we explain the Proposed Development within the Outline Component of the Application.

Introduction

10.2 The outline component will be controlled by the Development Specification; Parameter Plans; and Design Code as well as the description of development, planning conditions and legal obligation.

10.3 Reserved matters (Appearance, Access, Landscaping, Layout and Scale) will be submitted for further consideration later. The Town and Country Planning (Development Management Procedure) (England) (Order) 2015 (“DMPO”) sets out the requirements and information that needs to be provided in support of both outline and full planning applications. Further guidance is also provided in the National Planning Policy Guidance (NPPG).

Demolition Works

10.4 To facilitate delivery of the outline component, the remaining part of Lewisham Shopping Centre, Molesworth Street car park, certain High Street buildings, the existing vehicular access ramps to the service deck as well as areas of the service deck and areas adjoining Lewisham House will be demolished.

10.5 The areas for demolition are identified on Parameter Plans 03 – 05 with extracts showing Level 00, Level 01 and Level 02 and above in Figure 10-1 below

10.6 Figure 10-1 also identifies existing buildings within the planning application boundary which are to be retained without works; to have at least their facades retained (the former Woolworths and Marks and Spencer); and those buildings to have at least their structure retained but with significant alterations and extensions (Lewisham House and the Corporation of London Building on the most southerly point of the Site).

10.7 The extent of demolition comprises c.46,000sqm

Figure

Amount and Use for the Outline Component

10.8 With reference to the details to be submitted with an outline planning application, NPPG Paragraph: 034 Reference ID: 14-034-20140306 states that – information about the proposed use or uses, and the amount of development proposed for each use, is necessary to allow consideration of an application for outline planning permission

10.9 The proposed amount of development and use is set out below in Table 10-1.

10.10The proposed uses and quantum of development for the outline component36 of the Proposed Development comprises the following uses and maximum amount of development.

36 The detailed component is not contained within Table 1-1 of the DSF which relates to the outline component only

37 The residential C3 floorspace maximum excludes floorspace needed for servicing, as that is included in item 5

38 This figure includes the re-use of Lewisham House for residential purposes

39 Sui generis uses defined at paragraph 2.7 below

40 Minimum Class E(a) retail floorspace (GEA) Phase 1: (inc detailed phase): 693sqm; Phase 2: 2,737sqm; and Phase 3: 15,351sqm

41 Minimum Class E(a) retail floorspace defined by 50% of the indicative schedule of accommodation (SOA) masterplan town centre floorspace

42 The town centre floorspace maximum excludes floorspace needed for servicing, as that is included in item

43 Sue generis uses defined at paragraph 2.7 below, with specific exclusions for the community & cultural uses floorspace

44 Elevated service deck to be shared between masterplan uses.

Reserved Matters

10.12Article 5(1) of the DMPO explains that “where an application is made to the local planning authority for outline planning permission, the authority may grant permissions subject to a condition specifying reserved matters for the authority’s subsequent approval”.

10.13In accordance with Article 2(1) DMPO, the following matters can be reserved for future approval:

▪ ‘Appearance’ – the aspects of a building or place within the development which determine the visual impression the building or place makes, including the external built form of the development, its architecture, materials, decoration, lighting, colour and texture.

The Design Code establishes the design principles to be applied to the massing and appearance of the buildings and the public realm at reserved matters stage

▪ ‘Access’ – the accessibility to and within the Site, for vehicles, cycles and pedestrians in terms of the positioning and treatment of access and circulation routes and how these fit into the surrounding access network. As explained in Section 8 of this statement, some highway works are submitted in detail for approval.

The Parameter Plans set the location of vehicle, cycle and pedestrian routes, accesses and egresses to and within the Site. They also show areas where access points to the Proposed Development and the existing network will be situated. The Design Code provides details of the treatment of the access and circulation routes

▪ ‘Landscaping’ – the treatment of land (other than buildings) for the purpose of enhancing or protecting the amenities of the Site and the area in which it is situated and includes – a) screening by fences, walls or other means; b) the planting of trees, hedges, shrubs or grass; c) the formation of banks, terraces or other earthworks; d) the laying out or provision of gardens, courts, squares, water features, sculpture or public art; and e) the provision of other amenity features.

The Parameter Plans identify the areas of public realm and Design Code describes the treatment of the different spaces within the Site

▪ ‘Layout’ – the way in which buildings, routes and open spaces within the development are provided, situated and orientated in relation to each other and to buildings and spaces outside the development.

The Parameter Plans identify a series of Development Plots across the Site where built development can come forward. The Parameter Plans also identify the main routes and open spaces. The Design Code establishes a series of rules about how these different elements interact with each other

▪ ‘Scale’ – the height, width and length of each building proposed within the development in relation to its surroundings.

The Parameter Plans describe the maximum building heights within, as well as minimum distances between Development Plots. The Design Code sets further rules to control the relationship between different buildings (e.g. height differences between blocks)

10.14In accordance with the DMPO definitions Article 2(1) DMPO, all matters will be reserved for future approval.

10.15Subsequent reserved matters will be submitted in due course, providing this detail and pursuant to the Development Specification, Parameter Plans and Design Code.

Design Principles for the Outline Component

10.16The Parameter Plans establish a series of design controls. Any future Reserved Matters Application must be in conformity with these. They are to be read alongside the Design Code and relate only to the outline component.

The Parameter Plans

10.17The Parameter Plans are grouped into types as outlined below:

▪ Planning Application Boundary

▪ Demolition and Retention

▪ Proposed Development Plots

▪ Maximum Building Heights

▪ Maximum BMU Heights

▪ Access and Circulation

▪ Land Use

▪ Public Realm and Open Space

10.18The Parameter Plans are listed in full below in Table 10-2.

10.19A description of each Parameter Plan is set out in the Design Code.

Design Code

10.20The Design Code will be enforced by means of being an approved controlling document secured by planning condition. It sets out design guidance which future Reserved Matters Applications will be submitted against and will need to conform with.

10.21The purpose of the document is to provide clear guidance for the intended form, scale and character of the individual buildings and landscape spaces proposed by the Parameter Plans. It will assist decision makers in assessing detailed design proposals as they come forward. It will also inform the architects commissioned to design the outline buildings and landscape of the obligations that the outline component is required to fulfil in terms of design intent.

10.22The Design Code for this Application has been produced by Studio Egret West

Illustrative Scheme and Accommodation for Outline Component

10.23Whilst the Outline Component will be subject to the controlling documentation discussed above, the Applicant has prepared an illustrative scheme, as an example of how the future phases of the development might come forward informed by the controlling documents, but as reserved matters. To clarify, the Detailed Component shown in the illustrative scheme does represent how the Detailed Component will be delivered.

10.24This scheme does not comprise a formal part of the Application or Proposed Development because it is illustrative, and NPPG45 confirms that details such as this which have been submitted for illustrative purposes only should not be treated as forming part of the development for which the application is being made

10.25A full description of the illustrative scheme is provided in the Illustrative Masterplan section of the Design and Access Statement. This describes the multi-levelled approach to the scheme, with the re-provided shopping centre at the heart and a series of open spaces and routes at ground, level 01 and level 02. The other buildings then sit within these spaces and can be accessed from various levels.

10.26The northern part of the Site includes the Northern Square open space, with a route in from Rennell Street to the north as well as an east-west route through it linking the High Street with Molesworth Street. The entrance to the shopping centre sits on the southern side of the Northern Square. Detailed Plots N1 and N2 are located on the eastern site of the Northern Square with Plot N3 on the western side. Plot N3 retains elements of and extends Lewisham House for residential use (430 homes, with town centre uses around the base in the illustrative scheme). The building is up to 33 storeys in the illustrative scheme. Alongside Detailed Plots

45 Conditions reserving outline application details: Where details have been submitted as part of an outline application, they must be treated by the local planning authority as forming part of the development for which the application is being made. Conditions cannot be used to reserve these details for subsequent approval. The exception is where the applicant has made clear that the details have been submitted for illustration purposes only. NPPG Paragraph: 005 Reference ID: 21a-005-20190723 Revision date: 23.07.2019

N1 and N2, the NorthernSquare and Plot N3 comprise the majority of Phase 1 of the Illustrative Scheme.

10.27Also in Phase 1, on the southern most point of the Masterplan, is the Music Venue (“MV”) which utilises and extends the existing Probation Service building to create a new music venue and cultural offering.

10.28In the illustrative scheme the southern part of the Site comprises the ‘People’s Platform’ and New Model Market open spaces with routes into these spaces from both the High Street and Molesworth Street. ‘New Romer Place’ links the High Street with Molesworth Street on an eastwest route. The southern entrance to the shopping centre is accessed from New Romer Place.

10.29This part of the illustrative scheme is located within Phase 2 and it also comprises Plots S1 (student accommodation – 342 units, 21 storeys), S2 (residential – 166 homes, 25 storeys), S3 (residential – 61 homes, 11 storeys) and S4 (student accommodation – 288 units, 17 storeys). All of these plots include town centre uses at ground level in the illustrative scheme.

10.30The central part of the illustrative scheme comprises the shopping centre at ground floor level with east and west accesses into it from the High Street and Molesworth Street respectively. Above the shopping centre at Level 01 are the ‘Eastern Terrace’ and ‘The Street’ open spaces which are accessed from the High Street and Northern Square respectively. The enclosed service deck is also located at Level 01, above the shopping centre, with ramped access from Molesworth Street to the south. At Level 02 is ‘The Park’ which provides a new green space for Lewisham, extending from the Northern Square to the People’s Platform and can be accessed from various points in the scheme. Also within The Park is Plot M1 or ‘The House within the Meadow’ which is safeguarded for community use and could comprise a café, community space and flexible space.

10.31The central part of the illustrative scheme forms Phase 3 of the Proposed Development. The other buildings within Phase 3 which sit above the shopping centre are Plots C1 (residential –81 homes, 12 storeys,), C2 (residential – 170 homes, 13 storeys), C3 (residential - 142 homes, 21 storeys), C4 (residential – 308 homes, 35 storeys) and C5 (residential – 166 homes, 24 storeys).

10.32Diagrams showing the illustrative scheme plots and phasing are shown in the Phasing and Landscaping Sections of the DAS.

10.33Based on the illustrative masterplan it is anticipated that up to approximately 1,524 new homes and 630 student bedspaces could come forward in the Outline Component. 44,181sqm of town centre floorspace is proposed but this will be subject to future reserved matters applications.

10.34The illustrative scheme dwelling mix is shown in Table 10-3 below:

Table 10-3 Illustrative Scheme Dwelling Mix

scheme)

10.35The proposed amenity space for the outline component is set out below at Table 10-4:

Table 10-4 Illustrative Outline Component Open Space

10.36The proposed play space within the illustrative scheme, which also forms part of the total amenity space calculation, is set out in Table 10-5 below:

Table 10-5 Illustrative Scheme Playspace

10.37The proposed car parking of the outline component is set out below in Table 10-6:

Table 10-6 Illustrative Outline Component Car Parking

10.38The outline residential element of the application will provide short and long stay cycle parking in line with the London Plan (2021). Cycle parking for commercial will be provided to cater for the increase cycle trips to the site whilst having regard to public realm aspirations and landscaping.

11Pre-application Engagement

11.1 Crucial to the development and formation of the proposals that form this Application has been the extensive and collaborative pre-application process that has taken place over the last few years. This section seeks to describe that process and explain how this engagement and feedback received has informed the Proposed Development.

11.2 We consider the pre-application process undertaken by the Applicant, with the Council, the GLA, and the local community as well as other key stakeholders to have positively defined the parameters for redevelopment of this Site. The consultation programme undertaken by the Applicant has sought to engage with a wide range of groups and individuals to ensure they were informed and had the ability to input to or provide feedback on the emerging proposals.

11.3 This approach is consistent with the national policy requirement for early engagement which has the significant potential to improve the efficiency and effectiveness of the planning application system for all parties. Good quality pre- application discussion enables better coordination between public and private resources and improved outcomes for the community46 .

11.4 The participation of other consenting bodies in pre-application discussions enables early consideration of all the fundamental issues relating to whether a particular development will be acceptable in principle, even where other consents relating to how a development is built or operated are needed at a later stage47

11.5 This includes engaging in design review, assessing proposals including workshops to engage the local community, design advice and review arrangements, the most benefit of which are if used as early as possible in the evolution of schemes for significant projects such as large scale housing and mixed use developments which has been the case for this application as demonstrated below48

11.6 Many of the planning objectives set out in the adopted and emerging development plan have been reflected in the consultation exercises undertaken by Landsec. There is an overriding desire for change. People want a cleaner, safer town centre, redesigned shopping centre, and more pedestrian areas. More independent retailers, cafes & restaurants are sought and whilst Lewisham market is popular, there are strong views about the way it is managed and the negative effects it has on the public realm.

Pre-application meetings

11.7 The Applicant has engaged with the Council and other key stakeholders including the GLA since 2020

46 Framework paragraph 39

47 Framework paragraph 42

48 Framework paragraph 138

11.8 A Planning Performance Agreement (‘PPA’) was entered into with both the Council and the GLA in accordance with Framework paragraph 46.

11.9 The Applicant has held a significant number of pre-application meetings It is this transparent and collaborative consultation that the Applicant believes has driven the positive progression of the proposals for a high-quality mixed-use development. The Applicant has also met with TfL, the Environment Agency and a range of other statutory and non-statutory organisations.

11.10In parallel to planning pre-application meetings, the Applicant also engaged with the Council’s policy team and engaged extensively with the Examination in Public of the Local Plan review.

11.11A schedule of both the planning and policy meetings is set within Appendix 4 (PreApplication Planning and Policy Meetings with the Council).

11.12We consider that early engagement has improved the quality of these proposals for all parties to enable improved outcomes for the community inaccordance with the Framework (paragraph 39)

Feedback from the Council

11.13The key topics of discussion during the pre-application process and how the proposals responded to them is set out below.

Retention and Demolition

11.14There were a series of discussions with officers around the extent of retention and demolition of the existing buildings and structures. The physical design constraints associated with elements such as the Leisure Box and existing service deck access ramps were explored both in terms of the impact of retaining them on the emerging masterplan as well as their suitability for retention. It was explained how the leisure box for instance has been vacant for many years and was in a poor state of repair. Analysis had shown that there were limited opportunities to add new structural openings, it was difficult to build above the existing structure and its retention would significantly compromise opportunities to open up the northern part of the Site.

11.15The retention and level of intervention to the buildings along the High Street was another area of focus As a result of the pre-application discussions, the extent of existing High Street buildings that are being retained has significantly increased. Early proposals retained a cluster of existing High Street buildings on the northern part of the High Street (opposite the Clock Tower) and a cluster to the south. In the final proposals, the majority of the existing units along the northern and southern parts of the High Street have been retained, including the repurposed Corporation of London building.

11.16The north of the site contains two of the largest existing buildings on the site - Lewisham House and the former Leisure Centre. Both buildings are long term vacant and currently unsuitable for occupation.

11.17However, the original brief from Landsec was to try to find solutions that left these buildings intact and re-purposed This approach of re-use and re-purpose is a good starting point for sites with existing uses.

11.18The original competition approach reflected this brief and identified only one potential significant development parcel in the northern part of the site, which was proposed to be a tower set fairly centrally on the south of Rennell Street. Given this lack of development capacity in the north, density and height were focused in the central and southern zones of the site.

11.19At early pre-application meetings, consultation and technical testing progressed, it became clear that this approach would not be supported by the Council, and that the most suitable zones of the masterplan for height and density would be west along Molesworth Street and north, close to where tall, high density development has already been delivered at the Gateway and other schemes.

11.20It also became clear that a centrally located tower on Rennell Street, sat opposite the existing pedestrian crossing and new pedestrian route through the Gateway scheme to the station, would also not be supported by the LPA for lack of line of sight and legibility. The proposed masterplan needed to provide a continuance of this route to facilitate circulation between the High Street, shopping centre, Gateway and station as clearly as possible.

11.21The team therefore moved to a strategy which was based on redevelopment rather than retention in the north, focusing density in the most appropriate location and assuming that both the Leisure centre and Lewisham House would need to be redeveloped more comprehensively in order to optimise delivery across the masterplan both of built form but also for coherent public space.

11.22The revised approach of concentrating height and density in the north and west allowed the removal of buildings placed centrally in the scheme. This released land and allowed the inclusion of two key benefits which were derived from public consultation and received very strong levels of public support - a covered shopping centre, and a new public park.

11.23In the absence of the redevelopment of Lewisham House and the Leisure centre in the context of the final masterplan proposals, significant height and density would need to be added elsewhere in the plan (which would not be supported by the Local Planning Authority) or would necessitate the loss of the shopping centre and central park (which would not be supported by any stakeholder including the local community). The approach involving comprehensive redevelopment in the north of the site is the only realistic way to achieve site optimisation and a range of objectives from the development plan policy, including the overall site capacity for homes.

11.24Given this we explored the demolition of Lewisham House, and redevelopment of land on which Lewisham House and the existing leisure centre sit. This was fundamental in delivering a comprehensive approach and achieving existing and emerging policy objectives.

11.25The next step and final solution became a 'hybrid' approach, which retains much of the concrete of the existing Lewisham House building (and therefore the embodied carbon) and extends the building to the north. This has achieved the same level of overall site optimisation by merging Lewisham House with neighbouring land. This emerges in the Evolution Summary section in September 2023, as Plot N3 in the proposal.

Access and Routes and Open Spaces

11.26Officers asked the design team to explore the relationship of the northern part of the masterplan with Lewisham Gateway. In earlier versions of the masterplan, a building was located across the northern part of the Northern Square which sat immediately in front of Rennell Street crossing. A building is no longer in this location, opening up a clear route from the Rennell Street crossing (leading from Lewisham Gateway) into the Northern Square. This also responded to comments relating to how fragmented the Northern Square was and the need for it to have a clear definition and being appropriately framed by surrounding buildings.

11.27Officers also sought for an increase in the number and changes to the alignment of routes through the Site, especially east-west routes. On the southern part of masterplan, New Romer Place now extends all the way through from the High Street to Molesworth Street and the route has widened. Significant changes were also made to the southern part of the masterplan in response to comments to integrate it better into the scheme, including direct links to the southern part of The Park and the introduction of the New Model Market space adjacent to Plot MV1. The east-west route through the Northern Square, linking the High Street and Molesworth Street, was made much more direct.

11.28The introduction of The Park at level 02 and ensuring easy and legible access from the lower levels was subject to detailed discussions with officers and it was considered that this could be a significant public benefit. More generally, the size and function of the upper level routes developed following discussions with officers which resulted in simplification and the introduction of The Street as a key linking route with activity at Level 01.

11.29A number of different options to service the development at both ground and service deck level were explored before settling on the retention of a reduced service deck at Level 01 alongside some ground level servicing in the northern and southern parts of the masterplan. Feedback from officers led to the priority to pedestrians over vehicles as well as planting in these areas being increased.

11.30Officers encouraged the setting back of the building line on Molesworth Street and greening where space allowed. This has been incorporated into the masterplan. Generally, officers encouraged the provision of as much greenery / soft landscaping / water as possible within the masterplan which has been included in the final proposals and led to an increase in the Urban Greening Factor score.

11.31These discussions fed into the proposed Parameter Plans (PP18 – 20) and Development Specification which secure the location and size of various routes and open spaces.

Town Centre Uses

11.32Officers were keen to ensure that town centre floorspace and active frontages were maximised across the scheme. Thedesign team have developed the proposals to provide active frontages to key open spaces and routes, as well as along Molesworth Street. As elements such as The Street, the Eastern Terrace and The Park have come forward during design development, these have also been carefully designed to accommodate town centre uses and activate

frontages, including the community building (Plot M1) on The Park Level. The Building Frontages Design Codes identify various types of active frontage across the masterplan.

11.33Officers also sought to secure a minimum level of town centre and community floorspace to be delivered in the scheme. The minimum quantums of these uses are set out in the Development Specification.

11.34Officers were keen to understand the internal environment of the new shopping centre, especially the width of the mall and the opportunities for incorporating seating and focal points. A number of precedents and options for the internal mall were explored, noting that the final designs would come forward at reserved matters stage. The submitted Parameter Plans (PP12) secure a minimum width of 12m for the internal shopping mall.

Building Heights and Massing

11.35During the pre-application discussions, officers wanted to further understand the rationale for the placement of the buildings as they emerged above Level 02. In certain instances officers recognised that buildings marked an important location or aided in wayfinding, however in others instances officers questioned the positioning of building. Concerns were also raised with the number of proposed buildings, how this had the potential to create a wall of development in certain areas as well as how the height transitioned from the High Street to Molesworth Street. The number and positioning of the buildings in turn compromised the size and quality of the open spaces across the Site. Officers questioned the height of the buildings on the southern part of the masterplan and generally the impact of the buildings in surrounding views and the character of the area

11.36Officers were engaged in a detailed of series workshops and testing to refine the approach to massing across the masterplan. The design team formulated a clear height strategy which entailed:

▪ ‘Healing the High Street’ – retaining further buildings on the High Street and keeping new interventions on the High Street to 4 storeys or less.

▪ ‘Creating a High Street Backdrop’ – a collection of buildings set back from the High Street and typically no more than 10 storeys in height.

▪ ‘A central mid-range spine’ – a linear collection of north-south orientated buildings through the centre of the Site, typically ranging from 10 – 15 storeys.

▪ ‘Taller buildings on Molesworth Street’ – taller buildings on the less sensitive western edge, variation of 15 – 35 storeys to avoid a wall of development.

11.37This strategy then led to a layering of buildings with the taller buildings sharing a clear base ‘landing’ on Molesworth Street and building tops expressed with a lightness and set backs in massing.

11.38Following this engagement, attention turned to the different building typologies presented in the illustrative scheme and how the principles established through illustrative scheme translated into the Parameter Plans and Design Codes.

Residential Amenity

11.39As the illustrative scheme progressed, officers focused comments on various elements of residential amenity and quality such as the building entrance sequence, unit aspect, overlooking, playspace and microclimate.

11.40Following comments, buildings in the illustrative scheme were developed to typically have more than one entrance, with primary entrances located at ground level where possible and secondary entrances typically located at upper levels. The buildings in the illustrative scheme have been positioned on the Site to ensure the primary facades of buildings are spaced at a minimum distance of 18m.

11.41The team presented officers with strategies to enhance the aspect of units within the illustrative scheme, identifying opportunities for dual aspect and enhanced aspect units. Careful microclimate analysis was undertaken to ensure that elements such as play facilities were positioned in appropriate locations having regard to wind conditions and sunlight availability.

Scheme Phasing

11.42Following comments from officers, the format of the planning application changed from being an Outline planning application to a Hybrid planning application with the first two plots (N1 and N2) being applied for in Detail. New architects for these Plots were appointed This also responded to officer requests to provide more certainty on how principles established for the masterplan would come forward at detailed design stage.

11.43In addition, officers made reference to R19 policy DM3 (Masterplans and comprehensive development) which seeks that where an outline application is made, it should be accompanied by a full planning application for the first phase of development.

11.44Officers were provided with specific details of the scheme phasing to aid in an understanding of the sequencing of the development and what elements would remain in situ whilst certain parts of the Site were being redeveloped.

Feeback from the Mayor of London

11.45As the Application is referrable to the Mayor of London under the Mayor of London Order 2008 the Applicant engaged with the GLA in respect of planning, housing design, transport and sustainability and a number of both joint and individual meetings were held.

11.46The GLA provided written comment on the application in June 2021, April 2022, May 2022, January 2023, January 2024 and September 2024.

11.47Comments on similar themes to LBL officers were raised, in summary:

▪ The principle of redeveloping the existing shopping centre to provide a mixed-use neighbourhood in an Opportunity Area and town centre location, with the highest PTAL of 6b, was supported and considered to have great potential to improve the area.

▪ Support was given to the Masterplan principles as well as the new north/south and east/west connections. However a number of the routes presented were relatively narrow, further access points should be introduced and visibility along routes improved In response, routes across the masterplan have been widened and further access points as well as improved visibility provided in response to comments.

▪ The activation of the ground floor is crucial. In response, ground floor activation has been maximised in the proposed scheme.

▪ The applicant is also encouraged to explore opportunities for concentrating or consolidating the planting in a specific place to create an actual park/landmark green space. A park/landmark green space would be transformative and could help establish the new future for the site. In response, this has been established through the creation of The Park.

▪ Every effort should be made to increase the number of dual aspect homes and single aspect north facing homes should be avoided. As explained above, the team presented strategies to enhance the aspect of units within the illustrative scheme, identifying opportunities for dual aspect and enhanced aspect units

▪ In relation to the southern part of the masterplan, the team was encouraged to explore opportunities to increase access from Molesworth Street as part of the aspiration to change its character, given that the current E-W routes to the south appear to be somewhat truncated. Furthermore, it was considered that a stronger relationship between High St and southern space should be sought. In response, this has all been incorporated into the final masterplan and officers confirmed how they had previously emphasised the importance of E-W routes through the site, which were lacking in the southern end of the development, so it was strongly supported that this point had been addressed.

▪ The increase in massing from east to west appears logical, mitigating impact on historic buildings and the market and helping to integrate the scheme into the all-important surroundings of Lewisham town centre. The reduction in scale north to south also appears logical, considering the relationship to the station and Lewisham Gateway to the north and the relationship with a low-rise context to the south. Nonetheless, was is noted that the proposed heights are still very significant and more information was necessary to establish whether these could be acceptable, particularly in terms of views and architectural quality. A Tall Building Assessment is provided in Section 17 of this Planning Statement which concludes that Proposed Development complies with the requirements of London Plan Policy D9, and with the corresponding tests in Lewisham’s local plan.

▪ The proposed long build period allows for a carefully phased delivery and is supported to maintain the viability of the town centre.

Design Review

11.48The Applicant is committed to bringing forward a viable development on this Site that secures a new town centre for Lewisham as well as design excellence. The Council are also committed to design excellence. The Council’s planning and design officers have been heavily involved

throughout the design and pre-application process and has coordinated reviews with the Council’s DRP. The DRP is an independent group, comprising experienced professionals who are charged with delivering the Government’s Design programme by creating high quality buildings and public spaces to enrich London’s communities.

11.49The collaborative design review process with the Council officers and the DRP has helped to inform the Proposed Development prior to submission of the Application

11.50The Framework, paragraph 133, gives weight to the design review process and identifies it as an important part of the scheme validation by independent bodies.

11.51Local planning authorities should ensure that they have access to, and make appropriate use of, tools and processes for assessing and improving the design of development. These include workshops to engage the local community, design advice and review arrangements, and assessment frameworks such as Building for a Healthy Life. These are of most benefit if used as early as possible in the evolution of schemes, and are particularly important for significant projects such as large scale housing and mixed use developments. In assessing applications, local planning authorities should have regard to the outcome from these processes, including any recommendations made by design review panels.

11.52London Plan Policy D4 Delivering Good Design also gives weight to design reviews recognising the following.

The design of development proposals should be thoroughly scrutinised by borough planning, urban design, and conservation officers, utilising the analytical tools set out in Part B, local evidence, and expert advice where appropriate. In addition, boroughs and applicants should make use of the design review process to assess and inform design options early in the planning process. It also adds some pressure on design developments to try and resolve as much detail as possible early on in the process, to avoid deferring the assessment of design quality to the consideration of a planning condition.

11.53A total of seven DRPs were held and a summary of the feedback received from the Panel on the masterplan is set out below.

▪ The Panel was supportive of the basic principles behind the project, and were appreciative of the many complexities of the context of the site and significant challenges that the scheme must overcome in order to be successful. The Panel were also supportive of the principle of retention of the interesting inter-war and post-war buildings that make up the character of Lewisham High Street

▪ The Panel endorsed the basis of the public realm strategy, interconnectivity and permeability, albeit it made a number of observations where these principles could be further strengthened. In particular, the positioning of the north and south squares could benefit from further reconsideration Following the final masterplan, the Panel concluded that the design concept for the Northern Square was strong but requires detailed design capturing the individual landscape and public realm elements within it

▪ The Panel noted that further work was required to develop the integration of vehicular traffic with the public realm. In response, the design and transport teams worked hard to

prioritise pedestrians throughout the public realm, including reducing the extent to which parking bays extended into the southern part of the masterplan.

▪ The Panel stated that the disposition of the north/south and east/west routes through this large urban block would do much to improve permeability and the alignment with wider connections, particularly those west to Cornmill Gardens were endorsed.

▪ As the scheme moved through the review process, the Panel recognised how the more developed organisation of the building masses, with the stepping in scale of buildings from Lewisham High Street toward Molesworth Street, was more legible and that the redistribution and evening ofmass across theMolesworth Street towers appeared largely successful The Panel concluded that the masterplan, including refinement of height and form are broadly supported at a masterplan level by the Panel

▪ The Panel were also presented the Design Code, Parameter Plans and Development Specification and welcomed the preliminary coding work. They noted that further work on the design codes was required so that future design teams will be provided with clear direction on the spatial and qualitative requirements for future proposals. The Design Code has been developed further following these comments.

11.54We consider that particular emphasis has been placed on achieving a well-designed place with a number of independent design panel reviews taking place with the Lewisham DRP as well as pre-application meetings with the Council’s and GLA’s design officers and heritage and conservation advice.

11.55We consider that a collaborative and rigorous approach has been undertaken to achieving a well-designed place by the Applicant in accordance with London Plan Policy D4 Delivering Good Design and the Framework paragraphs 132 and 133.

Public consultation

11.56The Proposed Development is the result of an extensive consultation with relevant local groups, stakeholders and decision-making bodies. Amendments have been made to respond to the comments received and the scheme therefore complies with the Localism Act’s duty to engage with the local community during the planning process.

11.57Alongside the pre-application process of consulting with public bodies, an extensive programme of consultation with the public has taken form through the following activities. These have targeted hard to reach, often marginalised groups to get a wide range of opinions and feedback.

▪ Creation of a group of Design Champions;

▪ Surveys (written, online and in-person);

▪ Local Polling;

▪ Newsletters;

▪ Public Consultation events including e-gaming;

▪ Themed public workshops;

▪ Existing Site Tours;

▪ Engagement with local youth group Circle Collective.

11.58The community engagement and consultation on the proposals for Lewisham Shopping Centre was delivered from July 2022 to September 2024. This engagement process built on earlier rounds of consultation carried out between autumn 2021 and spring 2022 and was designed to ensure a comprehensive and inclusive approach to community involvement. Consultation with stakeholders includes residents, businesses, shoppers, local groups, organisations and civic bodies, as well London Borough of Lewisham. In addition to this, a dedicated group of local residents, the Design Champions, were brought together as a sounding board to test and explore ideas and designs for the emerging masterplan.

11.59Set up in September 2022, the Design Champions were a carefully selected group of 16 local residents, appointed to provide feedback on a range of topics to shape the evolution of the masterplan. Over 300 applications were received and the final group chosen to represent a wide range of interests. These workshops related to:

▪ Site walk (October 2022);

▪ Movement (November 2022);

▪ Public realm (November 2022);

▪ Developing a meanwhile use offer (June 2023);

▪ Developing the vision (August 2023); and

▪ Northern Square (February and April 2024).

11.60Full details of the community consultation and engagement process and outputs can be found in the Statement of Community Involvement which accompanies the Application.

The Detailed Component

11.61Pre-application engagement with key parties has taken place since January 2024 regarding the design of the Detailed Component.

The Process

11.62The Detailed Component has been subject to focused engagement with key stakeholders since early 2024.

11.63This engagement has focused on ongoing discussions with three key parties:

▪ The Council’s Planning Officers (planning, design and conservation, and highways teams);

▪ The Council’s Design Review Panel; and

▪ GLA (planning, design and highways teams).

11.64These discussions have helped shape the final design as identified in the Proposed Development for Building N1 and Building N2. The design of these two detailed buildings has been a hugely involved and collaborative process.

11.65Further detail on the process is set out within the Statement of Community Involvement.

Principal Matters Discussed

11.66A high-level summary of the principal matters of discussion (by theme) is provided below.

11.67Further detail is provided within the Design and Access Statement, which also sets out the design evolution of the scheme

Building Scale and Built-Form

11.68The scale and built-form of Buildings N1 and N2 has been one of the primary pre-application engagement topics with the stakeholders.

11.69It is recognised that the location of Phase 1a within the Proposed Development as a whole is important as it forms a key ‘gateway’ site from both the north and the north-west. Buildings N1 and N2 are required to play multiple roles (including a town centre first role, and a resident arrival role), meaning that great care has needed to be taken to ensure the correct scale, massing and built form has been captured within the Proposed Development.

11.70Significant collaboration has been undertaken by the Applicant’s architectural team to ensure that the detailed N1 and N2 buildings have also been designed appropriately in the context of the outline parameters and Design Code prepared for the later phases of the Proposed Development.

11.71The final height, massing and built-form of Building N1 and Building N2 responds to the considerations tabled by all key stakeholders to arrive at the Proposed Development.

Proposed Uses

11.72Co-Living in particular is a relatively new alternative residential product. The Applicant has therefore sought to ensure that the Co-Living product is understood fully, particularly with Council officers on the basis that there is limited Co-Living operational in the borough. The Applicant has provided key information and precedent examples to Council officers throughout the pre-application period, and has undertaken a site tour of an operational facility (in Wandsworth). The Applicant’s team (including architects and building managers) are well experienced in the Co-Living sector and have brought this experience to the Proposed Development.

11.73The proposed residential (Class C3) use in Building N2 is more established and known to officers.

Phasing Considerations

11.74The Application is a relatively complicated, multi-phased development, involving both a part sought in full, and a part sought in outline. Phase 1a is the first phase of the Proposed Development to be delivered. In addition, Building N2 will have a physical connection to the Phase 1a Finish Works (also part of the Detailed Component) allowing it to align with the existing shopping centre, before the new shopping centre is delivered as part of Phase 3.

11.75Phasing, delivery and points of physical connection (across phases) has therefore required a significant amount of engagement to ensure that the Applicant’s intentions are fully understood

at the pre-application stage, and to allow the Proposed Development, at the point of submission, to be as robust as possible.

Heritage, Conservation and Townscape

11.76Heritage, conservation and townscape matters have been important considerations from the outset, recognising the proximity of Phase 1a in the context of local heritage assets, including St Stephen’s Church to the north west of the Site.

11.77The Council’s officers and DRP members, in particular, have required that the Applicant consider the evolving design in this context and from important view points. The design of Buildings N1 and N2 have been informed, in part, by the existing context and seek to respond and contribute to it in an appropriate manner.

Design, Appearance and Materiality

11.78The key stakeholders have been particularly keen to understand how the design detail has evolved throughout the pre-application period. Once the overall scale and building form of Buildings N1 and N2 were agreed in principle, matters of appearance and materiality were two of the primary discussion points.

11.79The Applicant has sought to be as collaborate and open as possible through the design process and has welcomed the inputs of the Council officers, DRP members and GLA officers.

Amenity Provision and Approach to Landscaping

11.80The mixed-use and multi-purpose nature of both Building N1 and Building N2 means that a certain amount of amenity provision has needed to be factored into the design, both internal and external. The relatively constrained nature the plots, and their proximity to the High Street and retained buildings on all sides, has facilitated a careful and considered approach to this amenity, particularly the external terraces and, in the context of Building N2, the play space areas.

11.81In addition, and in the context of Building N1, it has been important to the Applicant to show a commitment to achieving (and exceeding) the GLA’s recently published benchmarks for largescale purpose-built co-living developments.

11.82Council officers, in particular, have been very keen to understand how both buildings have responded to their site context in being able to achieve the required amenity provision, together with the incorporation of suitable landscaping.

Access and Servicing Arrangements

11.83Officers of the Council and GLA (with TfL), together with DRP members, have all engaged in the design approach of the dedicated service yards. Matters of security, access control, crime prevention, delivery vehicle movements and potential conflict issues between vehicles, cyclists and pedestrians have been a key part of the pre-application discussions.

11.84A number of approaches, layouts and strategies have been prepared, analysed and discussed over many months to arrive at the Proposed Development.

Technical Assessment Work

11.85Both Council and GLA officers have been keen to understand the performance of the emerging proposals throughout the pre-application period against key environmental indicators. The Applicant has sought to demonstrate that, through iterative test results, how the emerging designs have been evolved to respond to this ongoing technical assessment work, including wind, sunlight and daylight.

Summary

11.86The design of the Detailed Component has been a highly collaborative process which has involved a lengthy period of engagement with the Council, the Council’s DRP and GLA, plus other stakeholders. As a result of this process, the Applicant has prepared a high-quality proposal for Phase 1a of the Application which detailed planning permission is being sought for. The principal and the design of the Detailed Component is acceptable and has the support of the stakeholders.

12Town Centre First Approach

12.1 Landsec’s vision for Lewisham Town Centre has its foundations within adopted national policy, the London Plan and Lewisham’s Local Plan. Policies support adaptation and diversification of town centres to respond to the anticipated needs for town centre uses such as retail, office and leisure. Diversification in centres with current or projected declining demand for commercial, particularly retail, floorspace should be supported, alongside the promotion of residential floorspace which is considered a fundamental component of town centre vitality and viability.

12.2 This section of the statement explains this policy and how the Application responds to it.

The Framework

12.3 National policy relating to the vitality of town centres (Section 7) requires planning policies and decisions to support the role that town centres play at the heart of local communities by taking a positive approach to their growth, management and adaptation49. It recognises that town centres should grow and “diversify in a way that can respond to rapid changes in retail and leisure industries’ allowing ‘a suitable mix of uses (including housing)”50 Development plan policies should “recognise that residential development often plays an important role in ensuring the vitality of centres and encourage residential development on appropriate sites”51

12.4 National policy recognises that markets should be retained and enhanced and, where appropriate, new ones should be re-introduced or created52

12.5 Fundamentally, the anticipated needs for retail, office and leisure should be met, looking at least ten years ahead53

12.6 Reflecting the changing retail sector, the Government announced significant changes to the Use Classes Order which could render retail only town centre polices redundant. Class E (Commercial, Business and Service) incorporates a very wide spectrum of uses including Retail (previously A1), Financial and Professional Services (previously A2), Restaurant (previously A3), Offices (previously B1a), Research and Development (previously B1b), Light Industrial (previously B1c), Medical and Health Facilities (previously D1), Creches and day nurseries (previously D1), and Indoor sport, recreation and fitness facilities (previously D2).

12.7 This new class allows for a mix of uses to reflect changing retail and business models. It recognises that a building may be in a number of uses concurrently or that a building may be used for different uses at different times of the day.

49 The Framework Paragraph 90

50 The Framework Paragraph 90 (a)

51 The Framework Paragraph 90 (f)

52 The Framework Paragraph 90 (c)

53 The Framework Paragraph 90 (d)

12.8 The Government acknowledged that bringing these uses together under Class E and allowing movement between them will give businesses greater freedom to adapt to changing circumstances and to respond more quickly to the needs of their communities.

12.9 To comply with this objective, the Application seeks planning permission for Use Class E.

London Plan

Town Centre Diversification

12.10The London Plan Policy SD6 ‘Town Centres and High Streets’ reinforces the need to promote and enhance town centre vitality and viability (Part A). Whilst the London Plan does not define vitality and viability, it seeks to achieve this through inclusivity; a diverse range of commercial and community/social uses (operational day and night); housing; access by walking, cycling and public transport; creating a sense of place and local identity; economic contribution; and a Healthy Streets Approach54

12.11The policy specifically recognises that “the adaptation and diversification of town centres should be supported in response to the challenges and opportunities presented by multichannel shopping and changes in technology and consumer behaviour, including improved management of servicing and deliveries”55

12.12Part C and D refer to the importance of introducing new homes into town centres. The potential for new housing within town centres should be realised, capitalising on the availability of services within walking distance and current/future accessibility by public transport56. The suitability of town centres to accommodate a diverse range of housing should also be considered and encouraged. Specific reference is made to smaller households, Build to Rent, student accommodation and older people’s housing57 as being suitable for town centres.

12.13The re-development change of use and intensification of identified surplus office space to other uses including housing should be supported; social infrastructure should be enhanced; and safety and security should improve.

12.14Boroughs should support the town centre first approach in their development plans by assessing the need for main town centre uses, taking into account capacity and forecast future need; allocate sites to accommodate identified need within town centres, considering site suitability, availability and viability, and review town centre boundaries where necessary; support the development, intensification and enhancement of each centre, having regard to the current and potential future role of the centre in the network; identify centres that have particular scope to accommodate new commercial development and higher density housing, having regard to the growth potential indicators for individual centres in Annex 158

54 LP SD6A(1-6)

55 LP SD6B

56 LP SD6C

57 LP SD6D

58 LP SD7

12.15In respect of identifying sites suitable for higher density mixed-use residential intensification the London Plan suggests a number of relevant examples:59

▪ comprehensive redevelopment of low-density supermarket sites, surface car parks, and edge-of centre retail/leisure parks.

▪ redevelopment of town centre shopping frontages that are surplus to demand

▪ redevelopment of other low-density town centre buildings that are not of heritage value, particularly where there is under-used space on upper floors, whilst re-providing nonresidential uses; and

▪ delivering residential above existing commercial, social infrastructure and transport infrastructure uses or re-providing these uses as part of a mixed-use development.

12.16The rest of the policy suggests a flexible approach based upon existing capacity, forecast need and diversification. Vitality and viability are not dictated solely by retail floorspace quantum, rather a whole range of uses, including housing.

The Role and Function

12.17Policy SD8 ‘Town Centre Network’ recognises that “the changing roles of town centres should be proactively managed” in relation to Annex 1. Diversification in centres with current or projected declining demand for commercial, particularly retail, floorspace should be supported60 These centres may be reclassified at a lower level in the hierarchy through a coordinated approach with local planning authorities.

12.18The classification of International, Metropolitan and Major town centres (Annex 1) can only be changed through the London Plan.61 Annex 1 indicates potential future changes to the Town Centre Network. International, Metropolitan and Major town centres should be the focus for the majority of higher order comparison goods retailing, whilst securing opportunities for higher density employment, leisure and residential development in a high-quality environment. Boroughs and other stakeholders should have regard to the broad policy guidelines for individual town centres in Annex 1.

12.19The London Plan defines Metropolitan centres as serving wide catchments which can extend over several boroughs and into parts of the wider South East. Typically, they contain at least 100,000 sqm of retail, leisure and service floorspace with a significant proportion of high-order comparison goods relative to convenience goods. These centres generally have very good accessibility and significant employment, service and leisure functions. Many have important clusters of civic, public and historic buildings.

12.20The London Plan defines Major centres as typically found in inner and some parts of outer London with a borough-wide catchment. They generally contain over 50,000sqm of retail, leisure and service floorspace with a relatively high proportion of comparison goods relative to convenience goods. They may also have significant employment, leisure, service and civic functions.

59 LP SD7C(5)(5)(a-d)

60 LP SD8B

61 LP SD8C

Lewisham

12.21The London Plan Annex 1 Town Centre Network (and Figure 2.18 Town Centre Classification) provides strategic guidance for town centres in London.

12.22Lewisham is categorised as a Major Town Centre (ref. 40) with ‘future potential’ for classification as a Metropolitan Centre. The broad London Plan approach for Lewisham is set out below.

▪ Residential growth potential – High – This is a broad strategic-level categorisation that has been informed by the SHLAAA and Town Centre Health Check and takes into consideration the potential for impacts on heritage assets.

▪ Commercial growth potential – High – includes town centres likely to experience strategically-significant levels of growth with strong demand and/or large-scale retail, leisure or office development in the pipeline and with existing or potential public transport capacity to accommodate it (typically PTAL 5-6).

▪ Office Guideline – C – Protect small office capacity – These centres show demand for existing office functions, generally within smaller units. Category C is the lowest growth category for offices. Category A centres have the capacity, demand and viability to accommodate new speculative office development; and Category B the capacity, demand and viability to accommodate new office development, generally as part of mixed-use developments including residential use.

▪ Night-time economy classification – NT3 – These centres have a strategic night-time function involving a broad mix of activity during the evening and at night, including most or all of the following uses: culture, leisure, entertainment, food and drink, health services and shopping. NT3 is a more than local centre For reference NT1 is an international or national centre and NT2 is a centre with regional or sub-regional significance.

▪ Strategic area for regeneration – Yes -

12.23The London Plan allocates New Cross/Lewisham/Catford as an Opportunity Area for 13,500 homes and 4,000 jobs. The relationship with this wider growth area is important because New Cross (District) and Catford (Major) are designated town centres themselves and include uses which in other Boroughs may include in higher level town centres (e.g., Metropolitan Centres) e.g., the Civic Centre, Broadway Theatre, Goldsmith’s College and other evening economy/cultural uses.

12.24Unlike Croydon or Kingston, for example, where all the uses are concentrated within the Metropolitan Town Centre, Lewisham is different as these uses are located in adjacent centres. The potential for Lewisham to achieve Metropolitan status does therefore need to consider the residual effects on the growth and renewal ambitions of Catford and Deptford.

12.25Supporting text paragraph 2.1.19 states that Lewisham will grow in function and population and has ‘potential’ to become a town centre of Metropolitan importance. The potential for further growth at Lewisham will be supported by the arrival of the Bakerloo line at Lewisham Interchange. This will bring enhanced access to central London and encourage the delivery of employment, leisure, service and community uses that serve the local and sub-regional population. Public realm and environmental enhancements of the town centre and surrounding employment, mixed-use and residential re-developments will continue to be delivered and will

assist the continued transformation of Lewisham into a ‘high performing’ and ‘vibrant’ retail hub with excellent leisure services.

Mayor of London Adaptive Strategies

12.26The Mayor of London is seeking to grapple with the issue of town centre flexibility having published his ‘Adaptive strategies’62 for high street renewal in early 2020. The Mayor reminds us that his new London Plan calls for high streets and town centres to adapt and diversify.

12.27The Mayor recognises that London’s town centres are the focal point for our culture, communities and everyday economies. They support the most sustainable models of living and working, including active travel and shorter commutes. The strategy recognises that high streets are so much more than just retail. The guidance supports the implementation of ambitious, innovative and fresh strategies so our high streets and town centres not only adapt and survive but thrive.

12.28Landsec supports the recognition that when it comes to our high streets, London’s communities, businesses and local authorities can show extraordinary levels of enterprise, motivation and commitment to delivering change. In particular Landsec supports the following findings within the Mayor’s report:-

▪ There is significant value in London High Streets. Jobs, businesses, other nonresidential uses and the homes we live in are all part of our understanding of the high streets as places. High streets typically have more retail at ground floor facing the street, but they support a huge range of uses above and behind, and an interdependent mix of different activities and characteristics. Taken together, these have a multiplier effect in creating value of many types.

▪ High streets are about much more than retail. London’s high streets serve a wide range of Londoners in multiple and inclusive ways. They are highly social, diverse and accessible spaces. As such, they have a crucial role in supporting social, economic and environmental benefits. Particularly significant is the observation that high streets often cater for groups who areat risk of marginalisation or under-representation.These include the young, the elderly, jobseekers and those with young families.

▪ Whilst high streets appear to be a resilient urban typology in London, this varies widely across the city. For example, in Metropolitan centres, growth in the number of businesses and jobs is much lower than for high streets in general. Some of London’s larger centres are seeing a downturn in retail-related jobs and businesses, which is significant by national standards. In the three years from 2015-2017, retail employment in Kingston Metropolitan town centre for example fell by 15 per cent. The Mayor’s latest data shows that Croydon town centre has an overall vacancy rate of 22 per cent across all use classes.

▪ The Mayor sees high streets and town centres as good places for residential intensification. This is already being delivered across London, especially outer London, meaning more people will be living on and around high streets. Huge changes are needed. That’s why the London Plan supports and encourages the adaptation and

62 Mayor of London High Streets & Town Centres Adaptive Strategies, 21st January 2020

restructuring of town centres. This will enable them to take advantage of existing infrastructure and benefit from higher populations of residents.

12.29National policy and the London Plan provide an important policy framework, the conformity of which will apply a rigid backbone to Landsec’s proposals.

Lewisham Development Plan

12.30The adopted Lewisham Town Centre Local Plan (2014) (the ‘LTCLP’) recognises that Lewisham Shopping Centre will be ‘redeveloped over time63’. The plan specifically promotes redevelopment of the Leisure Box and Riverdale Hall for commercial uses at ground floor and residential above and supports residential conversion of the Citibank Tower (Lewisham House). It also allocates comprehensive redevelopment of the Beatties Building and model market to provide retail/restaurants or leisure uses on the ground floor with commercial or residential uses on the upper floors.

12.31Policy LTC8 – S9 (Land north of the Lewisham Shopping Centre) comprises land to the north east of the Lewisham Shopping Centre, the Citibank Tower and the land surrounding it. It recognises that redevelopment of the site could be in sections or phases. Redevelopment will be encouraged in conjunction with more comprehensive improvements to the Lewisham Shopping Centre to provide retail (A1 – A3) and/or leisure use on the ground floor with commercial, leisure and/or residential use on the upper floors.

12.32Policy LTC8 confirms that more intensive office use or residential conversion of the Citibank Tower would be favourably considered by the Council. Any proposal should include recladding of the building and improved environmental performance. Redevelopment (including taller elements) should respond positively to the Lewisham Gateway development and provide a welcoming and accessible entrance to the centre from Lee High Road.

12.33Policy LTC8 – S10 (Land south of the Lewisham Shopping Centre) seeks comprehensive redevelopment of the Beatties Building and model market sites to provide retail (A1-A3) or leisure uses on the ground floor with commercial and or residential uses on the upper floors Redevelopment should mark the beginning of the commercial and retail heart of Lewisham town centre, while respecting the height, mass and bulk of local surroundings. It should create a new southern anchor for Lewisham High Street to encourage customers to travel the full length of the High Street

Lewisham R19

12.34The emerging local plan promotes wholesale redevelopment of a 6.38ha island site comprising land bound by Molesworth Street, Lewisham High Street and the A20 referenced as Site Allocation LCA 2. The indicative capacity of the site is 60,291sqm of town centre floorspace.

Lewisham Town Centre

12.35Since 2009, the Council has sought reclassification of Lewisham Town Centre from a Major to a Metropolitan Town Centre. The challenge that the Council faces is that Lewisham has not yet met the floorspace metrics for Metropolitan classification, both in terms of catchment and floor area. Given the structural change in retailing, it may never achieve the London Plan metrics, and therefore a new interpretation of what is meant by Metropolitan is required.

12.36Lewisham Shopping Centre comprises an outdated retail model which does not serve the town centre as well as it could principally through a lack of permeability, poor environment, limited mix of uses, lack of afterhours footfall and a number of big box retailers which traditionally rely on car borne trips.

12.37With the removal of car parking from the development in line with London Plan and emerging policy, large box retailers will have to adapt. Landsec’s analysis demonstrates that retailers such as Primark, H&M and TK Max operate from smaller stores in higher order town centres which offers the prospect of Lewisham attracting more national retailers to smaller floorplates alongside increased opportunities for independents.

12.38This can result in improvements to employment density ratios as well as increased sales densities reducing the prospects of long term vacancies, smaller optimised retail units, which are less reliant on a handful of national retailers representing a more sustainable retail offer for the future. Our analysis shows that the most successful major town centres contain above average number of independent retailers. Lewisham can become a high performing and vibrant retail hub with this approach.

12.39It is also possible to maintain and enhance employment numbers and increase footfall through intensification and a mix of uses and the contribution of the missing offer of a nighttime economy. Catford, for example, scores higher than Lewisham for its nighttime economy.

12.40To complement greater employment densities, skills and training initiatives can be delivered both for retail and other professional jobs. New homes (including affordable homes) will generate increased council tax and new homes bonus and local spending. Indirect jobs and residential spending will contribute to vibrancy of the town centre and employment benefits will be complemented by end use employment and gross value add.

12.41The outcomes that are secured through investment in a town centre such as jobs, homes, businesses, health and wellbeing, safety, permeability, beautiful buildings, carbon reduction, accessibility, culture and urban greening can become the new ingredients for success and ambition of potential Metropolitan status. The future of Site Allocation 2 is clearly a catalyst to achieving these outcomes as the largest most central site in Lewisham, and these improvements can only take place with physical rationalisation of the existing commercial floorspace.

Role and Function

12.42Geographically, Canary Wharf is the closest Metropolitan Centre to Lewisham (one of ten Metropolitan Centres north of the River Thames). South of the Thames there are only 4

Metropolitan Centres (Bromley, Croydon, Sutton and Kingston) which form a crescent south of Lewisham.

12.43Lewisham is one of 36 centres classified as ‘Major’, albeit the only town centre south of the Thames with the potential for re-classification to Metropolitan. The Royal Borough of Greenwich is not seeking reclassification of Woolwich town centre due to insufficient retail expenditure growth and market share.

12.44To grow, improve and enhance vitality and viability, Stratford, Shepherds Bush and Croydon relied upon large, cleared sites or existing shopping centres to bring forward a specific retail model by Westfield. Croydon was more complex as it relied upon another landowner (Hammerson) but ultimately failed due to the economic cycle and is now a redundant business model due to on-line shopping. Hammerson also tried to deliver a similar retail model at Brent Cross but this has been in gestation for decades and the focus is now on the delivery of the residential quarter south of the north circular by Argent, similar to the International Quarter at Stratford and White City Living.

12.45Sutton Metropolitan Centre is different to Westfield, albeit like Lewisham has been the subject of a number of individual development plots that comprise tall buildings. Whilst cumulatively they symbolise regeneration and investment, individually the silo applications are unable to contribute significantly to the town centre as they are in different ownerships on very small plots. The St Nicholas Centre freehold has now been purchased by the Council to plan for the rationalisation of surplus floorspace.

12.46Canada Water and Wembley comprise low density retail warehouse and leisure parks with large surface level car parks. Whilst not fully cleared sites like Westfield, they do represent simpler clearly defined phases of development with greater scope for unencumbered development without multiple and layered interests such as those at Lewisham.

12.47The Elephant and Castle development comprises the shopping centre and land beyond it. Unlike Lewisham, the whole shopping centre was first demolished (2021). The site will comprise (Phase 2) Castle Square, a small shopping destination bringing together local traders around a public square (already opened), 485 homes across three towers and a twelve-storey university campus for UAL’s London College of Communication.

12.48The London Plan classifies town centres across London in accordance with their existing role and function, which is determined by the health check criteria that considers the centres’ scale, mix of uses, financial performance and accessibility.

12.49Whilst Lewisham performs well against all of the Major town centre thresholds, the town centre does not yet meet any of the Metropolitan Town Centre criteria. Metropolitan centres are characterised as serving a wide catchment that can extend over several London boroughs and into parts of the wider Southeast.

12.50To better understand Lewisham’s role within the sub-region, we have considered the classification and floor areas of adjacent town centres in South-East London to understand whether there is likely to be competition from these centres in terms of role and function. Peckham and Woolwich town centres are also performing close to the upper thresholds of a Major town centre constraining growth capacity for Lewisham. Woolwich has received

significant inward investment as a result of the opening of the Elizabeth Line, albeit is no longer seeking Metropolitan status due to a lack of retail capacity growth evidenced as part of the local plan review.

12.51When considering Woolwich’s potential for growth alongside the likes of Bromley, an established Metropolitan town centre, the ability for Lewisham to serve a wide catchment which can extend over several boroughs and into parts of the Wider Southeast through floorspace alone may be challenging

12.52Spatial improvements (other than the binary metric of floorspace) can however improve town centre vitality and viability as well as the outcomes secured through investment in town centres for jobs, homes, businesses. These improvements can support Lewisham’s role and function as potentially one of the most important centres in south London as it seeks to reinvent itself and compete with the more dominant established Metropolitan Centres to the south, and the growth ambitions of other Major Centres such as Woolwich, Canada Water, and the Elephant and Castle to the north. Yet unclassified centres with potential for classification such as North Greenwich and the Old Kent Road are also competing with Lewisham and driving growth through redevelopment based around tall building typologies.

Retail Needs

12.53Landsec has commissioned, using a methodology agreed with the Council and their specialist advisors, a new household shopping study and has applied the latest industry forecasts on special forms of trading (internet shopping); growth rates; shopping patterns within and outside the borough. The effect of applying the latest expenditure data and retail forecasts (including the growth of online shopping) substantially reduces the available retail expenditure for Lewisham town centre when compared with the evidence base provided to date in support of the evolving new local plan.

12.54The recent new household survey demonstrates that the retail growth forecast in 2009 has fallen away. An oversupply of retail floorspace exists in the town centre as a whole and Lewisham’s market share has not increase as expected, the town centre’s penetration draws principally from a localised catchment. Online shopping has increased significantly, well beyond the Council’s forecasts to 5.4% and 25.6% respectively for convenience and comparison goods. Year on year retail expenditure forecast up to 2040 is flat.

12.55Convenience floorspace needs have been met largely through existing stores cannibalising trade from each other, rather than from growth in expenditure. Sainsbury’s and M&S have seen market share reductions of over 70%, whilst Asda and Lidl’s market share has grown as a result. Further analysis using CACI data demonstrates that there has been a historic pattern of overinflated retail growth predictions which have simply not materialised.

12.56However, the need for retail floorspace consolidation and the Council’s objective for potential Metropolitan status are not mutually exclusive objectives.

12.57The London Plan recognises, in the case of Lewisham, that its potential relates to the further growth supported by the arrival of the Bakerloo line at Lewisham Interchange; enhanced access to central London; encouraging the delivery of employment, leisure, service and community uses that serve the local and sub-regional population; public realm and environmental enhancements; and the continued transformation of Lewisham into a ‘high

performing’ and ‘vibrant’ retail hub; with excellent leisure services. It is the performance of the retail floorspace and its vibrancy that defines its potential re-classification, not its quantum, and there is no reason why Lewisham cannot become a high performing and vibrant retail hub through redevelopment and floorspace consolidation.

Vacant Floorspace

12.58The oversupply of floorspace in Lewisham town centre is manifested when one considers the occupancy of floorspace in the town. LCA 2 is beset by long term vacant floorspace and short term lets which comprise a substantial amount of floorspace. Short term or temporary lets (0 –24 months) include occupiers who may be in administration, subject to a company voluntary arrangement (CVA), or are retained to ensure a degree of animation and activation within the shopping centre. This type of floorspace represents significant uncertainty in the long-term sustainability of a shopping centre, particularly in a contracting retail market. It is an economic risk, and occupancy risk and creates an unhealthy shopping environment and reduced footfall. Anti-social issues can arise as a result. This also creates negative effects on town centre vibrancy and vitality, particularly where much of the floorspace is in prominent locations to the north of the allocation.

12.59The oversupply of floorspace in Lewisham town centre evidenced in the previous and most recent household survey is manifest at Site Allocation S2. Physically it results in unlet shops and vacant floorspace. Combined with the long-term significant vacant floorspace to the north of S2 (Lewisham House; Riverdale Hall and the Leisure Box) this has represented a long-term issue.

12.60This pattern is typical within Lewisham Shopping Centre itself. Of the 47,288sqm of existing floor area64 , 7,251sqm (15%) is vacant or subject to short term lets.

12.61It is agreed that the consolidation of this old town centre floorspace, and particularly long-term vacant floorspace is a pro-active planning tool to foster and enhanced vitality and viability of the centre.

Proposed Development

12.62Across London, there are other examples of town centre development, albeit none directly comparable to the Landsec proposals at Lewisham. This is because Landsec are seeking to balance the need to develop and invest whilst maintaining operational continuity of Lewisham Shopping Centre and limiting disruption to the rest of the town centre.

12.63Landsec also do not consider that wholescale demolition of the Lewisham Shopping Centre (as a first phase) to create a cleared site is the most appropriate solution for Lewisham. It would detrimentally result in more areas of the town centre becoming inactive and redundant for a long period pending development. However, costs are associated with this approach. It is within this context that proposals need to be considered.

64 Excluding Lewisham House, Riverdale Hall and the Leisure Box

12.64In total, Landsec is proposing 46,666sqm of town centre floorspace. This compares to 73,483sqm existing town centre floorspace, of which only 45,261sqm is in sustainable occupation (e.g. excluding vacancy and short term lets).

12.65There is therefore a significant reduction (24,079sqm) in total town centre floorspace but when accounting for the fact that a large proportion is long term vacant (25,445sqm) or subject to temporary short-term leases (3,830sqm), much of the existing floorspace does not actively contribute to the vitality and viability of the town centre.

12.66The reduction in existing town centre floorspace will not therefore have a negative effect on Lewisham Town Centre, as much of its existing floorspace is sub-standard or underoccupied and therefore serves little to no economic function, and can be considered to actively detracts from Lewisham’s attractiveness as a town centre, and associated vitality and viability.

12.67The provision of new floorspace as part of the proposed redevelopment of the Lewisham Shopping Centre does represent an excellent regenerative opportunity for the Council and residents of Lewisham, with the proposed quantum of 62,618sqm of new town centre floorspace aligning with the R19 site allocation LCA 2 designation of 60,291sqm (2,327sqm increase).

13Economic Development

13.1 This section of the Statement summarises the economic and socio-economic position of Lewisham and explores the contribution that the Proposed Development will make.

13.2 Further detail is included within the Economic Growth Statement which supports the Application.

Context

13.3 The employment challenge in Lewisham is acute. It is the local authority with the lowest job density in London (see Figure 13-1) in 2019 with only 0.4 jobs per resident65. With overall employment in Lewisham staying the same between 2015 and 2021, compared to growth of 5.5% in London.

Haringey

Redbridge

Newham

Harrow

Bexley

Enfield

Bromley

Barnet

Brent

Lambeth

Kingston upon Thames

Hounslow

Hammersmith and Fulham

Tower Hamlets

Kensington and Chelsea

Westminster

65 ONS, 2019. LI01 Regional labour market: Local indicators for counties, local and unitary authorities

Figure 13-1 Job Density in London (Jobs Per Person)

Job Density

13.4 A new approach is therefore needed to support employment in the borough – and in particular in the town centre. This cannot rely on the continuation of a retail model that is outdated and declining. The counterfactual for the shopping centre, and indeed for the wider town centre, is not a continuation of the current snapshot. It is continued decline in employment.

13.5 Landsec recognise this issue and believe that it is appropriate to consider alternative ways of achieving potential Metropolitan Centre status. Historically, local planning policy identified that the vision to achieve Metropolitan status was based on a requirement for considerable growth in comparison retail floorspace66. This position was reached within a different retail context, namely one where the available retail evidence (published in 2009) suggested that there was substantial scope for further retail floorspace in Lewisham town centre.

13.6 There has been a fundamental shift in the retail sector in recent years meaning that it is no longer the case that there is substantial capacity forecast for further retail floorspace. This position is not unique to Lewisham and is reflected across town centres in London and elsewhere in the UK.

13.7 The Applicant seeks to address the town centre issues in a number of ways. In this context, the reimagined town centre will:

▪ Capture a higher proportion of spend – this is not about competing with online retail sales, but capturing more of what people spend in person, including on experiences and leisure.

▪ Expand and diversify its catchment to attract more and higher spending visitors to the town centre.

▪ Provide a range of employment and training opportunities both in the shopping centre and across the town centre.

13.8 These aims are summarised further below.

Capturing a Higher Proportion of Spend

13.9 The role and function of town centres is changing – the redevelopment of the shopping centre is an opportunity to move away from big box retail and a long-term vacancies to provide a mix of town centre uses that meet a local need.

13.10This means capturing more of what people spend in person – including importantly on leisure, food and beverage (‘F&B’) and the evening economy. Data from the 2017 GLA Health Check also highlights the lack of night time economy attractions Lewisham has compared to some of London’s most successful town centres. This is presented in Figure 13-2 below.

66 As outlined by the supporting text (para. 6.33) to Policy LTC15 of the LTCLP

Figure 13-2 Night Time Economy in London

Restaurants and cafes

Public houses

Other drinking establishments

Hot food takeaways

Hotels

Cinema

13.11There is comparatively little nighttime economy floorspace in Lewisham town centre, with no hotels or theatres, limited F&B and an overprovision of hot food takeaways. Catford has more floorspace to support its nighttime economy than Lewisham, owing to its theatre.

13.12Both residents and employees that are generated from the Proposed Development are likely to spend money in the local area and the wider Lewisham area. An assessment of the level of spending likely to occur once the Proposed Development is operational has also been carried out. This includes an assessment of:

▪ Household expenditure generated by the new households living within the new homes who may buy goods and services locally. This assessment was based on the Regional average household expenditure of £210 per week for London (ONS Family Spending Survey 202367);

▪ Calculation of spending by residents in Co-Living homes has been based on the average person expenditure of £85 per week derived from the from the (ONS Family Spending Survey 202368); assuming average occupancy of co-living homes of 1.25 (assuming one unit in every four occupied by two people);

67 Office for National Statistics, (2024). Household Expenditure Survey 2021-2023

68 Office for National Statistics, (2024). Household Expenditure Survey 2021-2023

▪ Spending by students has been based on an average annual spend of £8,673 on goods and services. This is based on a data from the Student Income and Expenditure Survey and adjusted for inflation69;

▪ Local expenditure by net additional employees. An average spend per day of £14.62 per employee has been applied, based on survey information carried out by research agency Loudhouse for Visa Europe (2014)70 and adjusted to account for inflation71

13.13The operational employees will spend a portion of their wages in the local economy, such as picking up items before or after work, or going for lunch. Workers in the UK spend an estimated £14.19 per day in the local area around their place of employment72. Table 13-1 breaks down the total spending set to be generated as a result of the Proposed Development by use (household, Co-Living, student and employee).

13.14As shown in Error! Reference source not found.1, gross annual spending by new residents (including students) and employees accommodated by the Proposed Development would total approximately £30.8 to £34 million. A proportion of this is expected to be spent on local goods and services. When looking at the net employee spending (taking the existing employee spending into account), the total expenditure is expected to be between £28.7 - £31.8 million.

Table 13-1 Estimated Household, Student and Employee Spending Category of Spending

£4.9 - £8.1

Expand and Diversify its Catchment

13.15The Proposed Development includes purpose-built Co-Living and student accommodation as well as traditional homes.

13.16The location (adjacent to Lewisham Station) and the type of units (the inclusion of flats / build to rent) are likely to attract young, mobile households who will spend money in the town centre, particularly if the town centre offer is diversified and improved.

13.17A report by the GLA ‘More Residents, more jobs’ (2015 update) found that 17 jobs were supported in the local area for every 100 residents. This would mean that 2,500 homes would support 850 jobs in the local area – ranging from teachers and health workers to people working in retail and leisure.

69 Department for Education, 2023. Student Income and Expenditure Survey 2021 to 2022

70 Visa Europe, (2014). UK Working Day Spending Report.

71 Bank of England, (2021). Inflation calculator. Available online: https://www.bankofengland.co.uk/monetarypolicy/inflation/inflation-calculator

72 Visa Europe, 2014. UK Working Day Spending Report. (Daily spending rate has been adjusted to account for inflation based on Bank of England inflation rate change since 2014).

13.18The provision of student accommodation is a further opportunity to support the demand for a wider variety of amenity and leisure uses and help animate the town centre in the evening. While student income is generally low, student spending is not – and it tends to be a disproportionally local and on a range of amenities. It also helps toforge links between education and employment opportunities (which is considered in more context below).

13.19The Proposed Development includes a range of uses including retail, leisure, community and office / workspace. This will facilitate significant opportunities across a range of uses.

Provide a Range of Employment and Training Opportunities

Construction Employment

13.20The construction of the Proposed Development will generate employment in the construction sector. Due to the nature of construction employment, it is not possible at this stage to accurately estimate the number of construction jobs that would be based on site during the construction phase. This is in part due to the mobile nature of construction workers, and the way in which various trades move on and off site over a construction programme. As a result, employment on-site fluctuates over the course of the build programme. Due to this, the contribution of the Proposed Development towards the overall construction sector has been estimated.

13.21The Construction Industry Training Board (CITB) Labour Forecasting Tool provides an estimate of monthly labour requirements based on the estimated construction cost and projected duration by assessing the output of each occupation and trade within the construction sector. This figure has been used to estimate the quantum of employment generated by the Proposed Development within the sector as a whole. When calculating construction jobs, the Labour Forecasting Tool assumes that there are 20 occupations73 that are of direct relevance to the on-site element of the construction phase of development. Direct, on-site full time equivalent (FTE) construction jobs are calculated by summing the generated monthly labour requirement for the 20 occupations identified as being directly relevant to the construction phase and dividing this figure by the duration of construction in months.

13.22It is estimated that the scheme would support the employment of a gross average of c.770 direct, on-site FTE construction roles over the duration of construction (around 120 months).

13.23The figure above only considers direct, on-site construction employment, with occupations that are expected to be off-site being taken out of the Labour Forecasting Tool when generating this figure. When considering the occupations that are likely to be offsite, it is estimated that the Proposed Development could generate a total average of over c.1,280 FTE construction roles over the construction period, including c.510 offsite roles. These roles are likely to be

73 Construction occupations include (HSC05) Construction trades supervisors, (HSC06) Wood trades and interior fit-out, (HSC07) Bricklayers, (HSC08) Building envelope specialists, (HSC09) Painters and decorators, (HSC10) Plasterers, (HSC11) Roofers, (HSC12) Floorers, (HSC13) Glaziers, (HSC14) Specialist building operatives not elsewhere classified (nec*), (HSC15) Scaffolders, (HSC16) Plant operatives, (HSC17) Plant mechanics/fitters, (HSC18) Steel erectors/structural fabrication, (HSC19) Labourers not elsewhere classified (nec*), (HSC20) Electrical trades and installation, (HSC21) Plumbing and heating, ventilation and air-conditioning trades, (HSC22) Logistics, (HSC23) Civil engineering operatives not elsewhere classified (nec*), (HSC24) Non-construction operatives

based over a wide area, in some cases nationally, and have therefore not been included within the consideration of local benefits.

13.24Construction employment is highly mobile, with travel to work patterns being wider than average. This is demonstrated within Construction Industry Training Board (CITB) surveys, with a third of workers in the UK having travelled more than 50 miles awayfrom their permanent homes74. According to CITB research, approximately 27% of construction workers working in London reside outside of this region. As a result, the construction employment effects should be considered at the regional (or wider) scale.

13.25The nature of construction is that employees move from project-to-project and site-to-site but remain with a single employer who would be sub-contracted to work on a specific project. Survey data from CITB75 suggests that in London, 30% of construction workers are employed on a temporary basis. The Proposed Development will make a significant impact in terms of construction employment opportunities.

Operational Employment

13.26The Proposed Development will provide a range of non-residential floorspace that will provide employment opportunities. The non-residential floorspace includes the provision of some flexible retail, commercial, community and cultural spaces. space and some community cultural uses. The assessment of the number of jobs expected to be accommodated by the Proposed Development has been calculated by using standard employment densities as set out within the HCA employment density guide.

13.27At this time in the development process, the future occupiers / operators are not known. Therefore, a range of employment densities has had to be applied to the flexible E Use Classes proposed (and a mid-point taken from these).

13.28Due to the flexibility of the proposals, the Detailed Component of the Proposed Development could accommodate between 145 - 195 jobs (FTE) and the Outline Component could accommodate between 1,445 – 2,405 jobs (FTE). When taking the estimated existing jobs into consideration, the Proposed Development could generate up to 900 – 1,910 net jobs which will positively contribute towards the economic growth of Lewisham, pushing the borough closer to being recognised as a Metropolitan town centre.

13.29The Proposed Development will also diversify the town centre and act as an improvement on the current town centre offer, making Lewisham a more popular destination for people to reside and spend time in.

Summary of Economic Benefits

13.30 The Proposed Development supports the Government’s economic growth ambition, including in the following ways:

74 CITB, 2023. Workforce Mobility and Skills in the UK Construction Sector 2022 – UK-wide Report

75 CITB, 2023. Workforce Mobility and Skills in the UK Construction Sector 2022 – London Report

▪ The biggest investment in the town centre for nearly 50 years, securing its future and growth comprising more than £1bn in investment

▪ Widening the offer in the town centre, with improved food and beverage, leisure and cultural provision, improving Lewisham’s place as one of South London’s best town centres.

▪ Reconnecting and tying together the town centre with new pedestrian and cycle routes, removing severance and fragmentation.

▪ Construction employment of c. 770 FTE jobs over the ten-year construction period on site, with a further c. 510 FTE jobs offsite.

▪ A net increase in employment of between 900 and 1,910 FTE jobs, once the development is complete.

▪ The delivery of up to c. 1,719 homes, 445 co-living homes, and up to 661 student bedspaces, contributing 13% of the ten-year London Plan target for the Council.

▪ New homes for households on the council’s waiting list, intermediate homes to rent for key workers, family homes, and homes for students, supporting the higher education sector in the borough, and developing skills locally

▪ The development provides a new place for up to around 4,350 people to live in the town centre.

▪ These homes would generate up to £3.8m in New Homes Bonus for local priorities.

▪ This increase in employment will generate gross value added (additional economic activity) of between £30 million and £160 million per year

▪ Securing business rates revenue for the Council.

▪ An increase in resident and employee spending of between £28.7 - £31.8 million annually.

▪ The delivery of a series of publicly accessible open spaces, including The Park, Northern Square, Eastern Terrace and New Model Market.

▪ New homes for students, supporting the higher education sector in the borough, and developing skills locally.

▪ Delivering approximately £27 million CIL payments to fund local priorities

13.31Landsec has a track record of unlocking some of the most technically complex regeneration sites at the heart of communities across London and England. Its vision in Lewisham is to renew the town centre through a contemporary mixed-use development that is entirely compatible with the unique historical nature of the Site, taking inspiration from local businesses and community. The end goal being to reconnect the site with that community and transform its future as an important and resilient town centre where people want to live, work and spend time for years to come.

13.32The Lewisham Shopping Centre development will deliver new homes, new open space and a new leisure offer to support the town centre, and creating a new cultural venue. It will revitalise the retail environment, tying together the high street, market, station and open space with new convenient and attractive links.

13.33These proposals come at a time when the Government, has called for Britain to get building. Delivering economic growth is the number one mission for our country, and the planning system is central to achieving this. This is an opportunity for Lewisham Town Centre to play its part, securing its own economic growth for the borough and beyond.

13.34Lewisham town centre is unlikely to achieve Metropolitan status based upon floorspace thresholds alone and the success of the town centre will be reliant on a flexible interpretation of the Metropolitan classification read alongside the qualitative objectives of the Development Plan. This will also need to be applied to The R19 once adopted.

13.35The Applicant recognises the issues which the town centre faces and also the part that the Proposed Development can play in addressing these issues. In terms of the local economy, the Proposed Development will assist Lewisham in terms of capturing a higher proportion of spend; expanding and diversifying its catchment; and providing a range of employment and training opportunities.

13.36As set out further in the Economic Growth Statement the economic benefits of the Proposed Development are considered significant, weighing heavily in favour of the Application.

14Living Uses – C3 Housing

14.1 Within this section, we consider the strategic housing needs of London, and those of the Council including affordable housing.

14.2 Given that the Application proposes a significant amount of housing including affordable housing, where there is a clear need for more housing delivery, significant weight will be given to this aspect of the proposal, particularly as the tilted balance applies in Lewisham.

14.3 We have divided our assessment of housing into the following headings:-

▪ The Government’s changes to housing delivery

▪ Lewisham’s housing need and the presumption in favour of sustainable development

▪ The contribution of the Application proposals

▪ Affordable housing

▪ Housing mix

▪ Viability

14.4 Both the Council and the GLA support the principle of bringing forward housing on this strategic site.

The Government’s changes to housing delivery

14.5 The principle of development of the Site for housing is accepted. The Proposed Development is consistent with the national, regional and local policies which expect housing at higher densities to be promoted in locations that are well connected to jobs, services, infrastructure and amenities by public transport, walking and cycling, including car parks.

14.6 The 2024 consultation76 Framework provides a welcome statement of intent from the new Government. Delivering economic growth is the Government’s number one mission

14.7 Angela Rayner’s statement as Deputy Leader and Secretary of State for Housing, Communities and Local Government brings necessary urgency to housing delivery setting out a moral obligation to deliver economic growth by approving more housing and commercial development, now; and highlights the social and economic impacts77 arising from our national housing shortage. Fundamentally she makes it clear that the Government will intervene where there is persistent failure to deliver new homes.

14.8 The narrative that there is a Government led presumption in favour of sustainable development is the biggest change of tone from the previous Government, which is supported by the

76 30 July 2024 at 2pm and close at 11.45pm on Tuesday 24 September 2024

77 “150,000 children are in temporary accommodation, nearly 1.3 million households on social housing waiting lists; and rents are up 8.6% in the last year; and homelessness is at record levels”

technical changes proposed within the Framework. Cumulatively the Government seeks to provide a significant boost to housing delivery.

14.9 The Framework seeks to draw together housing need and delivery of that need, the overall aim to meet an area’s identified housing need78, rather than just publish it. It reinstates the requirement to demonstrate a 5 year housing supply79; and elevates the substantial weight applied to the value of using suitable brownfield land within settlements for homes because these proposals “should be regarded as acceptable in principle80”

14.10The Government proposes to delete the get outs introduced by the previous Government which advised that housing numbers are advisory starting points81; local authorities do not need to plan density uplifts where they would be out of character82; and that local need should be met ‘as far as possible’.83

14.11The Government’s annual target of 300,000 homes per annum, has increased to at least 370,000 homes per annum, specifically recognising that London has fallen well behind meeting its housing needs:-

More important than setting a deeply ambitious but credible target is of course meeting it. The Government is clear that recent delivery in London has fallen well short of what is needed, and that is why we are committed to working in partnership with the Mayor of London and the GLA to turn this around - including by optimising density and through Green Belt review84

14.12The Government’s proposal to delete the 35% urban uplift of housing need85 in the nation’s 20 most populous urban centres, of which London is one, could have been a concern, but the proposed method for Lewisham (2,470 homes per annum), requires more housing than the current London Plan requirement of 1,667 homes per annum, an increase of 803 homes every year.

14.13With this change Footnote 28 has been deleted (“In doing so, strategic policies should promote an effective use of land and optimise site densities in accordance with section 11. This is to ensure that homes are built in the right places, to prioritise brownfield and other under-utilised urban sites, to utilise existing infrastructure, and to allow people to live near the services they rely on, making travel patterns more sustainable.”) This has been replaced by the clear objective to prioritise brownfield land with new paragraph 122(c), a more potent policy.

14.14The consultation text reiterates the Ministerial Statement that new housing contributes to economic growth and “maximising delivery in urban areas” will also make the most of our transport hubs, support the objectives of brownfield-first and gently densifying urban areas, including building upwards where appropriate.

78 NPPF (2024) para 61

79 NPPF (2024) para 76

80 NPPF (2024) 122(c).

81 NPPF (2023) para 60

82 NPPF (2023) para 130

83 NPPF (2023) para 60

84 MHCLG Blog 5th August 2024 (Our Plan to Get Britain Building Again

85 NPPF (2024) para 62

Lewisham’s housing need - the presumption in favour of sustainable development

Summary

14.15Lewisham cannot meet its 5YHLS and has delivered an average of 730 homes per anum across the last 3 years which is 51% of its London Plan target, and 29.5% of the new standard method published by the government in 2024.

14.16The tilted balance exists in Lewisham, which means that planning permission should be granted, without delay, unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole. For the reasons set out in this statement, we believe that the benefits delivered by the Proposed Development would substantially outweigh the impacts.

Housing Need

14.17The principle of development of the Site for housing is accepted. The Proposed Development is consistent with the national, regional and local policies which expect housing at higher densities to be promoted in locations that are well connected to jobs, services, infrastructure and amenities by public transport, walking and cycling, including car parks.

14.18The Framework sets out policies to significantly boost the supply of homes (paragraph 60). It requires local plans to meet the full, objectively assessed needs for market and affordable housing. It requires Council’s to identify and update annually a supply of specific deliverable sites to provide a minimum of five years’ worth of housing against the adopted strategic housing requirement.

14.19At a regional level, London is not meeting its housing demand. There is a chronic and acute housing need in London and Lewisham

14.20The London Plan does not meet the housing need for London, identified in 2017 as a minimum of 66,000 additional homes per year for at least twenty years. In October 2019, the London Panel Inspectors reported that the London Plan failed to meet, by some margin, the identified annual need of 66,000 homes. The Panel reported their major concern that the housing targets were so far below the assessed need, they considered whether the London Plan should be paused for further work to be done; that it did not meet the tests of soundness; and so, should be withdrawn. Despite these concerns, the Panel also recognised that there would be negative effects if the Panel delayed adoption of the Plan. The Panel therefore urged boroughs to use all the tools at their disposal to ensure that homes are actually built. They adopted a 10 year housing target of 52,285 homes per annum on the basis that it would be higher than the existing London Plan.

14.21The Mayor of London’s Dataset outlines that residential completions over the last 5+ years (2017/18 to 2022/23) have fallen short of the minimum threshold London has consistently failed to meet its housing delivery targets.

14.22The Mayor of London’s completion rates for the last ten years are set out in Table 14-1 below, demonstrating a failure to meet housing need for all but two years.

Table 14-1 GLA Housing Completions

14.23The current targets are set to be replaced after three years at most and sooner if an early review is conducted as requested by the Secretary of State. However, it is clear that the current targets are considered too low by the Government and are significantly below current guidance. The targets will need to be updated within three years or earlier and are likely to need to be increased significantly.

14.24At a local level, the Council’s minimum housing requirement is derived from the London Plan Table 4.1. This equates to 16,670 homes over the ten year period (2019/20 to 2028/29) which equates to at least 1,667 homes per year.

Historic Delivery in Lewisham

14.25It is important to consider the historic rate of housing completions by the Council as this provides a benchmark for future forecast completion rates. It informs a judgement whether new annual minimum housing requirements are achievable. For example, it is unusual for Councils to double their historic completion rates for a sustained 5-year period. Planning policy, land acquisition, build programmes and political constraints normally restrict this from happening.

14.26The Council’s 5 Year Land Supply and Housing Trajectory was published in December 2021. The results since 2018 are summarised below in Table 14-2, demonstrating a continued deficit against London Plan targets.

14.27The provision of 119 residential homes in the Detailed Component, and up to 1,600 residential homes in the Outline Component, will make a major contribution to alleviating a clear and pressing need for new homes in Lewisham, including affordable homes. The Proposed

Table 14-2 The Council’s Housing Completions

Development will contribute towards meeting the minimum London Plan targets. The provision of co-living and student accommodation will further contribute towards meeting this need.

14.28There is a clear need for housing and the proposals will contribute to meeting this need. In accordance with the Framework, we consider that substantial weight should be given to the value of using the Site for new homes. We consider that the Proposed Development complies with London Plan Policy GG4, H1 (London Plan Table 4.1), SD1 (London Plan Table 2.1), and LCS Objective 2.

Lewisham Housing Delivery Test

14.29In December 2023, the Government published the 2022 Housing Delivery Test measurement for all plan making authorities in England. It showed that over the preceding 3 years, Lewisham delivered only just above half its housing target. This is confirmed in Table 14-3.

Table 14-3 Lewisham Housing Delivery Test Measurement (December 2023)

14.30Where authorities performance is below 75% of the housing target, they must prepare a Housing Action Plan; plan for a 20% buffer in the 5 year housing land supply; and the Framework presumption in favour of sustainable development applies.

14.31The Action Plan sets out the causes for the shortfall as including development industry underperformance, applicants amending consents, the time it takes to undertake enabling/infrastructure works, Brexit, and Covid.

14.32To help boost delivery, the Council proposes the following:

▪ The Major and Strategic Projects Team will focus on major development schemes.

▪ PPAs to aid the pre-app process.

▪ Given the ‘Presumption’, the Council will be taking proactive actions during its decision taking.

▪ The Council will ensure that sites coming forward for consideration are granted consent when they are considered to be genuinely deliverable schemes (ideally within 3 years).

▪ Site allocations in the draft Local Plan should maximise opportunities for housing delivery.

▪ The Council considers that the lack of delivery is not due to a lack of housing land supply.

The Housing Contribution of the Application

14.33It is agreed that the residential floorspace proposed will make a significant contribution to Lewisham’s targets as set out in the current Development Plan. Moreover, the Proposed Development will comprise an integral component of the R19 Site Allocation LCA 2. National, regional and local planning policy recognises the contribution that town centre housing will make to the vitality and viability of Lewisham.

14.34Given the scale of the Proposed Development, it is neither appropriate nor necessary to fix a maximum number of homes in the Outline Component as this would limit the inherent flexibility of the Outline Component and undermine the purposes of submitting a hybrid planning application.

14.35Any reference to housing and student accommodation numbers in the Outline Component is indicative only and is submitted for the purposes of informing the technical assessments that have been prepared in support of the Application and is not to be controlled by the planning permission. A maximum GEA sqm residential area is proposed as a control and set out in the Development Specification which is submitted with the Application

14.36Nevertheless, we believe that it is helpful to indicatively report how many homes the Application might deliver, including the student accommodation and Co-Living homes’ contribution towards housing needs.

14.37Site wide, the Proposed Development could deliver up to 1,719 new homes and up to 661 student bed spaces (albeit the exact number of homes will be determined through subsequent reserved matters applications. This is in addition to 445 Co-Living homes.

14.38For reference and to demonstrate the contribution that this development will have towards meeting London’s housing need, we enclose at Table 14-4 an indicative estimate of the C3 housing equivalence that the Proposed Development will deliver using the ratios set out in the London Plan.

14.39London Plan paragraph 4.1.09 defines the student housing to C3 homes ratio as 2.5:1; and a 1.8:1 ratio for Co-Living to C3 housing.

Table 14-4 Site wide equivalent C3 housing provision

14.40This demonstrates that the indicative number of an equivalent of C3 homes proposed is 2,230 homes, which is a significant benefit ofthe Application, particularly given theshortfall that exists within the borough at present.

14.41This quantum addresses the housing capacity identified by Site Allocation LCA 2 of 2,150 homes.

Affordable Housing

14.42This section of the Planning Statement sets out the national, regional and local policy position in relation to Affordable Housing.

National Planning Policy and Guidance

14.43The Framework provides the national context for planning in England, including Central Government’s housing policy objectives and is an important material consideration in the determination of all planning applications.

14.44The Framework establishes that plans and decision-taking should ensure delivery of a wide choice of high-quality homes for a range of needs for today and in the future (paragraph 8(b)). An aim of the Framework is to reduce reliance on scheme-specific viability evidence, however it is recognised that there will be circumstances where this is necessary, and that the decision maker should have regard to the circumstances in the case (paragraph 58).

Regional Policy and Guidance

14.45The London Plan provides the overarching strategic planning framework in London. In respect of affordable housing, Policy H4 (Delivering Affordable Housing) states that the strategic target is for 50% of all new homes to be affordable. It requires (inter alia):

“Major developments which trigger affordable housing requirements to provide affordable housing through the threshold approach (Policy H5 Threshold approach to applications) using grant to increase affordable housing delivery beyond the level that would otherwise be provide”

14.46Policy H5 (Threshold Approach to Applications) confirms the circumstances where schemes can follow the Fast Track route, meaning a viability assessment and late-stage viability review mechanism should not be required. Where schemes fail to meet the requirements set out in Part C of Policy H5 the Viability Tested Route is required to be followed (Part F).

14.47The threshold level of affordable housing for residential development is initially set at a minimum of 35%, or 50% for public land or Strategic Industrial Locations, Locally Significant Industrial Sites and Non-Designated Industrial Sites appropriate for residential use in accordance with Policy E7 industrial intensification, colocation and substitutions where the scheme would result in a net loss of industrial capacity. Footnote 59 sets out further details on the applicability of the 50% threshold:

“However, it is recognised that some surplus utilities sites are subject to substantial decontamination, enabling and remediation costs. If it is robustly demonstrated that extraordinary decontamination, enabling or remediation costs must be incurred to bring a surplus utility site forward for development, then a 35 per cent affordable housing threshold

could be applied, subject to detailed evidence, including viability evidence, being made available”.

14.48The Viability Tested Route requires detailed supporting viability evidence to be submitted in a standardised and accessible format as part of the application for scrutiny by the determining authority and their advisors to ascertain the maximum reasonable level of affordable housing using the methodology and assumption set out in the London Plan and the Affordable Housing and Viability SPG.

14.49Policy H6 (Affordable Housing Tenure) sets out the required tenure split to meet the Threshold Approach to Viability as:

▪ A minimum of 30% low cost rented homes, as either London Affordable Rent or Social Rent, allocated according to need and for Londoners on low incomes

▪ A minimum of 30% intermediate products which meet the definition of genuinely affordable housing, including London Living Rent and London Shared Ownership

▪ The remaining 40% to be determined by the Borough as low-cost rented homes or intermediate products based on identified need

14.50There is flexibility for alternatives for this to be agreed with the determining authorities where supported by robust evidence.

14.51Policy H10 advises on the range of considerations that need to be considered in determining the appropriate mix of unit size, this includes the nature and location of the site and the aim to optimise housing potential on sites. Supporting text to Policy H10 confirms that flexibility should be applied in determining unit size mix for a scheme.

GLA Affordable Housing and Viability SPG (2017)

14.52The Affordable Housing and Viability SPG sets out the Mayor’s preferred approach to affordable housing delivery and undertaking viability assessments mirroring many of the requirements in the LP and providing additional details. Schemes should be designed to maximise tenure integration and affordable housing units should have the same external appearance as private housing. The need for separate provision of entrances and circulation spaces for different tenures is recognised particularly in higher density schemes (paragraph 1.1.18).

14.53The SPG provides guidance on the suggested approach to both early and late-stage review mechanisms including worked examples and formulas to be included within s106 agreements where appropriate.

GLA Affordable Housing LPG and GLA Development Viability LPG (Consultation Drafts –May 2023)

14.54New London Planning Guidance was published for consultation in May 2023 on Affordable Housing and Development Viability. They provide supplementary guidance on the threshold approach and other London Plan policies related to affordable housing.

14.55Both documents, once adopted, would supersede the adopted GLA Affordable Housing and Viability SPG (2017).

14.56The new LPG’s do not propose to fundamentally change the existing provisions or approach to viability and affordable housing within current guidance.

14.57The draft Affordable Housing LPG does however confirm that the Mayor’s strong preference is for the delivery of Social Rent homes, which are best placed to address current housing need (paragraph 3.1.2).

Local Policy

Adopted Local Plan

14.58The Councils LCS Policy 1 sets out a baseline target of 50% of the new homes built over the plan period to be affordable. Part 4 of the policy states that the starting point for negotiations will be a contribution of 50% affordable housing on qualifying sites across the borough, subject to a financial viability assessment.

R19

14.59The Council’s R19 Policy H03 (Part A) seeks to maintain the 50% overall target, achieved through delivering affordable housing through the threshold approach set out in Policy H5 the London Plan.

14.60For large sites (major developments), Part E of Policy H03 sets out that development proposals must deliver the maximum amount of genuinely affordable housing, taking into account a number of considerations, including:-

▪ Their contribution to the Borough’s strategic affordable housing target, based on habitable rooms, subject to viability;

▪ The need for provision of a mix of housing tenures, provided on the basis of a tenure split of 70 per cent genuinely affordable (social rent or London Affordable Rent) and 30 per cent intermediate (London Living Rent or shared ownership);

▪ Availability of public subsidy; and e. Other planning benefits that may be achieved, having particular regard to the delivery of the spatial strategy for the Borough.

Affordable Housing Proposal

14.61Owing to the exceptional abnormal costs associated with bringing the Site forward for redevelopment, and in line with Policy H5 of the London Plan, the Application will be subject to the Viability Tested Route.

14.62As such, a Financial Viability Appraisal (FVA) is submitted as part of the Application in support of the Proposed Development, which will be subject to subsequent review and agreement with the Council.

14.63At a national level, the Framework acknowledges that there may be specific circumstances where scheme-specific viability evidence is needed (paragraph 58).

14.64Policy H6 of the London Plan notes that flexibility in the preferred tenure split can be applied and agreed with the determining authorities where it is supported by robust evidence. Similarly, Policy H10 of the London Plan notes that flexibility should also be applied in determining unit size mix.

14.65Overall, there is a policy framework in place that enables the individual circumstances of this Site to be considered when determining the level of affordable housing that could be supported when weighed against other policy requirements/priorities including creating a new town centre, permeability, provision of significant new open space and connections, delivery of nonresidential uses and environmental and sustainability objectives.

Housing Mix

14.66This section of the Planning Statement sets out the relevant planning policy in relation to housing mix.

London Plan

14.67London Plan Policy H10 considers that schemes should generally consist of a range of unit sizes. To inform the unit mix, applicants and decision-makers should have regard to robust local evidence on need; the range of housing need and demand identified by the 2017 London Strategic Housing Market Assessment; and the aim to optimise housing potential on sites.

14.68Policy H10 recognises that well-designed one-and two-bedroom homes in suitable locations can attract those wanting to downsize from their existing homes, and this ability to free up existing family stock should be considered when assessing the unit mix of a new build development.

14.69The London wide SHMA (2017)identifies a requirement for new homes across London (2016 to 2041) of 55% 1 bed; 16% 2 bed; 14% 3 bed and 15% 4 bed+.

14.70London Plan Policy H10 explicitly recognises that the nature and location of a site is an important consideration, with a higher proportion of one and two bed units generally more appropriate in locations which are closer to a town centre or station or with higher public transport access and connectivity. We consider that these characteristics apply to the Site.

Lewisham Local Policy

14.71Policy 1 (part 5) of the LCS (2011) seeks to ensure a mixed tenure and promotion of mixed and balanced communities. Policy 1 (part 6) sets out that family housing (3+ bedrooms) will be expected as part of any new development with 10 more dwellings.

14.72Policy 1 (part 8) outlines a number criteria that must be considered when determining an appropriate mix of dwellings within a development as follows:-

a. the physical character of the site or building and its setting

b. the previous or existing use of the site or building

c. access to private gardens or communal garden areas for family dwellings

d. the likely effect on demand for car parking within the area

e. the surrounding housing mix and density of population

f. the location of schools, shops, open space and other infrastructure requirements.

R19

14.73Policy H01 (part D) of the R19 outlines that development proposals for housing must demonstrate how they will contribute to and support inclusive and mixed developments and communities across Lewisham.

14.74Policy H01 (part E) of the R19 sets out that development proposals must deliver an appropriate mix of housing within the site and the local area. It states that the appropriate mix should be established on a case-by-case basis having regard to the site’s location and character, the nature of the development proposed, along with a series of other considerations, which includes:

▪ The need for provision of family housing units (3+ bedrooms), with a reasonable proportion of family units to be delivered on major developments of 10 or more dwellings; and

▪ The delivery of liveable and sustainable neighbourhoods that are appropriately supported by community facilities and other infrastructure.

14.75Policy H01 (part F) of the R19 outlines that development proposals comprising solely of studios and/or 1 bedroom, 1 person units, or those that will result in an overconcentration of 1 or 2 bedroom units on an individual site, will be refused unless it can be suitably demonstrated that the housing provision:

a. Is located in an area with higher Public Transport Access Levels (i.e. PTAL 3-6); and

b. Forms part of a larger development, or is located within an area for which a masterplan has been adopted or endorsed by the Council, that includes provision for a mix of unit sizes, including a reasonable amount of family-sized units (3+ bedrooms); or

c. Is sited in a local area that consists predominantly of family housing units, and would therefore provide for a balance in the mix of unit sizes in the area; or

d. Is the only housing format deliverable owing to site size, site configuration or other development constraints, and where a studio unit is proposed, it is of an exceptional design quality.

14.76In terms of promoting housing choice, Policy H01 (part G) of the R19 sets out that to help ensure that local residents and other people have access to a wide range of suitable housing provision, the Council will:

a. Seek that development delivers a wide range of genuinely affordable and other housing products, including market housing, to meet the needs of households of different sizes and income levels;

b. Support development proposals that meet the needs of specific groups including: families with children, older people, people with disabilities, students and vulnerable people;

c. Promote and support innovative housing designs, such as modular housing, particularly where these address acute or specialist local housing needs;

d. Support appropriate proposals for self-build or custom build housing, and seek to identify land to help facilitate such development where a need is clearly established; and

e. Encourage developers and agents to market new housing units for sale or rent to existing local residents and people with a local connection before advertising them more widely to others.

Assessment

14.77The Applicant has sought to deliver a genuine mix of unit types across the Proposed Development to achieve a balanced community whilst being informed by a number of other significant considerations including viability, the unique circumstances of the Site and the Site’s location in close proximity to two rail stations in a highly accessible part of London.

14.78Residential accommodation is therefore proposed to be provided within a range of unit types The proposed mix is considered to be acceptable taking into account the wider strategic requirements of the Council and the GLA and the need to incentivise delivery.

14.79The C3 housing mix within the Detailed Component (the first phase of development) is known and includes a mix of homes and uses aimed at achieving quick delivery as part of this complex multi-phased development. The housing within the Detailed Component is contained within Building N2.

14.80The proposed mix for the C3 Detailed Component is set out in Table 14-5 below.

Table 14-5 Detailed Component C3 Proposed Housing Mix

14.81The Detailed Component includes a broad mix of homes including studios, 1 bed, 2 bed and 3 bed homes therefore complying with the regional and local planning policy objectives to deliver a mix of housing types to assist in creating balanced communities.

14.82Policy H10 of the London Plan recognises the role that well-designed one-and two-bedroom homes in suitable locations can play particularly in freeing up existing family stock. The Site’s location in close proximity to an overland railway station and a DLR station means it is highly accessible and an entirely appropriate location for smaller sized units (studios, 1 and 2 bed units).

14.83Priority has been given to the provision of 1 and 2 bed units with 46% and 39% of the overall provision within Phase 1a for those unit sizes. These unit sizes play a vital role in meeting local housing need, as demonstrated in Figure 5-7 in the Housing Statement, single person households and households with two or more adults are projected to increase significantly and significant consideration should be applied to that.

14.84The Detailed Component (which also includes the 445 home Co-Living building at N1) represents the first phase of development and will play a vital role in helping to create a place, acting as the front door to the Site and operating as a standalone phase whilst the remaining

phases are built out. Inevitably, it will take time for the development to create a place and for the full provision of open space, for instance, to come forward. Therefore, a lower level of family sized homes is proposed in this initial phase.

14.85For the Outline Component of the Application, the housing mix is illustrative, details of which will be secured through subsequent Reserved Matters Applications.

14.86Crucially the proposed unit mix must be considered in the context of the site-specific characteristics i.e. the appropriate housing need of the borough, where different types of homes are best accommodated and constraints (including viability and maximising the affordable housing delivery). There is no other site of this nature and size (and representing this level of transformative opportunity) and this must be taken into account when considering housing mix policy requirements. Flexibility must be applied to enable an overarching planning balance to be achieved.

Viability

14.87Residential development performs an integral role for the development economics of the proposal. Unlike other proposals which are subject to cleared, or low intensity land uses, R19 LCA 2 is an extremely complex site.

14.88There are numerous existing commercial rights which have been acquired across the site over recent years; 3rd party interests; legal interests across multiple levels; and physical overlays of different buildings withdifferent land interests and structural grids. These existing constraints represent significant abnormal costs.

14.89Further abnormal costs are associated with the phased nature of delivery, a strategy necessary to avoid extensive wholescale demolition which could adversely impact town centre vitality and viability. The scheme must also deliver appropriate social and physical infrastructure to serve its residents and the wider community.

14.90As evidenced within the Financial Viability Assessment report which accompanies the planning application, the proposed development is complex and requires significant investment in the town centre, in order to deliver the high quality homes which will address the diverse housing needs of the borough as well as improving the public realm.

14.91In addition to housing, the proposed development will deliver new and improved retail with more than 40,000 sqm of non-residential floorspace increasing employment opportunities which will generate gross value added of between £30m and £160m per year. Furthermore, indirect spending arising from new employees and residents will be up to £28.7-£31.8m per year. The Proposed Development will generate in the region of approximately £27 million of CIL, in addition to s106 contributions.

14.92Whilst the borough-wide target of 50% affordable homes is recognised, every effort has been made to achieve this, the financial constraints mean that this target is not deliverable 20% of the residential floorspace will be affordable, with these homes crucial to providing much needed housing to households on the councils housing register. Alongside the affordable homes, a wider package of local benefits including payment in lieu and planning obligations will be delivered.

14.93The Applicant has adopted optimistic approaches to both values / value creation and delivery costs, only reaching a positive appraisal output in the sensitivity testing. Notwithstanding the challenges, the appraisal outcome indicates that a deliverable scheme is achievable, albeit with the appraisal outcome still falling below the target profit levels.

14.94The appraisal outcomes indicated within this report demonstrate that the proposal of 20% affordable homes (by residential floorspace) is well in excess of that which would typically be justified by viability alone. The Applicant’s proposal of this level of affordable homes, therefore, represents a substantial benefit and will enable delivery of much needed affordable homes in the borough.

14.95The decision to deliver 20% of the residential floorspace as affordable has been taken after careful consideration of baseline scheme viability and opportunities to improve this. The Applicant’s approach will deliver significant housing benefits for the local community, although the proposed development will be subject to review mechanisms, which will capture opportunities for the borough to secure an uplift of affordable homes if scheme viability improves over delivery period.

14.96Given the above, the proposed affordable homes should be considered a significant benefit of the application proposals and given substantial positive and material weight in the planning decision making process.

15Living Uses – Co-Living

15.1 Within this section, we assess the Co-Living accommodation proposed within the Detailed Component of the Application.

Proposal

15.2 The Application proposes 445 Co-Living homes (sui generis).

15.3 The Co-Living accommodation is proposed within Building N1, which will be delivered as part of Phase 1a.

Policy

London Plan and Mayor’s LPG

15.4 The London Plan recognises the pressing need for more homes in London. Policy GG4 seeks to deliver the homes that Londoners need, stating that those involved in planning and development must create mixed and inclusive communities, with good quality homes that meet high standards of design and provide for identified needs, including for specialist housing.

15.5 The Mayor supports the provision of large-scale Co-Living developments in London at Policy H16. In this context, purpose-built large-scale Co-Living developments provide sui generis non-self-contained market housing. Supporting paragraph 4.16.2 of the London Plan explains that such developments are not restricted to particular groups by occupation or specific need such as students, nurses or people requiring temporary or emergency accommodation proposed by speciality providers.

15.6 Importantly, the Mayor specifically recognises that Co-Living (or Shared Living) schemes count towards meeting housing targets on the basis of a 1.8:1 ratio, with one point eight bedrooms/units being counted as a single home. The Application proposes 445 homes in Building N1, meaning that the proposals deliver the equivalent of 247 residential units. This makes a significant contribution to the housing delivery targets identified within the London Plan.

15.7 Co-Living is an innovative form of private rented residential development that contributes towards the housing targets, mix and choice in the local area. The Housing Needs Assessment, prepared by Quod in support of this planning application, provides an overview of the current housing market, explaining that in the last few years there has been a rise in the proportion of London residents turning to the private rented sector to fulfil their accommodation needs. This is also coupled with a decline in the quality of PRS market stock. The Quod report concludes that shared living offers a high-quality alternative to other PRS products and that there has been a increase of c. 5,000 homes opting to rent. It is estimated that there is a demand pool for Co-living in Lewisham, with a projected uplift of c.15,000 single person households in the borough by 2043.

15.8 Policy H16 (Large-Scale Purpose-Built Shared Living) of the London Plan provides the Mayor’s policy guidance for Co-Living developments. It sets out that Co-Living will be acceptable when a number of criteria can be demonstrated, as set out in Table 15-1 below.

Table 15-1 London Plan Policy H16 Compliance

Requirement

It is of good quality and design

It contributes towards mixed and inclusive neighbourhoods

Application Response

The Application achieves high-quality design and has been carefully developed to respect and enhance the local context. The internal layouts for the development have been subject to a rigorous design process to ensure the private units and associated shared communal areas are sufficient in size and are of highquality design.

The design of the development has been an iterative process, in collaboration with the Council and DRP.

In addition, the Applicant’s design and consultant team has utilised its significant relevant experience and key learnings from other operational sites.

Please see the supporting Design and Access Statement for further details.

Co-Living accommodation provides a higher-quality alternative to PRS stock of declining quality. The provision of Co-Living homes, together with the wide range of other uses and housing typologies within the Application, including affordable homes, will attract a diverse range of individuals and families that will contribute towards a mixed and balanced community, with a diverse neighbourhood within the local area in particular. The Co-Living model will foster community engagement and meaningful relationships between residents and encourage interaction with the existing community through social and educational events. Within Building N1 itself, the focus on shared communal space for all residents provides opportunities for residents to integrate into a single community. The community, co-working, gym, lounge and dining spaces will allow residents to eat, drink, socialise and work together, creating an inclusive neighbourhood.

It is located in an area well-connected to local services and employment by walking, cycling and public transport, and its design does not contribute to car dependency

It is under single management

Its units are all for rent with minimum tenancy

The Site is located in a well-connected area with a PTAL of 6b. The Co-Living accommodation will be car free (save for Blue Badge) meaning that residents will not own private cars ensuring there is no contribution to car dependency.

The Co-Living will include cycle parking in line with the GLA’s requirements.

The Co-Living accommodation will be under single management. A Co-Living Management Plan is submitted in support of the Application.

The tenancy lengths for the Co-Living development will be a minimum of 3 months.

Requirement Application Response

lengths of no less than three months

Communal facilities and services are provided that are sufficient to meet the requirements of the intended number of residents and offer at least:

a) Convenient access to communal kitchens – In addition, each of the 445 Co-Living units is also equipped with a compact kitchenette with a hob and fridge for private cooking.

b) Outside communal amenity space (roof terrace and/or garden) –A total of 1,693sqm of external communal amenity space is provided in the form of high-quality landscaped roof terraces, designed for residents to relax, exercise, socialise, cook, eat and create.

c) Internal communal amenity space (dining rooms, lounges)Residents have access to a range of internal communal spaces, including shared kitchen and dining lounge areas, bookable kitchen and dining rooms, creative recording studio, co-working and agile working spaces, collaboration spaces, bookable meeting rooms, residents social hub, games breakout area, sitting/reading rooms, a cinema room, gym, well-being studio, laundry room and flexible events space.

d) Laundry and drying facilities – Laundry facilities are provided

e) A concierge - A concierge will assist in the management of the building.

The private units provide adequate functional living space and layout, and are not self-contained homes or capable of being used as self-contained homes

The Co-Living units will be comfortable yet functional with an average room size of 22.5 sqm (including wheelchair accessible units). The average unit size for non-wheelchair accessible units is 20.5 sqm. This is larger than the GLA’s prescribed minimum target (18 sqm). The units will be fully furnished with an en-suite, compact kitchenette, double bed, separate seating and homeworking spaces.

The design of the units also incorporates the following elements to ensure adequate functional living space:

▪ The floor to ceiling heights of the units is 2,550mm in general;

▪ Each unit contains a minimum of 1.2 m3 of storage space;

▪ The glazing size and specification has been optimised to maximise natural daylight within the units.

A management plan is provided with the application

It delivers a cash in lieu contribution towards conventional C3

A detailed Co-Living Management Plan is submitted alongside the Application. Further details in respect of the management strategy can be conditioned requiring approval prior to occupation.

Given the scale of the site and the importance of affordable housing delivery, the co-living component will contribute towards

Requirement

affordable housing. Boroughs should seek this contribution for the provision of new C3 offsite affordable housing as either an: a) upfront cash in lieu payment to the local authority, or b) in perpetuity annual payment to the local authority In both cases developments are expected to provide a contribution that is equivalent to 35% of the units, or 50% where the development is on public sector land or industrial land appropriate for residential uses in accordance with Policy E7.

Application

Response

the delivery of conventional social rented and intermediate homes elsewhere within the site. This approach is equivalent to a cash in lieu option but offers the benefit of direct and certain on-site affordable housing delivery.

15.9 On the basis of the above, the Proposed Development fully accords with London Plan Policy H16.

15.10The GLA has recently adopted its London Planning Guidance on Large-Scale, Purpose-Built Shared Living (February 2024). Building N1 has been designed with the LPG in mind. Of particular note, Building N1:

▪ Provides rooms which are larger than the minimum prescribed in the LPG;

▪ Exceeds the LPG’s recommended benchmark for internal community amenity space provision;

▪ Exceeds the LPG’s recommended benchmarks for the provision of internal communal facilities (including kitchen areas; dining space; laundry and drying facilities);

▪ Exceeds the LPG’s recommended benchmark for cycle storage; and

▪ Exceeds the LPG’s recommended benchmark for external community amenity space provision.

15.11Further information relating to Building N1 in the context of the LPG is provided in the Design and Access

Lewisham Local Plan and Emerging Policy

15.12The adopted LCS (2011) does not include specific reference to Co-Living as a residential typology. In addition, neither the LTCLP (2014) or the LDMLP (2014) includes reference to Co-Living. This is not unsurprising given the dates of the three documents.

15.13However, the R19 aligns itself with the London Plan, confirming that the Council’s direction of travel is supportive towards Co-Living (or Shared Living) where, among other points, there is

an identified local market demand, where the development will not lead to a proliferation of CoLiving and where it will not compromise the delivery of conventional housing.

15.14Paragraph 7.75 of the R19 recognises that housing with shared facilities contributes to meeting housing need in London. Paragraph 7.75 goes on to set out that there does, however, remain a need for conventional housing in the Borough and as such development proposals for largescale purpose-built Co-Living will only be supported where there is an identified local market demand and where it will not lead to a proliferation of Co-Living locally. These tests are contained within Draft Policy H08 Part D, which states that development proposals for largescale purpose-built Co-Living accommodation (sui generis) will be permitted where a number of criteria can be demonstrated. The majority of the Draft Policy H08 Part D tests align to the London Plan Policy H16 tests and for completeness are set out in Table 15-2 below.

Table 15-2 R19 Policy H08 Part D Compliance

Requirement Application Response

There is an identified local market demand for the type of housing proposed and the development will not lead to a proliferation of this type of development in an area and the Borough which will compromise the delivery of conventional housing

The Quod Housing Statement confirms Lewisham’s population is projected to increase by 27,000 over the next 19 years with growth is forecast to be concentrated amongst smaller households (comprising singles and childless couples).

The existing housing stock in the borough is typically characterised by 2 and 3 bed properties, however the existing stock will not address the demand for smaller one person households based on the projected figures set out in Figure 5-7 of the Housing Statement.

In addition to this the PRS (typically characterised by young professionals and key workers in their 20s and 30s) saw the greatest increase between 2011 and 2021 (+5,000 households). The PRS is under significant strain, with rents increasing at unprecedented and unsustainable rates, and with high levels of over-occupation. The Proposed Development will go some way to addressing these housing issues.

Should Planning Permission be granted for the Application it will not lead to a proliferation of Co-Living developments in this part of the Borough, or within the Borough as a whole. Currently, the only Co-Living in the Borough is at Lewisham Gateway (119 units). Therefore, the delivery of Building N1 will not compromise the delivery of conventional housing.

Private units within the development are demonstrably not selfcontained homes in the C3 Use Class or capable of being used as selfcontained homes

The units within Building N1 will be Co-Living homes (sui generis). The units will not be Class C3 residential units, or be capable of being Class C3 residential units. The management of the building will ensure that they remain operating as Co-Living units.

Requirement Application Response

There is well-integrated provision of communal facilities and services sufficient to meet the requirements of the intended number of occupiers

The design of Building N1 has been carefully designed to consider its future residents. It has been designed to reflect:

▪ Industry best practice, including the most successful currently operating schemes;

▪ Lessons learned from the Applicant’s consultant team, including from Urban Bubble, one of the leading Co-Living operators in the UK today, who manage sites at Sunday Mills, Earlsfield; Florence Dock, Wandsworth; and The Palm House, Harrow (all under their Folk Living brand).

▪ Standards and guidance contained within the GLA’s recently adopted London Planning Guidance on Large-Scale, PurposeBuilt Shared Living (February 2024).

As a result of this considered approach, the design of Building N1 ensures that there is a well-integrated provision of communal facilities and services.

The development is appropriately located and of a high quality design.

The development will be under single management, suitably managed and maintained over its lifetime, as evidenced by a management plan

All units are available to rent, with minimum tenancy lengths of no less than 3 months

The Site is located in a well-connected area with a PTAL of 6b. This is considered to be a suitable location for Co-Living (in line with London and Lewisham policy).

The design of Building N1 is of a high-quality architectural design, both internally and externally. The collaboration of two highquality, award winning architects demonstrates the Applicant’s commitment to design quality.

The Application has also been prepared following extensive public and stakeholder engagement, including with Council officers, the Council’s DRP, the GLA and Design Champions. The design of Phase 1a, including Building N1, has formed a key part of the public and stakeholder engagement, resulting in iterative design review. This has allowed the final design to be reflective of comments received.

The Co-Living accommodation will be under single management. A Co-Living Management Plan is submitted in support of the Application.

The tenancy lengths for the Co-Living development will be a minimum of 3 months.

Requirement Application Response

A cash-in-lieu contribution is made towards affordable housing in the C3 Use Class

Given the scale of the site and the importance of affordable housing delivery, the co-living component will contribute towards the delivery of conventional social rented and intermediate homes elsewhere within the site. This approach is equivalent to a cash in lieu option but offers the benefit of direct and certain on-site affordable housing delivery.

15.15The adopted Lewisham policy documents do not include specific reference to Co-Living, however, on the basis of the above, the Proposed Development fully accords with the R19.

16Living Uses – Student Accommodation

16.1 Within this section, we assess the student accommodation proposed within the Outline Component of the Application.

Proposal

16.2 The Application proposes student accommodation (sui generis) in the following locations:-

▪ Building S1: 107 studios and 252 cluster beds

▪ Building S4: 302 cluster beds

Policy

London Plan

16.3 The Mayor is clear in his support for Purpose-Built Student Accommodation (‘PBSA’) in London.

16.4 The London Plan sets out that London’s higher education providers make a significant contribution to the economy and labour market and, as such, their attractiveness and potential growth should not be compromised by inadequate provision for new student accommodation (Paragraph 4.15.1).

16.5 The London Plan goes on to explain that the housing need of students in London, including in PBSA, is an element of the overall housing need for London, determined in the 2017 London SHMA (Paragraph 4.15.1).

16.6 The overall strategic requirement for PBSA in London has been established through the work of the Mayor’s Academic Forum, and a requirement for 3,500 PBSA bed spaces to be provided annually over the Plan period (Paragraph 4.15.2).

16.7 Policy H15 is the relevant policy in the London Plan to assess the acceptability of the proposed PBSA. Policy H15 sets out that boroughs should seek to ensure that local and strategic need for PBSA is addressed, subject to a number of criteria, as summarised in Table 16-1 below.

Table 16-1 London Plan Policy H15 Compliance

Requirement Application Response

At the neighbourhood level, the development contributes to a mixed and inclusive neighbourhood

The provision of PBSA, together with the wide range of other uses and housing typologies within the Application, including affordable homes, will attract a diverse range of individuals and families that will contribute towards a mixed and balanced community, with a diverse neighbourhood within the local area in particular.

Requirement

Application Response

The Application is a significant, mixed-use, multi-phased development which will contribute to the town centre and beyond. The PBSA element is an integral part of this.

The use of the accommodation is secured for students

Student, for the purposes of Policy H15, is defined in the London Plan as a person following a course in higher education as recognised by the Office for Students.

The accommodation proposed will be secured for the use of students during term time (as required by the London Plan).

The majority of the bedrooms in the development including all of the affordable student accommodation bedrooms are secured through a nomination agreement for occupation by students of one or more higher education provider

The maximum level of accommodation is secured as affordable student accommodation as defined through the London Plan and associated guidance

The accommodation provides adequate functional living space and layout

The majority of the bedrooms will be secured through a nomination agreement with a higher education provider.

Boroughs, student accommodation providers and higher education providers are encouraged to develop student accommodation in locations well connected

Given the pressing need for social rent and intermediate homes in the borough, the PBSA in the proposed scheme will not include affordable student accommodation, and will instead utilise the value generated to maximise the affordable conventional homes.

The PBSA is part of the Outline Component of the Application and as such the detail of the PBSA will be set out within the subsequent reserved matters process.

However, the Application includes a framework to ensure that the reserved matters details will enable an appropriate design to come forward for the PBSA. This will include internal design and layout considerations to ensure that functional living spaces are provided within the PBSA (and all residential buildings).

The Site is located in a well-connected area with a PTAL of 6b. This location for PBSA is considered to be highly suitable in this context.

Requirement Application Response to local services by walking, cycling and public transport, as part of mixed-use regeneration and redevelopment schemes

16.8 On the basis of the above, whereby the Applicant will be seeking nomination agreements with HEP, the Application fully accords with London Plan Policy H15.

Lewisham Local Plan and Emerging Policy

16.9 The adopted LCS (2011) does not include specific reference to PBSA. However, the LTCLP (2014) directly acknowledges the role that the residential typology can play. Policy LTC13 (part 1) sets out that the Council will, in principle, support the provision of PBSA within the town centre, providing that the development does not:

(a) cause a net loss of permanent self-contained homes, employment space or other town centre uses that add to its vitality or viability,

(b) prejudice the Council’s ability to meet the London Plan target for delivery of selfcontained homes or,

(c) involve the loss of sites that are considered especially suitable for affordable housing.

16.10The provision of PBSA within the Proposed Development (Outline Component) will not trigger (a), (b) or (c) of Policy LTC13 (part 1).

16.11Part 2 of Policy LTC13 sets out a number of requirements for PBSA, as summarised in Table 16-2.

Table 16-2 Policy LTC13 Compliance

Requirement Application Response

Provide a high quality living environment in private and shared spaces and comply with all relevant national and local standards and codes, including BREEAM and ANUK

The PBSA is part of the Outline Component of the Application and as such the detail of the PBSA will be set out within the subsequent reserved matters process.

However, the Application includes a framework to ensure that the reserved matters details will enable an appropriate design to come forward for the PBSA. This will include internal design and layout considerations to ensure that functional living spaces are provided within the PBSA (and all residential buildings), according with relevant standards.

Include a range of unit sizes and layouts, including with and without

As above.

Requirement Application Response

shared facilities, as appropriate

Contribute to the establishment of a mixed and inclusive community and does not create an over-concentration of student housing

Be needed by and easily accessible to the higher education institution/s it will serve using public transport

Have a positive effect on the existing and emerging environment of the site, Policy Area and town centre as a whole.

The proposed PBSA will provides a higher-quality option for Lewisham’s students. The provision of PBSA, together with the wide range of other uses and housing typologies within the Application, including affordable homes, will attract a diverse range of individuals and families that will contribute towards a mixed and balanced community, with a diverse neighbourhood within the local area in particular. The PBSA will foster community engagement and meaningful relationships between residents/students across the Site and encourage interaction with the existing community through social and educational events.

The need for the proposed PBSA I set out within this Application submission.

The Site is located in a well-connected area with a PTAL of 6b. This location for PBSA is considered to be highly suitable in this context.

The PBSA is part of the Outline Component of the Application and as such the detail of the PBSA will be set out within the subsequent reserved matters process.

However, the Application includes a framework to ensure that the reserved matters details will enable an appropriate design to come forward for the PBSA, which will have a positive effect on the Site and its surrounding areas. The Application as a whole will seek the comprehensive redevelopment of the Site for the benefit of the town centre and beyond.

Demonstrate it is suitable for year round occupation and that it has long term adaptability and sustainability.

The PBSA is part of the Outline Component of the Application and as such the detail of the PBSA will be set out within the subsequent reserved matters process.

However, the Application includes a framework to ensure that the reserved matters details will enable an appropriate design to come forward for the PBSA, to ensure it is suitable for continuous occupation, with long term adaptability potential and sustainability at its heart.

16.12On the basis of the above, the Proposed Development fully accords with Policy LTC13.

16.13In terms of emerging policy, the R19 acknowledges the important role that the borough plays in higher education, noting the existence of Goldsmiths College at New Cross, Trinity Laban

Conservatory of Music and Dance at Deptford, and Lewisham College at Deptford Bridge and Lewisham Way. The R19 confirms the importance of providing Lewisham’s student population with access to affordable accommodation (Paragraph 7.56).

16.14The R19 confirms a number of other advantages of PBSA (at Paragraph 7.56), including: the role that PBSA can play in meeting local housing need; the role that PBSA plays in relieving pressure on the private rented market, thereby enabling others to access housing that might not otherwise be available; and the benefits that PBSA can bring to Lewisham’s neighbourhoods and communities, for example by attracting a student population that supports the local economy, complements the creative and cultural industries, and stimulates inward investment.

16.15R19 Policy H07 sets out a number of criteria for PBSA proposals, as summarised in Table 163 below.

Table 16-3 Draft Local Plan Policy H07 Compliance

Requirement Application Response

A (a) Meet an identified need for this type of housing (giving priority to the local student population), will not compromise delivery against the Borough’s strategic housing target and principal need for conventional housing, and will not result in a harmful over concentration of PBSA taking into account:

(i) The amount of PBSA within the Borough and the area within which the development is proposed, having regard to past delivery and consented but undelivered PBSA; and

(ii)The proportion of PBSA provided in relation to the overall mix of housing within the development, and where relevant a masterplan or site allocation.

(b) The accommodation is secured for use by students, as demonstrated by an agreement with one or more specific higher education provider(s)

(c) The maximum level of accommodation is secured as

The London Plan and supporting evidence sets out a need for 3,500 additional student beds per year for a 25 year period, establishing the strategic need for student accommodation in London.

As of 2024, the balance of supply and demand indicated by the ratio of students to student beds stands at 3.6 to 1, representing a significant shortfall in student accommodation.

The local need for student accommodation, together with the negative impacts on the wider housing market of students unable to find purpose-built beds, is set out in more detail within the Housing Statement.

All student accommodation within the scheme will be secured for the use of students during term time, benefit from a nominations agreement for the majority of units with a higher education provider and deliver affordable homes in the form of conventional affordable housing.

Requirement Application Response

affordable student accommodation, in line with the London Plan.

B Development proposals for PBSA must be appropriately located:

(a) At well-connected sites that are easy to access by walking, cycling and public transport;

(b) Within or at the edge of town centres, or other locations that benefit from good provision of shops, services, leisure and community facilities appropriate to the student population; and

(c) Giving priority to sites located in proximity to the education facility the development is intended to serve, or other higher education institutions in the Borough.

C Development proposals for PBSA must be of a high-quality design, giving particular consideration to:

(a) Adequate functional living space and layout with good-sized bedrooms and well-integrated communal areas and facilities, with a recommended benchmark of 1 square metre of internal and 1 square metre of external communal amenity space per student bed;

(b) Inclusive and safe design, including provision for wheelchair accessible accommodation, spaces and facilities;

(c) Amenity of occupiers and neighbouring properties including

The Site is located in a well-connected area with a PTAL of 6b. This is a very suitable site for the PBSA use.

In addition, the Proposed Development will include a network of footpaths within it that connect to the existing town centre network.

The Site is at the heart of the town centre meaning that access to amenity provision located outside of the Proposed Development will be significant. Moreover, the PBSA is part of a much larger, mixed use scheme which will allow the future student population to benefit from the amenity provision and facilities which comes forward as part of the Proposed Development too.

This part of Lewisham is well served by higher education facilities. The provision of PBSA within the Proposed Development therefore allows suitable sites (such as this) to be prioritised suitably for PBSA.

The PBSA is part of the Outline Component of the Application and as such the detail will come forward as part of the Reserved Matters Approval process. This detail will include the specifics relating to layout and appearance of the PBSA accommodation in Buildings S1 and S4.

The Applicant is committed to delivering a high-quality scheme (across all phases). The Applicant is therefore aware of the requirement to deliver PBSA which provides a comprehensive package of amenities within well designed buildings that are appropriate for the future student population.

Requirement Application Response consideration for outlook, daylight and sunlight, noise and ventilation;

(d) Adequate on-site cycle parking facilities; and

(e) Accommodation that is suitable for year-round occupation.

16.16 On the basis of the above, the Application accords with R19 Policy H07.

17A Well-Designed Place

17.1 In this section, we consider the national policy objective of creating well-designed places and optimising development through a design led process.

17.2 The Proposed Development has been through a thorough and detailed design review process, as summarised in Section 11 of this statement.

17.3 The Lewisham Design Review Panel can be said to be supportive of the scheme as a whole.

The Framework and National Design Guide

17.4 The Framework was updated in 2021 to put beauty at the heart of the planning system The principal changes in 2021 related to Section 12 achieving well designed places. National policy emphasises the importance of Design Codes, and consistency with the principles set out in the National Design Guide and National Model Design Code.

17.5 Framework paragraph 139 states that development that is not well designed should be refused, especially where it fails to reflect local design policies and government guidance on design (contained in the National Design Guide and National Model Design Code) taking into account any local design guidance and supplementary planning documents such as design guides and codes.

17.6 Conversely, the Framework gives significant weight to a) development which reflects local design policies and government guidance on design, taking into account any local design guidance and supplementary planning documents such as design guides and codes; and/or b) 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.

17.7 The National Design Guide (2021) provides planning guidance for ‘beautiful, enduring and successful places’. It addresses the question of how we recognise well-designed places, by outlining and illustrating the Government’s priorities for well-designed places in the form of ten characteristics: Context – enhances the surroundings; Identity – attractive and distinctive ; Built form – a coherent pattern of development; Movement – accessible and easy to move around; Nature – enhanced and optimised; Public spaces – safe, social and inclusive; Uses – mixed and integrated; Homes and buildings – functional, healthy and sustainable; Resources – efficient and resilient; and Lifespan – made to last

17.8 The Proposed Development reflects Government guidance on design, the design principles set out at a regional level within the London Plan and local design policies. This level of compliance, in our opinion, is afforded significant weight by national policy.

17.9 Whilst it is not a requirement to conform with Framework paragraph 139(b), if 139(a) has been addressed, for this Application Framework paragraph 139(b) is an important consideration as the Application is also compliant with this part of national policy.

17.10We consider that the Proposed Development represents outstanding design which promotes high levels of sustainability and helps to raise the standard of design in the locality whilst finding a sensitive design solution for the Site’s unique setting and context.

17.11This is reinforced by feedback received from the Council’s officers (and DRP) who support the principle of the Proposed Development and have fed into the emerging design. The Framework applies significant weight to this compliance and this should be afforded to the proposals

Design Context

17.12There is a significant ambition by the Government, the Mayor of London and the Council to boost the supply of homes through the redevelopment first and foremost of accessible brownfield sites, securing high density development through a design led approach. London Plan policies reflect national policy and as previously explained, include many policies which seek the best use and optimisation of land in sustainable locations to meet significant housing needs and to deliver jobs whilst delivering high quality design

17.13The Application responds directly to significant pressure for growth, and in particular housing need within London and the Council by redeveloping a highly sustainable brownfield site. The Proposed Development also directly responds to the site allocation requirements of 2,150 homes and 60,291sqm of town centre floorspace, to make a meaningful contribution to housing delivery, to provide new infrastructure and to contribute positively to the wider regeneration coming forward in the local area which is subject to major growth.

17.14A design led optimised approach by Studio Egret West demonstrates that tall buildings are a necessary typology to deliver the planning objectives at this site. Whilst tall buildings are considered appropriate in this location under existing and emerging planning policy, they are also necessary as a design and delivery tool to break open the inward facing shopping centre and create new open space, permeable routes, and active frontages. They are an inevitable consequence of a new mixed use town centre model.

17.15Positively, with a rational approach to townscape and heritage, tall buildings can contribute to the role and function of Lewisham and the potential Metropolitan classification of the town centre. Tall building typologies, up to 36 storeys, have already been developed to the north of Lewisham town centre, redeveloping large retail warehouse floorplates, car parks and infrastructure sites.

17.16However, the historic heart of Lewisham is the linear high street and market, with Lewisham shopping centre located behind this to the west. Whilst the high street is historic, the shopping centre is not a designated heritage asset, which might otherwise present a limitation on optimisation. The rebalancing of the town centre height hierarchy to its geographical core is important for its health, vitality and viability. Site Allocation LCA 2 is fundamental to this. There is a genuine transformative opportunity to connect the northern and southern tips of the town centre (a 2014 policy objective), connections east and west, and a critical mass of development within the core to draw Lewisham towards its town centre reclassification. Importantly, it can achieve this largely through single ownership enabling a comprehensive approach in phases to maintain operational continuity of trade and limiting disruption to the rest of the town centre.

17.17Tall buildings, alongside some linear blocks, are proposed to be the principal building typology at Site Allocation LCA 2 to enable phased delivery, continuity of trade, and improved residential amenity. The absolute height of 35 storeys justifiably seeks to rebalance the town centre height hierarchy. Recently this has been pulled north to the Tesco car park away from the traditional high street. Site Allocation LCA 2 2 affords the opportunity to place the greatest emphasis in the area that has the greatest significance to the function of the town.

17.18The Development Plan promotes the Site for high density optimisation - it is in a highly accessible and sustainable location and within a tall building zone. Therefore, the inclusion of tall buildings within the proposals is acceptable in this context, making the most of this opportunity, optimising development vertically to efficiently deliver new homes for London and the borough.

17.19Policy D3 outlines how the growth identified in the London Plan could come forward in an inclusive and responsible way. Policy D3 requires every new development to make the most efficient use of land by optimising site capacity. All development is expected to make the best use of land by following a design-led approach that optimises the capacity of sites, including site allocations. Optimising site capacity means ensuring that development is of the most appropriate form and land use for the Site. The design-led approach requires consideration of design options to determine the most appropriate form of development that responds to a site’s context and capacity for growth. Higher density developments should generally be promoted in locations that are well connected to jobs, services, infrastructure and amenities by public transport, walking and cycling, to achieve sustainable densities. Where these locations have existing areas of high-density buildings, expansion of the areas should be positively considered by Councils where appropriate.

17.20A Townscape, Visual and Built Heritage Impact Assessment (the ‘TVBHIA’) has been prepared and submitted in support of the Proposed Development within the Environmental Statement. The TVBHIA provides an assessment of the likely effects of the Proposed Development on heritage, townscape and visual receptors. The Assessment outlines how the design has undergone iterative development informed by the pre-application process and engagement with stakeholders. As a result, it states how the high-quality proposals mitigate any specific adverse impacts in the completed phase of development

17.21This demonstrates that there is a clear local context and planning policy context for high levels of density and optimised development This approach is supported at all levels of planning policy and creates the foundation for the delivery of tall buildings at the Site.

17.22The Design and Access Statement which supports the Application considers the design of the Proposed Development, both in illustrative masterplan terms and also specifically for the Detailed Component.

17.23We consider that the Proposed Development will be visually attractive as a result of its highquality architecture, layout and landscaping, consistent with paragraph 135(b) of the Framework In accordance with paragraph 135(c) of the Framework, the Proposed Development is particularly sympathetic to local character and history, including the surrounding built environment and landscape setting having developed a design that is transitions east to west from the local character of the high street It will also establish and maintain a strong sense of place, with the arrangement of spaces, building and landscaping

creating an attractive, welcoming and distinctive place to live, work and visit, consistent with paragraph 135(d) of the Framework. It will also create a place that is safe, inclusive and accessible, consistent with paragraph 135(e) of the Framework.

17.24The Application responds to the site-specific constraints and opportunities as well as its surrounding context. It establishes a design solution that responds sympathetically to the town centre context whilst creating a distinctive place, enabling it to meet other policy requirements of the Council’s Local Plan and deliver a mixed use scheme with significant public benefits.

17.25A key part of the design approach has been the intention to retain and significantly remodel and improve Lewisham House. Retention and improvement of this property allows for greater site optimisation in line with the R19 site allocation LCA2 development capacities, and the delivery of a covered shopping mall, the park, and stepping height away from the local character of the High Street.

17.26The character of the Site is also informed by the scale of development coming forward in the surrounding area, especially to the north around Lewisham Gateway. Here, there are many examples of tall buildings that have been permitted and/or constructed. The Proposed Development is therefore acceptable in its context and has been carefully formulated and designed to sensitively fit within its context.

17.27The Proposed Development has evolved through an extensive and collaborative preapplication process between the Applicant, the Council, the GLA, and local stakeholders and communities. The Applicant has worked closely with stakeholders and the local community to develop a design that takes account of the feedback received, consistent with paragraph 137 of the Framework. The original proposal has been through a number of revisions to respond to design review and advice.

17.28The Applicant has consistently engaged with and responded to the Council DRP advice and review arrangements consistent with paragraph 137 of the Framework

17.29The Proposed Development, and particularly the taller buildings, has been designed to respond positively to key townscape views agreed with the Council and other environmental constraints.

17.30It will deliver an appropriate massing and layout for the Site, integrating with the surrounding area in accordance with London Plan policies D3, D4 and D9.

17.31The arrangement of the buildings, the legibility of entrances and different uses and active frontages works well and contributes towards the vitality and function of the Proposed Development in accordance with London Plan Policies D3 and D4

17.32We consider that the detailed design and materiality of the buildings is of significant quality The specific design details including colour and architectural treatment will be secured by condition for the Detailed Component and in line with principles set out within the Design Code for future Reserved Matters Applications for the Outline Component, therefore according with the aforementioned policies.

Tall Buildings Assessment

17.33London Plan Policy D9 provides the most up to date development plan policy framework for assessing the acceptability of a tall building proposal. This policy is considered in detail below.

Tall Building Typology and Character

17.34The London Plan sets out a design-led approach to determining the optimum development capacity of sites.

17.35To accommodate the growth identified in this Plan in an inclusive and responsible way, every new development needs to make the most efficient use of land by optimising site capacity.

17.36Policy D1 B (3) ‘London’s form, character and capacity for growth’ is clear that boroughs should follow the design-led approach (set out in Policy D3 ‘Optimising site capacity through the design-led approach’) to establish optimised site capacities for site allocations. Paragraph 3.3.4 of Policy D3 acknowledges that this should be through a consultative design-led approach that allows for meaningful engagement and collaboration with local communities, organisations and businesses.

17.37Many of the surrounding town centres offer examples of regeneration and tall building typologies, albeit none are directly comparable to Lewisham. There are two principal reasons that differentiate Lewisham from other town centres.

17.38First, no other existing town centre proposed for change comprises an existing, multi-level operational shopping centre. The Westfield self-contained model which once successfully replaced existing town centres no longer exists in the UK. The Elephant and Castle model requires wholescale site clearance before development can commence. At present this is not considered appropriate for Lewisham due to the disruption that this will cause. Second, no other existing town centre proposed for change has a high street that is desirable to retain in part and complement due to the building stock and diversity of retail provision that it offers.

17.39It is common ground that Lewisham is the Council’s highest order town centre, due to its excellent accessibility to services and public transport, role and function. Because of these characteristics many layers of national, regional and local policy expect optimisation of brownfield opportunities as a key thread of sustainable development. The Council also considers the Site appropriate fortall buildings dueto its limited sensitivity and suitability across several criteria.

17.40Tall building typologies have already been developed in the north of Lewisham town centre, redeveloping large floorplate retail warehouses and former industrial and infrastructure sites. Many tall buildings have been approved up to 36 storeys on a site-by-site basis. This regeneration has largely been completed and comprises useful ingredients for a successful town centre including convenience retailing (Asda and Tesco), a cinema (Gateway) and Leisure Centre (Glass Mill).

17.41However, the historic heart of Lewisham is the linear high street and market, with the shopping centre located behind this. Whilst the high street is historic it is not a designated heritage asset, which might otherwise present a limitation on optimisation; however, it is a critical part of the

surrounding context of the site that should inform the proposed development. The rebalancing of the town centre height hierarchy to its geographical core is important for its health, vitality and viability. Site 2 is fundamental to this. There is a genuine transformative opportunity to connect the northern and southern tips of the town centre (a 2014 policy objective), connections east and west, and a critical mass of development to aid Lewisham in its town centre reclassification. Importantly, it can achieve this largely through single ownership enabling a comprehensive approach in phases to maintain operational continuity of trade and limiting disruption to the rest of the town centre.

17.42Tall buildings are an appropriate typology to deliver this ambition. They are commonplace within major town centre redevelopments because of the quantum of floorspace that they can accommodate, the public realm they create, the quality of floorspace they deliver and the dynamic way that they appear in the townscape with buildings separated from each other too. A tower typology also maximises the availability to integrate large scale and large format retail at ground floor, with large scale public realm above. Other typologies are less successful and are encouraged less by the London Plan. For example, perimeter blocks are unable to maximise dual aspect and homes per core and can create long fingers of development which generate microclimate issues and mass at lower (human scale) level.

17.43The location of the tall buildings within the Proposed Development follows a logical layout across the Site, with scale decreasing along the eastern edge respecting the relationship with the high street. Developable plots are identified to enable continuation of trade and phased delivery, whilst still retaining existing infrastructure on site including the service deck. Buildings are arranged to maximise daylight and sunlight penetration to the amenity decks, whilst creating a high-quality outlook for future occupiers. Development optimisation is proposed in line with the emerging residential density character of Lewisham town centre.

Tall Building Role

17.44The London Planrecognises that tall buildings can form part of a plan-led approach to facilitate regeneration opportunities and manage future growth, contributing to new homes and economic growth, particularly in order to make optimal use of the capacity of sites which are well-connected by public transport and have good access to services and amenities. Tall buildings can help people navigate through the city by providing reference points and emphasising the hierarchy of a place such as its main centres of activity, important street junctions.

London Plan Tall Building (Policy D9) Assessment

17.45The London Planrecognises that tall buildings can form part of a plan-led approach to facilitate regeneration opportunities and manage future growth, contributing to new homes and economic growth, particularly in order to make optimal use of the capacity of sites which are well-connected by public transport and have good access to services and amenities. Tall buildings can help people navigate through the city by providing reference points and emphasising the hierarchy of a place such as its main centres of activity, important street junctions.

17.46Supporting text to the policy recognises that tall buildings that are of exemplary architectural quality, in the right place, can make a positive contribution to London’s cityscape, and many tall buildings have become a valued part of London’s identity (paragraph 3.9.1)

17.47The supporting context to the application of Policy D9 is important as it provides a useful explanation ofthe broadprinciples which govern the plan led suitability for tall building locations in London: - regeneration; growth; new homes; economic growth; optimal use of site capacity in well-connected locations; a tool for navigation; and an emphasis for place hierarchy (town centres; junctions; and transport interchanges). These reflect the good planning principles that we refer to in this Statement, and the very detailed policy context which supports this Application.

17.48Supporting text at paragraph 3.9.1 of the London Plan does recognise the challenges that arise from the delivery of tall buildings noting the detrimental visual, functional and environmental impacts that can occur if tall buildings are proposed in inappropriate locations and/or of poor quality design.

17.49London Plan Policy D9 comprises four key components: Definition (A); Locations (B); Impacts (C); and Public Access (D). We address each in turn below to determine whether, as a whole, the Application complies with London Plan Policy D9:

London Plan Policy D9(A)

17.50London Plan Policy D9(A) defines tall buildings as not being less than 6 storeys or 18 metres measured from ground to the floor level of the uppermost storey.

17.51The Council at R19 Policy QD4 define Lewisham Tall Buildings as buildings which are 10 storeys or 32.8 meters measured from the ground level to the top of the building (including any rooftop equipment), or greater.

17.52The Proposed Development for this Site includes buildings within the Detailed Component of 23 (Building N1) and 15 (Building N2) storeys and extending up to 137m AOD (35 storeys) within the Outline Component.

17.53The Application therefore proposes tall buildings across the Site.

London Plan Policy D9(B)

17.54Part B of the policy relates to locations of tall buildings and is split into three limbs.

17.55The first two limbs require Boroughs to determine if there are locations where tall buildings may be an appropriate form of development. These locations and appropriate tall building heights should be identified on maps in Development Plans. The third limb, Part B(3), states that tall buildings should only be developed in locations that are identified as suitable in Development Plans.

17.56In terms of Part B(1), Lewisham’s local plan complies with this requirement at Policy 18 of the LCS and Policy LTC19 of the Lewisham Town Centre Local Plan (2014). In terms of emerging local policy, R19 Policy QD4 deals with building heights

17.57In terms of Part B(2), CS Policy 18 and Policy LTC19 including Figure 6.3 confirm that the whole of the Site is an appropriate area for tall buildings.

17.58R19 Policy QD4 (Part 4) confirms that the maximum height of buildings in Lewisham Town Centre shall not normally be more than 52.0 meters (16 storeys) to 112.8 meters (35 storeys). It also identifies appropriate locations for tall buildings in Tall Building Suitability Zones.

17.59Figure 5.5 comprises the Lewisham tall building suitability zones, which identifies a maximum of 25 storeys for Lewisham Shopping Centre and adjacent land, behind the existing built fabric of Lewisham High Street. Figure 5.5 is reprovided at Figure 17-1.

17.60Supporting text to Policy QD4 confirms that buildings that are appropriately located and welldesigned can help people to navigate through the Borough by providing reference points for wayfinding and emphasising the hierarchy of places. The London Plan provides that tall buildings will play a role in supporting good growth across London.

17.61Although maximum heights are provided for each for the Tall Building Suitability Zones, proposals will still be expected to include robust design justifications for the heights proposed, including testing in key views, taking into account the Lewisham Characterisation Study (2019), Lewisham Tall Buildings Study (2020) and Tall Buildings Study Addendum (2022).

17.62Development proposals will be considered on a case-by-case basis taking into account their impacts on an individual site level and cumulatively in combination with other existing, consented and planned tall and taller buildings.

17.63Turning to Part B(3), the adopted Lewisham local plan identifies the Site as an acceptable location for tall buildings within Lewisham Town Centre and the Opportunity Area. It is identified

Figure 17-1 Lewisham Tall Building Suitability Zones (R19 Figure 5.5)

as being the focus of significant growth and renewal, where a substantial number of new dwellings and commercial floorspace are planned, which will require high density development including a number of tall buildings to make best use of the highly accessible brownfield land.

17.64The adopted local plan identifies the site as an acceptable location for tall buildings within Lewisham Town Centre and Opportunity Area. It is identified as being the focus of significant growth and renewal, where a substantial number of new dwellings and commercial floorspace are planned, which will require high density development including a number of tall buildings to make best use of the highly accessible brownfield land.

17.65The emerging policy (R19 Policy QD4 and Figure 5.5) is more nuanced. It supports the principle of tall buildings across the Site, offset from the High Street, up to 25 storeys or greater, having regard to relevant material considerations, and a wider public benefit to justify the design of the development.

17.66The Application conforms in the main with the locational requirements of tall buildings Policy QD4. A small portion of Building N1 sits outside of the tall building zone designated by Figure 5.5, specifically an element of the roof structure of the shorter part of Building N1 as a result of the sloping roof design.

17.67The Application broadly complies with the 25 storey parameter across the 6.87ha site. The Detailed Component comprises a 23 storey building (N1) and a 15 storey building (N2) at their tallest parts, whilst the Outline Component comprises several development plots ranging from 3 storeys to 25 storeys.

17.68However, two plots are taller with maximum heights of 33 and 35 storeys, beyond the 25 storey height threshold, but these are justified by the public benefits that are delivered as a result of the Proposed Development. Further detail on the public benefits and planning balance is contained at Section 22 of this statement

17.69The proposed maximum building storey heights are set out in full below, and within the detailed drawings and at Parameter Plan 10 (Maximum Vertical Extents of Development Plots):

Detailed Component

▪ N1 – 23 storeys

▪ N2 – 15 storeys

Outline Component

▪ MV – 5 storeys

▪ S1 – 21 storeys

▪ S2 – 25 storeys

▪ S3 – 11 storeys

▪ S4 – 17 storeys

▪ C1 – 7 & 12 storeys

▪ C2 – 3, 9 & 13 storeys

▪ C3 – 21 storeys

▪ C4 – 35 storeys

▪ C5 – 24 storeys

▪ M1 – 3 storeys

▪ N3 – 23 & 33 storeys

London Plan Policy D9(C)

17.70London Plan Policy D9(C) considers the impacts of tall buildings and requires proposals to address: visual impacts; functional impacts; environmental impacts; and cumulative impacts.

17.71In terms of visual impacts, the position is summarised in Table 17-1.

Table 17-1 Summary of Proposed Development against Policy D9 (C) 1

The views of buildings from different distances (long, mid and immediate views)

The Built Heritage, Townscape and Visual Impact Assessment (BHTVIA) includes 39 accurate visual representations (“AVRs”), to help inform the assessment of perceived impacts on the significance of built heritage assets, townscape character areas and visual receptors. The AVRs have been independently prepared by Miller Hare, in accordance with relevant best practice and technical guidance. Their location (which includes two static and strategically designated views from Greenwich’s Local Plan) have been agreed with the Council in their Scoping Opinion dated 14th June 2024.

Long-range views: particularly careful consideration has been given to the design of the tall building cluster to provide articulation and modulation of its silhouette in longer distance views. The BHTVIA confirms that the proposed development would integrate with the existing and emerging skyline of Lewisham Town Centre, achieving a successful skyline composition with Lewisham Gateway and the other taller buildings at Lewisham town centre.

There are no adverse impacts on strategic or local views identified in policy and guidance. In Lewisham, the proposed development would integrate with the hierarchy of built form across the centre and would not detract from any of the identified Lewisham landmarks.

Mid-range views: as confirmed in the BHTVIA, the Proposed Development is consistent with the varied urban character of Lewisham. In some views from further afield the taller elements of the development would be visible on the skyline in the background of views. The use of mixed materials will contribute positively to the appearance of the skyline by maintaining definition in the architectural composition of the taller elements. The architectural and visual relationships between the taller and lower elements of the proposed development reflect the transition in scale between the more traditional scale of the townscape character areas to the east and south of the Site and the more varied, urban scale of the character areas in central Lewisham. The proposed materiality reinforces that transition in townscape character areas – with the lower buildings responding to the prevailing character along Lewisham High Street, through the use of brick.

Legibility and wayfinding

Immediate views: The quality of local streetscape views near the Site will improve, as views of the existing buildings, many of which are in a poor condition, would be replaced with views of new buildings of high-quality design. The proposed development would provide added visual interest to Lewisham and new – and enhanced – public realm that integrates with the existing character of the townscape. The lower elements addressing Lewisham High Street respond to the scale of the traditional buildings and provide an appropriate transition to the taller buildings, consistent with the transition that occurs between townscape character areas in other parts of the town centre and where the tall building zone is adjacent to areas of lower scale development. Taller buildings are accompanied by generous areas of public realm, maximising active frontages to the principal streets. As part of the strategy to maintain a pedestrian scale and animation to the street elevations, the base of the buildings principally incorporates ground and first floors thereby maintaining a human scale. Pier widths are reduced to enable wide openings providing activity at street level.

The Proposed Development respects the spatial hierarchy of built form across central Lewisham. The Site is located within a transitional area within the townscape. The Proposed Development integrates comfortably within the existing and emerging hierarchy of built form across Lewisham and would not detract from the Lewisham skyline.

As confirmed in the BHTVIA, the height and massing of the taller elements within the proposed development reflect the Site’s location in an area of transitional townscape character, with the lower element relating to the more traditional scale of development to the south and east of the Site and the taller element relating to the larger scale taller buildings, which increase within the middle of the site along Molesworth Street with two accent points at plot C4 and N3, with plot C5 and C3 subordinate in height, and lower, to create an animated skyline and visual interest. The taller element would integrate comfortably within the wider cross section of tall buildings within the central area.

The design approach to the Site responds specifically to this context, and can be summarised through the following key moves.

▪ The urban plan is of a grain with clearly defined streets and spaces with ground floor active uses focussed on Molesworth Street, Rennel Street and the newly created street pattern resulting in improved legibility and improved permeability between Lewisham Gateway and the Station hub to the north, Cornmill Gardens next to Prendergast Vale School to the west, and Lewisham High Street to the south.

▪ Improved character of Molesworth Street and Rennel Street frontage by addressing level issues and providing ground floor activity through front doors.

▪ The introduction of on-site green space and improved visual amenity of the site from the street scape, as well as improving pedestrian access to the

Architectural quality

site. The massing along Lewisham High Street has been broken up improving the quality of public realm and enabling an increased provision of public open space, new homes and commercial active frontages.

▪ The massing has been located in response to the surroundings, with lower buildings adjacent to Lewisham High Street. Plots C1 (7 storeys) and C2 (3 storeys) have stepped down at these points to ensure a suitable scale transition. Plot MV, which largely retains the existing building is proposed to be 5 storeys as it fronts the south entrance to the site and is located adjacent to retained and listed buildings.

▪ Along Molesworth Street where there is less impact on existing buildings, neighbours, and the railway line to the west, a greater transition in metropolitan scale can be accommodated to support the growth policies of the local plan.

The proposed plots, in particular N3 and C4, act as a marker near Lewisham Station and the new public park on site reinforcing the newly created local landmarks and improve legibility.

The retention of Lewisham House also plays an important role in terms of legibility. The significant remodelling and improvements to Lewisham House will ensure comprehensive development, and that the policies of the development plan (adopted and emerging) are achieved.

Full details are set out in the Design and Access Statement, Design Code and Parameter Plans.

The material choice and palette has been established to create a changing context for Lewisham and responds to engagement with planning officers and the Lewisham DRP. These are primarily robust brick buildings, designed in detail to be high quality, easy to maintain and age well.

Given the scale of the site, the varied character of Lewisham, the iterative design process in conversation with officers and the DRP, we propose an assemble of buildings which are distinctively different but share commonalities. Based on the Lewisham Character Study and emerging context differing but complimentary materials and colours will be selected. This approach applies to both new buildings and where buildings are to be retained and reused (for instance Lewisham House).

Full details are set out in the Design and Access Statement and Design Code.

To summarise, much of the focus of the illustrative scheme has been around the relationship to Lewisham High Street. In this regard, the materiality and character of interventions on the High Street is designed to celebrate its diversity, whilst maintaining and reference the common thread of brickwork.

Heritage, avoid harm, alternative designs

Generally, the lower levels of plots have a strong character in terms of material and tone, chiming with the High Street approach. This is extended to the shopping centre entrances which have their own strong character.

Buildings above the podium are generally muted brickwork tones, design to provide a family of buildings as a backdrop to the lower levels and multilevel landscape. There is an opportunity to differentiate between these ‘background’ types in the central centre of the site and Molesworth Street, where buildings are taller.

Marker buildings introduce more colour responding to their townscape role, and vertical access points through the site (such as external lifts) also provide an opportunity for boldness and the introduction of public art.

As confirmed in the proportionate and robust assessment within the BHTVIA the Proposed Development will preserve the significance of scoped in built heritage assets. The carefully considered, contextual high-quality design will improve local townscape quality and be a positive addition to this part of Lewisham, in place of the existing poor quality and detracting buildings. The BHTVIA confirms that the proposed development would deliver beneficial change in the setting of the locally listed and statutory listed buildings in Lewisham.

Alternative options have been considered over the lengthy pre-application period and design review process. The design has been considered as a whole, taking into account heritage impact; development plan policies that seek to optimise site capacity; the site allocation for the site and quantum of development that it seeks to achieve including 2,150 homes and 60,291sqm of town centre floorspace to meet housing and commercial needs; deliverability; and viability including maximising the contribution of affordable housing. Within this context, heritage effects have been reduced and harm avoided as far as it can reasonably be reduced / avoided

Setting of a World Heritage Site

A Zone of Theoretical Visibility (ZTV) of the Proposed Development has been produced and is included in Figure 2.2 of the BHTVIA. This indicates that there is visibility of the proposals from Greenwich WHS, however, we have produced AVRs to supplement this which show that visibility is limited to peripheral and glimpsed views. The Proposed Development is not visible from the core, grand axis of the Greenwich WHS and will not impact the Outstanding Universal Value (OUV) of the World Heritage Site.

River Thames & Thames Policy Area Not applicable.

Adverse reflected glare The use of a robust material palate which does not include reflective cladding will mitigate glare.

Light pollution

Full details are set out in the Design and Access Statement, Design Code, Lighting Strategy and Assessment and Daylight, Sunlight, Overshadowing, Solar Glare, Light Pollution Section (12) of the ES.

The Proposed Development is located in Lewisham Town Centre which already experiences a degree of light pollution as a result of its town centre role and function with street lighting and lighting within existing buildings including the tall building cluster contributing to the existing light baseline. The proposal incorporates both commercial and residential buildings, the latter being the tallest. Window openings have been sized to ensure sufficient natural daylight is achievable within the homes, and to enable a high quality external façade design. Artificial light egress from windows is considered to be proportionate for residential buildings of this type within a mixed residential/ commercial area. External lighting has been kept to a minimum for security and comfort and is located at entrances, adjacent to private balconies, and within the gardens.

Full details are set out in the Design and Access Statement, Design Code, Lighting Strategy and Assessment and Daylight, Sunlight, Overshadowing, Solar Glare, Light Pollution Section (12) of the ES.

17.72In terms of functional impacts, the position is summarised in Table 17-2.

Table 17-2 Summary of Proposed Development against Policy D9 (C) 2

Internal and external design

Buildings should be serviced, maintained and managed

The Applicant has engaged a full consultant team to develop the design to planning and provide specialist advice. The buildings have been designed to planning application level to comply with the Building Regulations and Approved Documents. Fire advice has been provided with regards to fire safety on the project, to ensure compliance.

Full details are set out in the Design and Access Statement, Design Code and Accessibility Statement.

The buildings will be serviced, maintained and managed, maintaining both buildings and landscaped areas in perpetuity.

Full details are set out in the Design and Access Statement; Transport Assessment; Construction Method Statement/Logistics Plan and Environmental Management Plan (including site waste management plan); Delivery & Servicing Plan; Parking Management/Arrangement Plan; Travel Plan Framework; and Transport Section (8) of the ES.

Safety / Fire Strategy

Jensen Hughes and Arup have provided ongoing advice with regards to fire safety on the Application, and to ensure compliance with London Plan Policy D12 and the Building Regulations, generally in the form of the recommendation of Approved Document B. The residential apartments follow a remain in place evacuation strategy, while the residential ancillary areas will operate a simultaneous evacuation strategy for all areas in each

Entrances, access routes, and ground floor uses

block. The commercial areas each operate an independent simultaneous evacuation strategy. All common corridors are provided with mechanical smoke ventilation and where travel distances are extended beyond the requirements of ADB it will be justified using CFD analysis. The smoke shafts will include automatic opening vents (AOV’s) at each level within the common corridors with an automatic vent at the top of the stairs.

Two stairs will be provided to each building, a firefighting stair and secondary escape stair. Buildings are sprinklered and incorporate at least two lifts (one firefighting and one evacuation lift). The apartments are designed as open plan flats using supplementary guidance from BS9991 and will be provided with an LD1 Grade D fire alarm and detection system. The fire alarm and smoke detection within the ancillary spaces, stores, plant and refuse rooms should be designed in accordance with BS5839 Part 1 and be of type L3. The buildings will comply with Regulation 7(2), where all materials which become part of the external wall, should achieve European Classification A2-s1,d0 or Class A1, classified in accordance with BS EN 13501-1:2018. The buildings will be provided with an evacuation alert system and a firefighting shaft is provided to each tower consisting of: firefighting stair, firefighting lift stopping at every floor level, a dry or wet riser (depending on tower) with outlets in the stair at every level including ground, ventilation to the stair (1.0m2 AOV), and ventilation to the firefighting lobby (smoke ventilated common corridor for residential areas). Dry risers and wet risers are provided in towers.

Full details are set out in the Fire Statement.

For the mixed-use residential buildings, each building is provided with a large entrance lobby with post boxes and are large enough to accommodate space for seating.

Full details are set out in the Design and Access Statement, Design Code and Accessibility Statement / Wheelchair Unit Statement.

Capacity of the area’s transport networks

Economic and regeneration outputs

Vectos has considered the capacity of the area’s transport network and consider that capacity exists for the proposed increase in population and additional commercial floorspace provision (noting that there is a net reduction overall).

Full details are set out in the Transport Assessment; Construction Method Statement/Logistics Plan and Environmental Management Plan (including site waste management plan); Delivery & Servicing Plan; Parking Management/Arrangement Plan; Travel Plan Framework; and Transport Section (8) of the ES.

The Proposed Development will provide new homes, student and Co-Living accommodation in addition to a significant quantum of town centre floorspace. This will comprise a significant public benefit and contribute significantly to helping meet housing needs and town centre needs

Aviation, navigation or telecommunication impacts

contributing to economic and regeneration outputs. Additional benefits comprise:-

▪ An increase in temporary demolition and construction employment; and full time employment.

▪ Increased expenditure arising from the new jobs and residents, generated by the development.

▪ Improved turnover arising from more sustainable and new town centre floorspace.

Full details are set out in the Economic and Town Centre Regeneration Statement; Socio Economic Section (15) of the ES; and Retail Assessment.

Tall structures (buildings, tower cranes etc), have the potential to disrupt the reception of broadcast and telecommunications networks by causing unwanted obstructions on the line-of-sight signal path between transmitter and receiver. Impacts and effects vary, but generally the wider and taller a structure, the greater the area of potential interference. Sensitive receptors in this case are terrestrial and satellite TV viewers because unwanted signal shadows could be caused, thus reducing the availability of the signal at the receive point. Mitigation involves the repositioning of satellite dishes to new locations or through the use of terrestrial receiving equipment.

A series of conditions will control further survey work in due course following the grant of the Application. To ensure London's global competitiveness now and in the future, the development will also:

1) ensure that sufficient ducting space for full fibre connectivity infrastructure is provided to all end users within new developments, unless an affordable alternative 1GB/s-capable connection is made available to all end users.

2) meet expected demand for mobile connectivity generated by the development.

3) take appropriate measures to avoid reducing mobile connectivity in surrounding areas; where that is not possible, any potential reduction would require mitigation.

4) support the effective use of rooftops and the public realm (such as street furniture and bins) to accommodate well-designed and suitably located mobile digital infrastructure.

Impact on solar energy generation of the building and adjoining neighbours

The buildings will provide additional solar energy generation through installing photovoltaic panels on available flat roof as set out in the Energy Statement.

Full details are set out in the Energy and Overheating Assessment and Climate Chage section (16) of the ES.

17.73In terms of environmental impacts, the position is summarised in Table 17-3.

Table 17-3 Summary of Proposed Development against Policy D9 (C) 3

Wind effects A detailed wind microclimate assessment using physical wind tunnel testing has been undertaken to assess the wind conditions on and around the buildings. Results from the testing were combined with climate date for London and suitability assessed using the industry standard Lawson Criteria. Results from this testing show that all locations on and around the development have suitable wind microclimate conditions in terms of both wind comfort and safety.

Full details are set out in the Wind Microclimate section (13) of the ES

Daylight and sunlight penetration

Temperature conditions around the building(s)

Full details are reported in the DSO analysis (internal and external), but the key principles of north/south facing amenity spaces, dual aspect and building breaks resulting in a layout and form of development that maximises daylight for habitable space and maximises sun on ground for amenity space, with some variety to provide shade to respond to heat fluctuations arising from climate change, have been applied.

Full details are set out in the Design and Access Statement, Design Code and Daylight, Sunlight and Overshadowing assessment (internal and external) including Daylight, Sunlight, Overshadowing, Solar Glare, Light Pollution Section (12) of the ES.

The size and form of the buildings (dwelling sizes, heat gains from surroundings, urban heat island) has been considered within the detailed assessment dynamic modelling

Full details are set out in the Climate Chage section (16) of the ES.

Air Quality Air movement affected by the buildings is expected to support the effective dispersion of pollutants, and not adversely affect street-level conditions. Planning conditions can be applied to ensure that this is the case.

Full details are set out in the Air Quality section (7) of the ES.

Noise It is not considered that noise created by air movements around the buildings, servicing machinery, or building uses, will detract from the comfort and enjoyment of open spaces around the building and planning conditions can be applied to ensure that this is the case. Plant attenuation will be incorporated, where necessary, such that plant noise levels at the neighbouring existing houses will comply with the local authority’s usual requirements.

Full details are set out in the Noise and Vibration Assessment and Noise Quality section (6) of the ES.

17.74In terms of cumulative impacts, the position is summarised in Table 17-4.

Table 17-4 Summary of Proposed Development against Policy D9 (C) 4

Cumulative visual, functional and environmental impacts of proposed, consented and planned tall buildings in an area must be considered

Free to enter publicly-accessible areas should be incorporated into tall buildings where appropriate.

The accurate visualisations within the BHTVIA illustrate the relationship of relevant cumulative schemes to the Proposed Development. This assessment confirms that the Proposed Development would be experienced in the context of other existing tall buildings, consented schemes or those under construction. The impact assessment in the BHTVIA confirms that there would be no adverse cumulative heritage, townscape or visual impacts requiring mitigation.

The Proposed Development as a whole provides a significant quantum of publicly accessible open space, in the form of the meadow and the Northern Square (amongst other areas). This ensures that the scheme as a whole provides more than enough space.

Within the Proposed Development, it would not be appropriate for the public to enter free of charge to a publicly accessible area at the top of a residential building due to security and management reasons. It would also require additional floorspace to accommodate the viewing gallery reducing the overall housing provision in this highly sustainable location. We do not consider that it would be appropriate to allow public access.

Tall Building Assessment Conclusion

17.75In light of the above and when read as a whole, the Proposed Development complies with the requirements of Policy D9, and with the corresponding tests in Lewisham’s local plan

17.76When considering the acceptability of the proposed tall buildings, the proposals fully align with adopted planning policy and sufficiently align with emerging planning policy The Proposed Development proposes tall buildings within an area that has been identified as suitable for tall buildings, the impact of the proposed buildings has been fully assessed within this Application including specifically within the ES and BHTVIA which concludes that the proposals do not give rise to any visual, functional, environmental or cumulative impacts and it has been concluded that it would not be appropriate to provide public access at the top of the proposed buildings.

Heritage

17.77The Site does not comprise any statutorily listed buildings and nor is it located in a conservation area. There are statutorily listed buildings which have been identified in the study area which

may experience a change to their heritage value as a result of the Proposed Development changing their setting.

17.78Section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 requires local planning authorities, when 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 and historical interest which it possesses.

17.79Section 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 requires decision makers to give special attention to the desirability of preserving or enhancing the character or appearance of the conservation areas which may be affected by the proposed development. The Proposed Development does not comprise any buildings or other land in a conservation area and, therefore, Section 72 is not engaged. There is no statutory duty relating to the setting of conservation areas within the Planning (Listed Buildings and Conservation Areas) Act 1990.

17.80The policy context is set out below.

The Framework

17.81Planning policy requires an applicant to ‘describe the significance of any heritage assets affected by a proposed development, including any contribution made by their setting’ (paragraph 200) Setting is defined in the Framework as ’the surroundings in which a heritage asset is experienced. Its extent is not fixed and may change as the asset and its surroundings evolve. Elements of a setting may make a positive or negative contribution to the significance of an asset, may affect the ability to appreciate that significance or may be neutral.’

17.82The Framework makes clear that some aspects of setting may be neutral. A change to setting, even a major one, may also be neutral, beneficial or harmful depending on the particular facts of any case. Case law has made clear that ‘an impact is not to be equated with harm: there can be an impact which is neutral (or indeed positive).’

17.83Setting is not, however, an asset in its own right. ‘Its importance lies in what it contributes to the significance of the heritage asset or to the ability to appreciate that significance’ .

17.84In terms of considering potential impacts on the significance of a designated heritage asset, the Framework sets out that ‘great weight’ should be given to the asset’s conservation (paragraph 205). Conservation is defined with the Glossary as ‘The process of maintaining and managing change to a heritage asset in a way that sustains and, where appropriate, enhances its significance’

17.85The meaning and import of the ‘great weight’ provision as set out in paragraph 205 of the NPPF is also applicable which treats the conservation of the significance of a heritage asset as a matter of considerable importance and weight, and it applies to development which directly affects an asset, or which affects its setting.

17.86In this staged process, the assessor/decision maker then moves on to look at whether aspects of development form (including architecture, layout, landscape) and character (e.g., use) diminish either our appreciation of the special architectural or historic interest (also called ‘significance’) or our experience of those qualities. National guidance (NPPF Glossary) makes it clear that even a noticeable change to setting can have a neutral impact on the ability to experience or appreciate significance; change does not equal harm. Likewise, a change may be beneficial or, obviously, harmful.

17.87The harm, if there is any, must be categorized as substantial or less than substantial.

17.88The NPPF requires that great weight must be given to an effect which is either beneficial or harmful. However, and this is an important point, it is the nature and extent of any harm which then must be taken into account.

17.89This Application will not lead to substantial heritage harm as there is no direct effect on heritage assets.

17.90Paragraph 208 of the Framework states that 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.

London Plan

17.91Chapter 7 of the London Plan sets out heritage policies. Policy HC1 Heritage conservation and growth and Policy HC3 Strategic and Local Views are the primacy policies for this application. They reflect the Framework.

The Local Plan

17.92LCS Policy 16 states that “The Council will ensure that the value and significance of the borough’s heritage assets and their settings, which include the Maritime Greenwich World Heritage Site, conservation areas, listed buildings, archaeological remains, registered historic parks and gardens and other non-designated assets such as locally listed buildings, will continue to be monitored, reviewed, enhanced and conserved according to the requirements of government planning policy guidance, the London Plan policies, local policy and English Heritage best practice.”

17.93Policy 37 of the LDMLP, in reference to non-designated heritage assets, states that “The Council will protect the local distinctiveness of the borough by sustaining and enhancing the significance of non-designated heritage assets.”

17.94A full breakdown of the policy position is set out in the detailed built heritage, townscape and visual impact assessment (BHTVIA) which supports the Application.

Assessment

17.95The BHTVIA, prepared by Montagu Evans concludes the following:-

▪ Views – 39 views formed the visual assessment. 9 of these views are recorded as having a notable change as a result of the Proposed Development. The visual assessment concludes that the Proposed Development forms a positive contribution to the overall visual amenity and enjoyment of Lewisham town centre and wider environs, introducing high-quality, responsive architecture which is well-considered in response its surrounding context. The Proposed Development will not give rise to any adverse visual and amenity impacts.

▪ Heritage Assets – There will be no significant likely adverse effects on designated heritage receptors (World Heritage Sites, listed buildings, conservation areas, Scheduled Monuments or Registered Parks and Gardens). In terms of non-designated heritage receptors, it is anticipated that there will be a likely moderate adverse effect on just one of the receptors (nos. 156-160 Lewisham High Street), during the construction stage and when factoring in the cumulative assessment; this receptor is a building of townscape merit identified by the Council, albeit in its present form it is hidden by a metal façade. There is no identified impact on any of the locally listed buildings.

▪ Townscape – There will no significant likely adverse effects on the four identified townscape receptors (identified as Lewisham town centre; the residential zone; Greenwich Park and Blackheath Garden; and parks and open green space). In fact, there will be a likely moderate beneficial effect on Lewisham town centre during the operational stage and when factoring in the cumulative assessment.

17.96The BHTVIA concludes that the Proposed Development will not result in any harm to the significance of any identified designated heritage assets. The demolition of nos.156-160 Lewisham High Street, a non-designated heritage asset, is required however to be considered in accordance with Paragraph 209 of the Framework, which requires a proportionate assessment based on the significance of the non-designated heritage asset and the overall planning benefits of the Proposed Development.

17.97The effects on heritage assets have been assessed against the public benefits of the Proposed Development set out in this Statement.

18Detailed Component – Assessment of Buildings N1 and N2

18.1 This section of the Planning Statement summarises the design approach adopted by the two buildings within the Detailed Component – Building N1 and Building N2.

18.2 This section has been separated into the following key themes:

▪ Principle of uses;

▪ Scale and massing;

▪ Residential mix;

▪ Internal amenity;

▪ External amenity;

▪ Playspace;

▪ Single and dual aspect units;

▪ Accessible units;

▪ Car parking;

▪ Cycle parking; and

▪ Urban Green Factor

18.3 This section should be read in conjunction with other sections of this Planning Statement, including Section 14 (Living Uses – C3 Housing), Section 15 (Living Uses – Co-Living), Section 17 (A Well-Designed Place) and Section 20 (Environmental Planning Considerations), the last of which addresses the Application’s compliance (as a whole) with policy and guidance on matters of transport, energy and sustainability, ecology and biodiversity, flood risk, microclimate, air quality and noise.

18.4 This section should also be read alongside other supporting documents, including:

▪ Design and Access Statement (Volume 2 – Building N1; Volume 3 – Building N2; Volume 4 – Landscape Design; Appendix 3 – Accessibility Statement; Appendix 11 – Open Space Assessment);

▪ Housing Statement;

▪ Transport Assessment (including Appendix 3 – Parking Management / Arrangement Plan);

▪ Sustainability Statement (and appendices);

▪ Energy Assessment (and appendices);

▪ Internal Daylight, Sunlight and Overshadowing Assessment;

▪ Waste Management Plan;

▪ Flood Risk Assessment (and appendices);

▪ Heritage Impact Assessment;

▪ Co-Living Management Plan (in the case of Building N1).

Principle of Uses

18.5 The overring policy support for new residential (Class C3) and new Co-Living (Sui Generis) within Phase 1a is set out in Sections 14 and 15 respectively.

18.6 The Site, including Building N1 and Building N2, sits at the heart of Lewisham Town Centre.

18.7 At the London policy level, the London Plan identifies the Site within the New Cross/Lewisham/Catford Opportunity Area for 13,500 homes and 4,000 jobs by 2041. It is identified as a location with significant development capacity to accommodate new housing, commercial development and infrastructure (of all types) linked to existing or potential improvements in public transport connectivity and capacity.

18.8 The London Plan identifies Lewisham as a Major Town Centre, with high residential growth potential and a strategic area for regeneration. Major Centres are defined as having significant employment, leisure, service and civic functions.

18.9 R19 designates the Site within Central Area Site Allocation 2. The site allocation seeks comprehensive mixed-use redevelopment comprising compatible main town centre, commercial, community and residential uses. This draft allocation recognises that the Site forms the heart of Lewisham and that comprehensive redevelopment of the shopping centre, alongside the delivery of a significant amount of new housing on upper floors, will enhance the quality of the town centre and help it to achieve Metropolitan Centre status.

18.10The principle of both Co-Living (Sui Generis) in Building N1 and residential (Class C3) in Building N2 is supported by the London Plan and by both adopted and emerging local policy.

Scale and Massing

18.11This central town centre location is considered entirely suitable for the heights proposed within Phase 1a.

18.12The Detailed Component comprises a 23 storey building (N1) and a 15 storey building (N2) at their tallest parts.

18.13As set out in Section 17 of this Statement, the emerging Lewisham local plan supports the principle of tall buildings across the Site, offset from the High Street, up to 25 storeys or greater, having regard to relevant material considerations, and a wider public benefit to justify the design of the development.

18.14The Detailed Component conforms in the main with the locational requirements of tall buildings as per R19 Policy QD4. A small portion of Building N1 does sit just outside of the tall building zone (designated by Figure 5.5 in the R19), specifically an element of the roof structure of the shorter part of the building as a result of the sloping roof design. However, as set out in this statement (including in Section 17), the significant public benefits justify this approach.

18.15The proposed scale and massing of Buildings N1 and N2 has been the subject of detailed engagement with the Council, key stakeholders and the public to ensure that it is appropriate, aligns well with the proposed buildings in the Outline Component and responds and contributes well to the existing built form in the town centre.

18.16Further detail regarding the appropriateness of the proposed scale and massing of Building N1 and Building N2 is contained within Section 17 of this Planning Statement

Residential Mix

18.17Both the London Plan and local policy (adopted and emerging) sets out requirements for residential developments in terms of housing mix.

18.18Across the Application as a whole, the Applicant has sought to deliver a genuine mix of unit types to achieve a balanced community which is informed by a number of significant considerations, including viability and the unique circumstances of the Site, including its highly accessible location. Residential accommodation is therefore proposed to be provided within a range of housing types.

18.19The housing mix within Building N2 includes a mix of homes which is aimed at achieving quick delivery and to accommodate for local need.

18.20The proposed housing mix for Building N2 in Table 18-1 below.

Table 18-1 Detailed Component Proposed Housing Mix

18.21The proposed mix in Building N2 is considered to be acceptable taking into account the wider strategic requirements of the Council and the need to incentivise delivery.

18.22Further justification of the proposed approach to housing mix in Building N2 is contained in Section 14 of this Planning Statement

Internal Amenity

18.23Building N1 and Building N2 have been carefully designed to ensure that a high-quality level of internal amenity provision is provided for future residents, in terms of size and type, having regard to the relevant standards and guidance

18.24The internal layouts of both buildings have been subject to a rigorous design process to ensure the private units and associated shared communal areas are sufficient in size and are of highquality design. The design of the internal arrangements has been an iterative process in collaboration with the Council and DRP, whilst the Applicant’s design and consultant team has utilised its significant relevant experience and key learnings from other operational sites.

18.25In terms of Building N1, residents will have access to a range of internal communal spaces, including shared kitchen and dining lounge areas, bookable kitchen and dining rooms, creative recording studio, co-working and agile working spaces, collaboration spaces, bookable meeting rooms, residents social hub, games breakout area, sitting/reading rooms, a cinema room, gym, well-being studio, laundry room and flexible events space.

18.26The Mayor’s recently published LPG for Large-Scale Purpose-Built Shared Living (2024) sets out a series of recommended benchmarks for new Co-Living schemes in London to seek to achieve. The Council’s position is to align with the Mayor’s LPG. Building N1 meets and exceeds all of these benchmarks, demonstrating the Applicant’s commitment to providing an exemplar Co-Living building.

18.27Further detail on the internal amenity spaces provided within Building N1 (including compliance with the Mayor’s LPG) is set out within the Design and Access Statement (Volume 2)

18.28In terms of Building N2, residents will have access to internal amenity areas, including a gym, working space and storage areas.

18.29Further detail on the internal amenity spaces provided within Building N2 is set out within the Design and Access Statement (Volume 3).

External Amenity

18.30The external amenity provision within Building N1 and Building N2 has been carefully designed to ensure that a high-quality level of internal amenity provision is provided for future residents, having regard to the relevant standards and guidance

18.31In terms of Building N1, the Mayor’s LPG for Large-Scale Purpose-Built Shared Living (2024) sets recommended benchmarks for on-site external amenity. Building N1 meets and exceeds the benchmark.

18.32In terms of location, the principal external amenity space is provided at Level 9, which is connected to the primary shared dining areas, thereby creating a highly usable and generous amenity area. A secondary external amenity space is provided at Level 1.

18.33Further detail on the external amenity spaces provided within Building N1 (including compliance with the Mayor’s LPG) is set out within the Design and Access Statement (Volume 2).

18.34In terms of Building N2, residents will benefit from private balconies, plus communal terrace areas. Building N2 complies with the requirements set out in the London Plan.

18.35Further detail on the internal amenity spaces provided within Building N2 is set out within the Design and Access Statement (Volume 3).

Play space

18.36Building N2 will contain 119 residential (Class C3) units and as such play space is incorporated into the proposal.

18.37The requirement for play space is contained within the Mayor’s Shaping Neighbourhoods: Play and Informal Recreation supplementary planning guidance (September 2012).

18.38The proposed play space provision for Building N2 is confirmed in Table 18-2 below.

Table 18-2 Play space within Building N2

18.39As confirmed in Table 18-2, the level of play space provided is fully compliant with policy.

18.40Building N1 will attract no children and as a result does not propose any play space

18.41Further detail on the play space provided with Building N2 is set out within the Design and Access Statement (Volumes 3 and Volume 4).

Single and Dual Aspect Units

18.42The design of Buildings N1 and N2 has factored in key standards as appropriate to the CoLiving and residential (Class C3) uses proposed. The metrics relating to single and dual aspect units are set out in Table 18-3.

Table 18-3 Single and Dual Aspect Units

18.43In the context of Building N2, London Plan Policy D6 (Housing Quality and Standards) requires new residential development to be of high-quality design and provide adequately sized rooms, and comfortable and functional layouts. Minimum internal space standards are set out in Table 3.1 of the London Plan, and key qualitative aspects including layout, orientation and form are set out in Table 3.2. Thepolicy states that provision of dual aspect homes should be maximised where possible, and a single aspect dwelling should only be provided where it is considered a more appropriate design solution in order to optimise the site’s capacity (in line with Policy D3).

18.44As a result of the proposed building typology of Building N2, over 37% of the units will be dual aspect (plus an additional 8% with enhanced aspect). There will be no single aspect north facing homes within Building N2. The approach has been to maximise dual aspect homes within the context of the development as a whole.

18.45Further detail and justification for the proposed design for Building N1 and Building N2 is set out within the Design and Access Statement (Volumes 2 and 3 respectively).

Accessible Units

18.46Both Buildings N1 and N2 include accessible units for wheelchair users, in line with relevant policy and guidance.

18.47Building N1 includes 46 wheelchair homes (10.3% of total units), whilst Building N2 includes 11 wheelchair units (9% of total units). The Detailed Component therefore achieves 10.1% wheelchair accessible homes (M4(3)).

18.48Further detail and justification for the proposed design for Building N1 and Building N2 is set out within the Design and Access Statement (Volumes 2 and 3 respectively).

Car Parking

18.49Building N1 and Building N2 are both car-free, save for Blue Badge parking. Building N1 incorporates 1 Blue Badge space which serves the Co-Living use, whilst Building N2 incorporates 3 Blue Badge spaces for the residential use. The commercial elements for both buildings are not served by any car parking.

18.50The London Plan (2021) sets the primary standards for parking. The London Plan requires 3% Blue Badge parking for both Co-Living uses and residential uses from the outset, with the ability to show provision for a further 7% (10% total).

18.51However, it is considered that the 3% Blue Badge provision at the outset for Building N1 (equating to 13 spaces), is an overprovision based on the Site’s location and the anticipated demand for Blue Badge bays from the future occupiers of the Co-Living building. It is therefore considered, in this instance, that a provision of 1 Blue Badge space for Building N1 is sufficient. This level of Blue Badge provision has been accepted recently elsewhere in London for proposed Co-Living developments in locations which have similar characteristics to the Site, and specifically Building N1.

18.52In terms of Building N2, 3 Blue Badge spaces are proposed, which equates to a 3% provision This is considered to be sufficient considering the highly accessible but constrained nature of the Site.

18.53This level of car parking provision is entirely appropriate given the specifics of the Site, and in this case Buildings N1 and N2. The Site benefits from the highest PTAL rating possible, i.e. 6b (excellent).

18.54Th overall provision of Blue Badge Parking in Phase 1a has been discussed and agreed with the Council at the pre-application stage.

18.55Further detail and justification for the proposed approach to car parking for Building N1 and Building N2 is provided within the Transport Assessment which supports the Application.

Cycle Parking

18.56Building N1 includes 336 long stay cycle spaces for the Co-Living residents with a further 12 short stay cycle spaces for visitors, whilst Building N2 includes 200 long stay cycle spaces for residents with a further 4 short stay cycle spaces for visitors. A total of 32 cycle spaces serve the commercial units across both buildings.

18.57This cycle provision is fully in accordance with the relevant standards. In terms of Building N1, the Mayor’s recently published LPG for Large-Scale Purpose-Built Shared Living (2024) sets a recommended benchmark of 0.75 spaces per unit (which would equate to 334 spaces), whilst the London Plan (2021) provides the guidance for Building N1 cycle provision.

18.58Furthermore, the cycle parking provision in both Buildings N1 and N2 will fully align with relevant size standards. The proposed split of cycle parking type will be 5% larger Sheffield stands, 20% standard Sheffield stands and 75% two-tier stands, whilst 5% of all cycle parking spaces will be accessible for larger cycles (as per LCDS standards).

18.59Further detail and justification for the proposed approach to car parking for Building N1 and Building N2 is provided within the Transport Assessment which supports the Application.

Urban Green Factor

18.60London Plan Policy G5 (part a) requires all major developments to include urban greening as a fundamental element of site and building design and by incorporating measures such as high-quality landscaping, green roofs, green walls and nature-based sustainable development.

18.61London Plan Policy G5 (part b) sets out that individual boroughs should develop an Urban Greening Factor (‘UGF’) to identity the appropriate amount of urban greening in new developments. The UGF should be based on a number of factors and be tailored to local circumstances. In the interim, Policy G5 (part b) recommends a target score of 0.4 for predominantly residential developments, and a target score of 0.3 for predominantly commercial developments.

18.62At the local level, adopted policy does not make specific reference to UGF. However, emerging local policy aligns itself to London Plan Policy G5. Specifically, draft Policy GR5 of the R19 states that major development proposals must increase green cover on site to achieve the recommended target UGF in the London Plan, unless it can be suitably demonstrated that this is not feasible.

18.63The Application achieves a site-wide UGF score of up to 0.4, with Building N1 and Building N2 contributing to this overall score. The recommended target in both regional and local planning policy is therefore achieved.

19The Re-Use of Buildings

Introduction

19.1 This section of the Planning Statement considers the proposed re-use of buildings as part of the Application proposals within the context of the Application, the Framework and Development Plan policy.

The Framework

19.2 The Framework addresses re-use of buildings in a very broad sense at Chapter 14 meeting the challenge of climate change, flooding and coastal change and more directly at paragraph 157 as set out below.

The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. 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 the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.

19.3 As has been tested recently, the Framework does not apply specific, individual, weight to ‘the conversion of existing buildings’, rather it includes them as one of several objectives that the ‘planning system’ should embrace.

London Plan

19.4 There are no direct policies that seek re-use of buildings as a priority, or first stage of hierarchy, in the London Plan albeit there some supporting text on building re-use.

Policy GG5 Growing a good economy

19.5 GG5 recognises and promotes the benefits of a transition to a low carbon circular economy to strengthen London’s economic success (H).

Policy GG6 Increasing efficiency and resilience

19.6 GG6 seeks to improve energy efficiency and support the move towards a low carbon circular economy, contributing towards London becoming a zero carbon city by 2050 (A)

Policy D3 Optimising site capacity through the design-led approach

19.7 Supporting Figure 3.2 shows a hierarchy for building approaches which maximises use of existing materials. Diminishing returns are gained by moving through the hierarchy outwards, working through refurbishment and re-use through to the least preferable option of recycling materials produced by the building or demolition process. The best use of the land needs to be taken into consideration when deciding whether to retain existing buildings in a development. (3.3.12)

19-1 London Plan Figure 3.2 Circular economy hierarchy for building approaches

Policy SI 2 Minimising greenhouse gas emissions

19.8 SI2 expects that major development should be net zero-carbon. This means reducing greenhouse gas emissions in operation and minimising both annual and peak energy demand in accordance with the energy hierarchy (A)

19.9 Development proposals referable to the Mayor should calculate whole life-cycle carbon emissions through a nationally recognised Whole Life-Cycle Carbon Assessment and demonstrate actions taken to reduce life-cycle carbon emissions (F)

Policy SI 7 Reducing waste and supporting the circular economy

19.10SI7 relates to how the proposal’s design and construction will reduce material demands and enable building materials, components and products to be disassembled and re-used at the end of their useful life (SI 7)

March 2022 Whole Life-Cycle Carbon Assessments LPG

19.11WLC Principles no. 1 - Retaining existing built structures for reuse and retrofit, in part or as a whole, should be prioritised before considering substantial demolition, as this is typically the lowest-carbon option. Significant retention and reuse of structures also reduces construction costs and can contribute to a smoother planning process (Table 2.1)

19.12If substantial demolition is proposed, applicants will need to demonstrate that the benefits of demolition would clearly outweigh the benefits of retaining the existing building or parts of the structure. Retention should be seen as the starting point; this will usually be the most sustainable option as it can make an immediate contribution toward the Mayoral objective of London becoming a zero carbon city by 2030, as well as reflecting the need to both move towards a low-carbon circular economy (set out in Good Growth objective GG6 – Increasing efficiency and resilience) and to push development up the waste and energy hierarchies (see Policy SI 2 – minimising greenhouse gas emissions; and Policy SI 7 – reducing waste and supporting the circular economy) (3.1.3)

Figure

19.13Table A2.1 WLC benchmarks (excluding modules B6, B7 and D) are provided for various land uses including residential (actual and aspirational)

March 2022 Circular Economy Statement LPG

19.14Paragraph 4.6 requires and sets out requirements for Pre-Redevelopment Audits and PreDemolition Audits to be carried out at pre-application stage:

Lewisham Emerging Policy

19.15There is no Whole Life carbon / demolition policy in the emerging Lewisham Plan.

Assessment

19.16LPG guidance expects that “applicants will need to demonstrate that the benefits of demolition would clearly outweigh the benefits of retaining the existing building or parts of the structure. Retention should be seen as the starting point.”

19.17The Application is supported by the following documents which have tested the scope of building retention and demolition. These assessments have drawn conclusions that in some cases, the benefits of demolition would clearly outweigh the benefits of retaining the existing building or parts of the structure. In other cases, the benefits of retention are considered to outweigh demolition. These documents include:

▪ Design and Access Statement

▪ Circular Economy Statement (Bioregional)

▪ Whole Life Carbon Assessment (Bioregional)

19.18The overall assessment has concluded that a number of the following buildings will be retained, in full or part, within the application boundary as a positive output of the assessment undertaken including Lewisham House and the Corporation of London Building

19.19To complement this approach, the redline application boundary, within R19 Site Allocation LCA2 has been drawn to exclude a number of properties along the High Street, which inform local character and appearance and are therefore retained.

20Environmental Planning Considerations

20.1 Within this section of the Planning Statement, we consider the following planning matters:

▪ Transport

▪ Energy and sustainability

▪ Flood risk

▪ Microclimate

▪ Daylight, sunlight and overshadowing

▪ Air quality

▪ Noise and vibration Transport

20.2 A Transport Assessment, Construction Method Statement/Logistics Plan, outline Environmental Management Plan (including Site Waste Management Plan), Delivery and Servicing Plan, Parking Management / Arrangement Plan and Framework Travel Plan have been prepared by SLR in accordance with planning policy requirements and are submitted in support of this Application. Detailed highways access plans have also been prepared.

Framework

20.3 When determining planning applications, development should only be refused on highway grounds where they would have an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. In demonstrating an acceptable impact, planning applications should be supported by a Transport Assessment that can outline any likely impacts of the proposal (Paragraph 111).

London Plan

20.4 Similarly, the London Plan requires all development proposals to ensure that impacts on transport capacity and the transport network, at both a corridor and local level, are fully assessed via the submission of a Transport Assessment prepared in accordance with TfL’s Transport Assessment Best Practice Guidance (Policy T4). Policy T5 of the London Plan seeks to remove barriers to cycling, whilst Policy T6 seeks to restrict car-parking, noting that car-free development should be the starting point for all development proposals, with the exception of disabled parking.

20.5 The Mayor of London published the Mayor’s Transport Strategy in March 2018, which sets out how the Healthy Streets approach should be used to reshape transport in London. Healthy Streets is Transport for London’s approach to assessing development and it aims to reduce the dependence on the private vehicle and encourage more Londoners to walk, cycle and use public transport. These principles will be assessed against the Proposed Development within the Transport Assessment.

The Local Plan

20.6 The Council’s adopted policy documents promote sustainable movement and transport within the town centre. This includes:

▪ In terms of the LCS, Policy 14 (part 1) states that “Access and safety of pedestrians and cyclists throughout the Borough will be promoted and prioritised.” Policy (part 4) outlines that car-free developments need to ensure that on-street parking is managed so that overspill onto the street will not occur.

▪ The LTCLP identifies the that Lewisham town centre benefits from a number of highquality public transport nodes, therefore making it well-equipped for residential and retail developments. Policy LTC21 relates to ‘Sustainable Transport’, and highlights a desire to improve the pedestrian and cyclist experience at key town centre locations, including Lewisham High Street, Molesworth Street, and the Lewisham High Street / Molesworth Street / Engate Street roundabout.

▪ The LDMLP acknowledges that a key desire for new developments is to be located in proximity to excellent active travel and public transport nodes. Both student accommodation and commercial units are specifically highlighted within this document as use classes that require good sustainable transport connections.

20.7 In terms of the Council’s emerging policy, the R19 sets out that within Lewisham Town Centre, Development proposals must be designed to improve access and permeability in the town centre and its surrounding area, particularly where sites are to be delivered through comprehensive redevelopment. This includes new or enhanced east-west routes through the Lewisham Shopping Centre site.

Transport Assessment and Supporting Documents

20.8 A Transport Assessment, Construction Method Statement/Logistics Plan, outline Environmental Management Plan (including Site Waste Management Plan), Delivery and Servicing Plan, Parking Management / Arrangement Plan and Framework Travel Plan

20.9 The Transport Assessment, Delivery and Servicing Plan and other transport supporting documents submitted in support of this Application confirms that the Application responds directly to the relevant London Plan and local policy requirements, as well as the National Planning Policy Framework. The following section provides a planning assessment of the Proposed Development in respect of:

▪ Site Connections and Access

▪ Routes through the Site

▪ Car Parking

▪ Cycle Parking

▪ Travel Demand

▪ Delivery and Servicing

▪ Refuse

Site Connections and Access

20.10The Site is very well connected to walking, cycling and public transport facilities. There is good access available to local rail stations and several bus stops / services available within the vicinity. The Site enjoys a PTAL of 6b.

20.11The Proposed Development seeks to maximise the Site’s location in terms of the proximity to public transport facilities, to ensure that the town centre evolves in line with adopted and emerging policy.

20.12The Detailed Component includes a series of works to facilitate vehicular access to the Site. These works are as follows:-

▪ Removal of the northern ramp access to the shopping centre;

▪ Creation of a two-way southern ramp on Molesworth Street including the southern servicing egress route;

▪ Creation of a two-way southern ramp on Molesworth Street including the southern servicing egress route;

▪ Access to the north-east of the Site (Detailed Component of the Application);

▪ Egress from the north-east of the Site (Detailed Component of the Application);

▪ Access from High Street to the southern part of the Site (Outline Component of the Application); and

▪ Relocation of the existing toucan crossing on Molesworth Street.

20.13The detailed access works are shown on the following drawings prepared by SLR:

▪ 184420/PD02/01 – Detailed Application Site Access;

▪ 184420/PD02/02 – Southern Service Route;

▪ 184420/PD02/03 – Southern Ramp Access;

▪ 184420/PD02/04 – Service Deck;

▪ 184420/PD02/06 - Proposed Molesworth Street Crossing; and

▪ 184420/PD02/07 – Temporary Southern Ramp

20.14These works will complement the highway works which form part of the Outline Component which will be subject to reserved matters applications at a later date

20.15The significant improvements to connections proposed represents compliance with both in adopted and emerging local planning policy.

Routes through the Site

20.16The hierarchy and layout of the routes through the Site have been designed to ensure permeability for pedestrians and cyclists. The street level areas within the Proposed Development have been designed around the requirements for pedestrian and cyclist activity (as appropriate) and for the minimisation of impacts by vehicular movement, in line with the general transport narrative outlined in the London Plan, specifically Policy T1. Active frontages

along all routes will further contribute to an attractive public realm, of which the design is led by the Healthy Streets principles advocated by the Mayor of London policy documents.

20.17The Proposed Development will provide a north-south pedestrian route, enabling shoppers, residents, employees and visitors to travel from Lewisham station and Lewisham Gateway to the north, through the centre of the Site, towards Lewisham High Street. Moreover, new eastwest pedestrian routes will also be created opening out the centre of the Proposed Development to the High Street and Molesworth Street, enhanced through proposals for a new toucan crossing on Molesworth Street to facilitate this.

20.18The Proposed Development ensures that the journey taken by pedestrians is prioritised, whether that is visitors to the shopping centre, or residents accessing their homes. This approach is line with policy and guidance.

20.19The Proposed Development includes the removal of the existing multi storey car park which would increase travel by sustainable modes and reduce highway impact.

Car Parking

20.20Given the sustainable transport connectivity of the Site, and in line with policy, the Proposed Development will be car free with the exception of accessible parking spaces for disabled users (for residents of and visitors to the proposed residential, student accommodation and CoLiving) Therefore, the Proposed Development includes the removal of the 836 car parking spaces within the existing MSCP which currently serves the shopping centre. A survey undertaken in June 2023, demonstrates that the car park is currently under-utilised, with a maximum occupancy of 44% capacity during a weekday or Saturday.

20.21For the Detailed Component, Building N1 incorporates 1 Blue Badge space which serves the Co-Living use, whilst Building N2 incorporates 3 Blue Badge spaces for the residential use. The commercial elements for both buildings are not served by any car parking. The London Plan requires 3% Blue Badge parking for both Co-Living uses and residential uses from the outset, with the ability to show provision for a further 7% (10% total). In terms of Building N1, it is considered that the 3% Blue Badge provision at the outset would be an overprovision based on the Site’s location and the anticipated demand for Blue Badge bays from the future occupiers of the Co-Living use; it is therefore considered, in this instance, that a provision of 1 Blue Badge space for Building N1 is sufficient. This level of provision has been accepted recently elsewhere in London for proposed Co-Living developments in locations which have similar characteristics to the Site. In terms of Building N2, 3 Blue Badge spaces are proposed, which equates to a 3% provision and is considered sufficient considering the highly accessible but constrained nature of the Site. The overall provision of Blue Badge Parking in Phase 1a has been discussed and agreed with the Council at the pre-application stage.

20.22For the Outline Component, as this is not submitted in detail, the exact quantum of the parking provision is not determined and will be secured within a subsequent reserved matters application. The Transport Assessment sets out however that 46 Blue Badge spaces will be provided beyond Phase 1a.

20.23The approach to car parking is considered to be in line with policy. Further detail on the approach is provided within the Parking Strategy Note continued as Appendix H to the Transport Assessment (details approach to car clubs and taxi drop-off).

Cycle Parking

20.24The Proposed Development seeks to encourage the use of cycling as a mode of travel and integrates a sufficient and policy compliant quantum and variety of long-stay and short-stay cycle parking

20.25In terms of the Detailed Component, Building N1 includes 336 long stay cycle spaces for the Co-Living residents with a further 12 short stay cycle spaces for visitors, whilst Building N2 includes 200 long stay cycle spaces for residents with a further 4 short stay cycle spaces for visitors. A total of 32 cycle spaces serve the commercial units across both buildings. This cycle provision is fully in accordance with the relevant standards, namely the Mayor’s recently published LPG for Large-Scale Purpose-Built Shared Living (2024) for Building N1 and the London Plan (2021) for Building N2. In addition, the cycle parking provision in both Buildings N1 and N2 will fully align with relevant size standards: 5% larger Sheffield stands, 20% standard Sheffield stands and 75% two-tier stands, whilst 5% of all cycle parking spaces will be accessible for larger cycles (as per LCDS standards).

20.26In terms of the Outline Component, the Application will provide cycle parking in line with the London Plan (2021), in terms of residents and visitors The location of this cycle parking will be confirmed in subsequent reserved matters applications.

20.27The approach to cycle parking is considered to be in line with policy. Further detail on the approach is provided within the Parking Strategy Note continued as Appendix H to the Transport Assessment.

Delivery and Servicing

20.28The Proposed Development will utilise four servicing points as part of the comprehensive delivery and servicing strategy. Servicing vehicles are proposed to access the Site from the following points:

▪ Northeastern Access (via the A20 Rennell Street);

▪ Northwestern Access (via Molesworth Street);

▪ Service Deck (via Molesworth Street); and

▪ Southern Access (via Lewisham High Street).

20.29In terms of the Detailed Component, Phase 1a will be serviced from the northeastern servicing access point, with the egress onto Lewisham High Street. Buildings N1 and N2 benefit from dedicated service yards at ground floor level. The Transport Assessment and the Delivery and Servicing Plan sets out the assumptions and strategy associated with Phase 1a.

20.30In terms of the Outline Component, the Transport Assessment and the Delivery and Servicing Plan provides the strategy and approach.

20.31In total, as set out in the Transport Assessment, it is estimated that the Proposed Development will attract 355 servicing and delivery vehicles per day, equivalent of 710 two-way trips (residential uses and commercial uses combined). These commercial trips are not new trips in their own right, due to no overall increase in occupied commercial floorspace proposed.

20.32In summary, the Delivery and Servicing Plan outlines how access in the Proposed Development will be controlled by the Site management For Phase 1a, the strategy for delivery and servicing is for it all to take place at ground level via the dedicated service yards.

Refuse

20.33The Site Wide Operational Waste Management Strategy which supports the Application sets out a number of guiding principles to ensure that waste arising from the Proposed Development is managed in a sustainable manner, with minimal impact on the environment.

20.34The space assigned for waste management in each plot / building and the future management and movement of wastes has been given careful consideration. In particular, the location of refuse rooms / stores (with respect to user access and vehicle stopping location and refuse collection crew access) has been considered within the limitations of other back of house space requirements. Residential refuse room locations at ground floor for bin presentation for the Council’s waste collection crew access has been refined and optimised to be as efficient as possible and to allow direct collection and return of bins where possible.

20.35In terms of the Detailed Component, detailed calculations and space planning have been undertaken for Building N1 and Building N2 Significant effort has been placed around resident and commercial tenant access to refuse rooms / stores, and the location of the refuse rooms / stores with respect to service yards and refuse collection vehicle access and stopping locations. The proposed waste management designs and solutions are considered to be the most efficient and appropriate for Buildings N1 and N2, acknowledging other back of house demands and servicing requirements.

20.36In terms of the Outline Component, indicative waste requirements have been estimated based on the proposed residential unit numbers and commercial unit areas (incorporating standard assumptions). A robust estate management solution with compactor skips for recyclables and residual waste is proposed for the service deck. All waste management needs, space requirements and access considerations will be considered in further detail during detailed design development in advanced of the future reserved matters applications.

Summary

20.37The Transport Assessment (and supporting documents) confirms that in addition to according with national, regional and local transport policies, the Proposed Development will not result in an adverse impact on highway safety or a severe impact on the highway network.

Energy and Sustainability

London Plan

20.38Policy SI2 of the London Plan outlines policy in relation to minimising greenhouse gas emissions. The core of the policy states that major development should be net zero-carbon and adhere to the following energy hierarchy:

1) Be lean: use less energy and manage demand during operation;

2) Be clean: exploit local energy resources (such as secondary heat) and supply energy efficiently and cleanly;

3) Be green: maximise opportunities for renewable energy by producing, storing and using renewable energy on-site; and

4) Be seen: monitor, verify and report on energy performance.

20.39Policy SI3 of the London Plan relates to energy infrastructure, and specifically requiring major development proposals to develop energy masterplans. Policy SI4 further requires development proposals to demonstrate through the energy strategy how they reduce the potential for internal overheating and reliance on air conditioning systems.

The Local Plan

20.40The LCS includes a number of high-level objectives and policies that developers should adhere to. LCS Strategy Objective 5 sets out that the Council will take action to ensure that climate change is adapted to and mitigated against, including those measures necessary to create a low carbon borough and reduce carbon emissions. LCS Policy 7 sets out the Council will adopt a partnership approach to implement the principles of ‘avoidance, mitigation and adaptation’ to reduce Lewisham’s carbon emissions, by:

a. raising awareness of climate change issues to promote and incentivise sustainable methods of living and working across the borough

b. promoting the sustainable and efficient use of land and improving the integration of land use and transport in accordance with national and regional requirements

c. applying the London Plan policies relevant to climate change including those related to: air quality, energy efficiency, sustainable design and construction, retrofitting, decentralised energy works, renewable energy, innovative energy technologies, overheating and cooling, urban greening, and living roofs and walls

d. recognising the role that the reuse and modification, where appropriate, of heritage assets can play in securing sustainable development in order to reduce carbon emissions.

20.41The LTCLP provides further requirements. In particular, Policy LTC24 sets out the need to consider communal heating and cooling to future-proof developments, whilst LTC25 focuses on future adaptability.

Energy and Sustainability Assessment

20.42In line with the London Plan, the Energy Statement, prepared by WSP, demonstrates that the Proposed Development follows the Energy Hierarchy of ‘Be Lean’, ‘Be Clean’ and ‘Be Green’ to reduce the carbon dioxide emissions of the entire Proposed Development.

20.43The Proposed Development has been designed to include high efficiency fabric and passive design measures such as external shading. Active measures such as high efficiency heat pumps and PV panels have also been included in the design to ensure the building is allelectric and supports the UK’s decarbonisation goal.

20.44The reductions under the GLA Energy Hierarchy have been maximised against the Part L 2021 notional building performance. The notional building is already a very energy efficient building but through collaborative engineering and design, the Proposed Development has incorporated solutions that results in a 71% reduction in carbon emissions compared to the notional building.

20.45An energy assessment using the Passive House Planning Package modelling tool has been carried out to ensure a more accurate prediction of the operational energy. As the design progresses, the analysis will be updated to ensure the building will meet its low energy targets.

20.46The proposals for the Proposed Development outlined within the Energy Strategy are considered to maximise the potential carbon savings which can be achieved on the Site through the provision of the following measures:

▪ A highly efficient building fabric design to minimise heat gains and heat losses while allowing for efficient access to daylight;

▪ Low energy ventilation system including efficient heat recovery, reduced fan power and optimised control system to minimise energy consumption during operation;

▪ PV allocation on roofs has been maximised;

▪ 100% low energy lighting, maximised use of LED and low energy fixtures;

▪ Low carbon heat provided by Air Source Heat Pumps;

▪ Smart efficient control systems and building management system will be provided to allow for efficient control and monitoring of MEP services to minimise energy waste.

20.47Under Policy SI2 of the London Plan, where it is clearly demonstrated that the zero-carbon target cannot be fully achieved on-site, any shortfall can be provided in agreement with the borough through a cash in lieu contribution to the borough’s carbon offset fund. The Energy Strategy confirms the position and sets out a proposed cash-in-lieu contribution based on a price of £95/tonnefor a period of 30 years according tothe GLA Energy Assessment Guidance.

20.48The Sustainability Statement, prepared by Bioregional, provides a comprehensive overview of how thew Proposed Development has embedded sustainability principles across the Site as a whole and on individual building plots (the Outline Component and the Detailed Component).

20.49The Applicant has integrated sustainability into the core design principles. This early and intentional focus on sustainability has resulted in a development that not only meets but exceeds the requirements set out in the London Plan and within local planning policy. The Proposed Development is an exemplar scheme, offering high quality and sustainable residential and non-residential uses. The Sustainability Statement also details the commitment to extending these sustainability principles into the construction and operational phases.

20.50In relation to sustainability considerations, the Sustainability Statement outlines the key sustainability features included as part of the Proposed Development. These include:

▪ Embodied Carbon Excellence – The project has set an ambitious aspirational embodied carbon target of less than 500kgCO2e/m2 for all stages. This target is ambitious and reflects the latest best practices in sustainable construction.

▪ Energy Efficiency – Energy efficiency is a cornerstone of the development. The approach not only meets but exceeds current energy efficiency standards, making the buildings some of the most energy efficient in London.

▪ Biodiversity and Green Spaces – The Proposed Development adopts a unified meadow planting strategy that is specifically designed to enhance biodiversity. The approach creates richm diverse ecosystems within the urban environment, providing habitats for a variety of species. As a result of this approach, the Proposed Development achieves a score of 346% Biodiversity Net Gain (site wide). Significant tree planting across the Site will improve air quality and urban cooling, and contribute to the overall aesthetic and ecological value of Lewisham Town Centre.

▪ Urban Greening and Climate Resilience – The introduction of new trees and green spaces throughout the Site is strategically designed to improve climate resilience by mitigating the urban heat island effect, enhancing stormwater management, and providing shaded areas that make outdoor space more usable and comfortable. The Proposed Development achieves an Urban Greening Factor score of up to 0.4 (Sitewide), which meets the GLA’s requirements.

▪ Inclusive Design – The Proposed Development’s approach to public open spaces, community and cultural facilities and mixed-use development will foster a sense of belonging and well-being amongst residents and visitors. The Proposed Development prioritises social sustainability.

20.51 The Sustainability Statement confirms that both the Detailed Component and the Outline Component will achieve at least BREEAM Excellent.

20.52The GLA’s Whole Life Carbon guidance document has been considered throughout the design process and the principles established have been adopted. A Whole Life Carbon Report, prepared by Bioregional, has been submitted in support of the Application and outlines in full the methodology and results in respect of the estimated emissions. The Report demonstrates how the targets associated with Whole Life Carbon have been met and how the process of further reducing and optimising the whole carbon emissions will continue throughout the planning and design process, with a further assessment undertaken prior to occupation to measure the impact of the materials.

20.53A Circular Economy Statement, prepared by Bioregional, supports this Application and sets out the approach to incorporating circular economy principles, as defined in the GLA’s Circular Economy Guidance document, within the Proposed Development. Key specific commitments include:

▪ Apply the Waste Hierarchy and follow the six principles of circular economy;

▪ Divert a minimum of 95% of all construction and non-hazardous demolition waste from landfill for reuse, recycling or recovery;

▪ Divert a minimum of 95% of inert excavation waste from landfill for beneficial use;

▪ To facilitate recycling levels in operation which will exceed the municipal waste recycling target of 65% by 2030; and

▪ To target a minimum 20% reused and recycled content by value of the Proposed Development.

Summary

20.54The proposed approach to energy, sustainability, Whole Life Carbon and Circular Economy accords with the requirements of national, regional and local policy.

Flood Risk Framework

20.55The Framework (at Paragraphs 165-175) covers policy pertaining to flood risk. The Framework statesthat inappropriatedevelopment in areas atrisk offlooding should be avoided by directing development away from areas at highest risk of flooding. Furthermore, Paragraphs 167-174 outline the requirements relating to sequential and exception testing where development is located on land within Flood Zones 2-3.

London Plan

20.56London Plan Policy SI12 states that development proposals should ensure that flood risk is minimised and mitigated, and that residual risk is addressed.

20.57London Plan Policy SI13 relates to sustainable drainage, with Part B seeking to ensure that development proposals aim to achieve greenfield run-off rates and ensure that surface water run-off is managed as close to its source as possible, with a preference for green over grey features.

The Local Plan

20.58LCS Policy 10 aims to “implement the spatial planning and development control recommendations of the Strategic Flood Risk Assessment and the Sequential Test” in order to reduce flood risk and conserve water resources. LCS Policy 11 sets out that the Council will work closely with the Environment Agency with regards to the local river networks and references the use of the Ravensbourne River Corridor Improvement Plan to be used as a guide for development along the waterway.

Assessment

20.59A detailed Flood Risk Assessment has been prepared by Expedition to support the Application.

20.60In terms of flood risk, the Applicant has agreed the context with the EA and LLFA. Environment Agency (EA) flood map shows that the northern half of the Site is within Flood Zone 3, whilst a Strategic Flood Risk Assessment previously prepared by the Council (2018) suggests that approximately half the Site is in Flood Zone 3 and approximately a third of the site would be in Flood Zone 3b (the “functional flood plain” of the River Ravensbourne and River Quaggy). As a result of this discrepancy, the Applicant has undertaken further investigative work to seek to agree the current context with the EA and LLFA. As a result of this work, a revised flood map for the Site has been produced which shows that approximately 10% of the Site area is now in Flood Zone 3, most of which is in Flood Zone 3b

20.61In terms of the Sequential Test, the Site has been designated to be redeveloped in both the adopted and the emerging Lewisham local plans. In the R19, proposed Site Allocation 2 seeks a comprehensive mixed-use redevelopment comprising compatible main town centre,

commercial, community and residential uses. As part of the development of the emerging local plan, sequential testing has been carried out which has established that no other location in areas with lower flood risk were suitable for the proposed development.

20.62The Flood Risk Assessment confirms full compliance with the Exception Test.

20.63The Flood Risk Assessment confirms that the Proposed Development incorporates several flood risk mitigation measures to protect the Proposed Development from flooding, including:

▪ Setting finished floor levels in relation to design flood levels, considering use class;

▪ Temporary flood protection and flood resilience measures where finished floor levels cannot be raised above design flood levels; and

▪ Safe emergency access and egress.

20.64In terms of managing flood risk off-site, loss of floodplain storage volume has been compensated on a level-by-level and volume-by-volume basis, in accordance with planning guidance. The flood storage lost to the west of the Site has been compensated by lowering levels within the Northern Square and connecting these levels to flooded area along Rennell Street. The Flood Risk Assessment confirms that for all level bands, existing floodplain storage is either matched or increased and, ss such, the Proposed Development will not increase flood risk elsewhere (it will result in a small reduction of flood risk).

20.65In terms of surface water management, a Sustainable Drainage Strategy, prepared by Expedition, supports the Application. The key strategic principles as set out in the strategy are summarised as:

▪ Adopting the most sustainable disposal route for surface water drainage flows, in line London Plan Policy SI13 and with the drainage hierarchy set out by the SUDS Manual CIRIA C753;

▪ Flood resilience and no increase in flood risk off-Site. Peak discharge limited to peak greenfield runoff rate in line with London Plan Policy SI 13 and LLFA requirements;

▪ Control runoff at source, maximise opportunities for enhancement of the landscape and biodiversity and control pollution following best practice in line with The SUDS Manual CIRIA C753;

▪ Management of stormwater flows in efficient multi-function open water bodies integrated with green infrastructure;

▪ Effective management and maintenance of the drainage infrastructure to ensure performance over design life in line with SUDS Manual CIRIA C753; and

▪ Smart harvesting of rainwater for irrigation of the podium landscape planting.

20.66This approach ensures that surface water flood risk is managed, in line with policy.

Summary

20.67The Flood Risk Assessment submitted in support of the Application confirms compliance with the relevant London Plan and local policy, plus national guidance

Microclimate

Framework

20.68Paragraph 135 of the Framework sets out that developments should, inter alia, function well an add to the overall quality of the area (a); optimise the potential to accommodate and sustain an appropriate amount and mix of development (e); and create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users.

London Plan

20.69The London Plan places importance on the creation and maintenance of a high-quality environment for London. The following policies specifically relate to wind microclimate:

▪ Policy D3: “Buildings […] massing, scale and layout […] should complement the existing streetscape and surrounding area. Particular attention should be paid to the design of the parts of a building or public realm that people most frequently see or interact with in terms of its legibility, use, detailing, materials and location of entrances. Creating a comfortable pedestrian environment with regard to levels of […] wind.”

▪ Policy D8: “Consideration should also be given to the local microclimate created by buildings, and the impact of service entrances and facades on the public realm… Ensure that appropriate shade, shelter, seating […] with other microclimatic considerations, including temperature and wind, taken into account in order to encourage people to spend time in a place.”

▪ Policy D9: “Wind […] around the building(s) and neighbourhood must be carefully considered and not compromise comfort and the enjoyment of open spaces, including water spaces, around the building... Air movement affected by the building(s) should […] not adversely affect street-level conditions… The cumulative visual, functional and environmental impacts of proposed, consented and planned tall buildings in an area must be considered when assessing tall building proposals and when developing plans for an area. Mitigation measures should be identified and designed into the building as integral features from the outset to avoid retro-fitting”.

Adopted and Emerging Local Plan

20.70The Council’s adopted local policy does not set out specific policies in relation to wind and microclimate.

20.71The emerging R19 does set out the Council’s position. It prioritises pedestrian-friendly neighbourhoods, efficient transportation options, and high-quality public spaces. Key points from the plan include:

▪ Prioritizing sustainable transport: Walking, cycling, and public transport are key modes of transportation within the borough;

▪ Creating comfortable public spaces: The importance of shading, shelter, and protection from adverse weather conditions in public spaces is recognised;

▪ Managing building heights: The plan recognises that tall buildings, if poorly located or designed, can have negative impacts on the local environment and community; and

▪ Addressing climate change: New development should not adversely affect air quality or the amenity of local communities.

20.72By focusing on these areas, the R19 seeks to create a more sustainable, equitable, and pleasant living environment for residents.

Assessment

20.73Chapter 13 of the Environmental Statement assesses the likely significant effects of the Proposed Development in terms of wind-microclimate.

20.74The method of assessment for the pedestrian level wind microclimate has been based on wind tunnel testing undertaken by RWDI. Details of the wind tunnel methodology are included within RWDI’s Pedestrian Level Wind Microclimate report (Appendix 13.1 to the ES). In addition, a CFD analyses has been used as a complementary tool to the wind tunnel, allowing further scenarios to be studied and comparisons made between the scenarios analysed computationally.

20.75The wind tunnel assessment comprises 5 scenarios as summarised below:

▪ Scenario 1 Existing Baseline: Assessment of the existing buildings on the Site with the existing surrounding context;

▪ Scenario 2 Future Baseline: Assessment of the existing buildings on the Site in combination with future (consented and under consideration) schemes;

▪ Scenario 3 Proposed Scenario (Detailed Component): Assessment of the Detailed Component with the existing surrounding context;

▪ Scenario 4 Proposed Scenario (Combined): Assessment of the Detailed Component and Outline Component (maximum parameters) combined, with existing surroundings; and

▪ Scenario 5 Cumulative Effects: Assessment of the Detailed Component and Outline Component (maximum parameters), in combination with future (consented and under consideration) schemes in the surrounding area.

20.76Scenario 3, when mitigation is included, results in negligible wind effects in all areas of the Site both at ground and elevated levels. The Detailed Component is therefore considered to be acceptable.

20.77Scenarios 4 and 5 will result in the windiest conditions, which is to be expected on the basis that they have assessed the maximum parameters of the Outline Component (i.e. the tallest and densest massing tested). However, although the maximum parameters represent a very robust assessment for the purposes of assessing the Outline Component, Scenarios 4 and 5 do represent an unrealistic worst-case scenario in terms of form of development, on the basis that the individual plots within the Outline Component will be developed further in detail (at the reserved matters stage) meaning that the building form, massing and mitigation will be refined, as required by planning condition. On this basis, the developed detailed design for the Outline Component plots will, in due course, provide improved wind conditions. This is demonstrated through the CFD analysis summarised in Chapter 13 of the ES, which illustrates that a carefully developed design will provide significant improvements to the wind conditions versus an unrealistic maximum parameters scenario where buildings are modelled as simple extrusions with no particular design or shape intended.

20.78The reserved matters stage will also provide the opportunity for the Outline Component plots to potentially provide further mitigation, if it is deemed to be required through testing at that stage.

20.79The CFD analysis undertaken demonstrates that it will be possible for the Outline Component to deliver significant improvements to the wind conditions, with a solution to be found at the reserved matters stage.

Summary

20.80In light of the above, it is considered that the Proposed Development complies with the Development Plan policies identified, and the R19.

Daylight, Sunlight and Overshadowing

Framework

20.81There are no national planning policies directly relating to daylight, sunlight and overshadowing. However, Chapter 11 of the NPPF deals with ‘Making effective use of land’, and under the sub-heading ‘Achieving appropriate densities’ it states at paragraph 123:

“Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities and ensure that developments make optimal use of the potential of each site. In these circumstances; …

(c) local planning authorities should refuse applications which they consider fail to make efficient use of land, taking into account the policies in this framework. In this context, when considering applications for housing, authorities should take a flexible approach in applying policies or guidance relating to daylight and sunlight where they would otherwise inhibit making efficient use of the site (as long as the resulting scheme would provide acceptable living standards).

London Plan

20.82London Plan Policy D6 (Housing Quality and Standards) states that the design of development should provide sufficient daylight and sunlight to new and surrounding housing that is appropriate for its context, whilst avoiding overheating, minimising overshowing and maximising the usability of outside amenity space. London Plan Policy D9 additionally states that sunlight penetration around tall buildings and their neighbourhoods must be carefully considered.

20.83The Mayor’s Housing SPG 2016 makes clear that ‘an appropriate degree of flexibility’ should be applied when assessing the impacts of new development on surrounding properties and within developments. It is worth noting the following extracts from Paragraphs 1.3.45-46:

“…Guidelines should be applied sensitively to higher density development, especially in opportunity areas, town centres, large sites and accessible locations, where BRE advice suggests considering the use of alternative targets. This should take in to account local circumstances; the need to optimise housing capacity; and scope for the character and form of an area to change over time.

The degree of harm on adjacent properties and the daylight targets within a proposed scheme should be assessed drawing on broadly comparable residential typologies within the area and of a similar nature across London. Decision makers should recognise that fully optimising housing potential on large sites may necessitate standards which depart from those presently experienced but which still achieve satisfactory levels of residential amenity and avoid unacceptable harm.”

20.84The Mayor’s Housing Design Quality and Standards SPG (2021) set out the following daylight, sunlight and overshadowing standards:

▪ Standard C5.3.1: New dwellings should achieve a minimum average daylight factor (ADF) target value of 1 per cent for a bedroom and 1.5% for a living room.

▪ Standard C5.3.2: Proposed development should maximise quality and availability of sunlight and natural light in outdoor spaces, particularly in winter. Outdoor spaces should benefit from at least two hours of daylight on 21st March into 50% of space in line with BRE Guidance Standard.

▪ Standard C5.3.3: All homes must provide for direct sunlight to enter at least one habitable room for part ofthe day. Living areas and kitchen dining spaces should preferably receive direct sunlight.

The Local Plan

20.85Policy DM32 of the LDMLP sets out the requirements of housing design, layout and space standards. Part 1 (b) of DM32 sets out that the Council expects all new residential development to provide a satisfactory level oof privacy, outlook and natural lighting, both for future residents and neighbours.

20.86In terms of emerging local policy, the R19 at Policy QD8 (part E) sets out that development proposals for housing must be designed to protect and enhance amenity of building occupants.

Assessment

20.87Chapter 12 of the Environmental Statement assesses the likely significant effects of the Proposed Development in terms of daylight, sunlight, overshadowing, solar glare and light pollution.

20.88The existing context is an important factor in the assessment of daylight, sunlight and overshadowing. The current Site is comprised of a large number of low-medium rise commercial buildings and, as such, where residential buildings are located in nearby proximity to the Site, their existing daylight and sunlight amenity levels are generally high and, in many cases, exceed the BRE guideline recommendations (levels which are predicated upon a more suburban environment). As a result, it is therefore inevitable, particularly in the case of major town centre regeneration opportunity areas such as the Site, that if redevelopment proposals are to deliver in accordance with local planning policy aspirations and make efficient use of brownfield land in line with the Framework (and as recognised by the proposed government reforms), a noticeable degree of change in daylight and sunlight levels will naturally be experienced.

20.89However, notwithstanding this important context, the detailed technical assessments show that for the operational phase of the Proposed Development (factoring in both the Detailed Component and the Outline Component (maximum parameters)), the compliance levels, when

measured against the BRE Guidelines (2022) recommendations, are very good for an urban town-centre location. Key findings include:

▪ In particular, 74% of all the habitable windows tested around the Site meet the BRE guideline targets for Vertical Sky Component (‘VSC’), with 86% of all habitable rooms also meeting the No Sky Line (‘NSL’) Daylight Distribution criteria.

▪ For sunlight, 94% of all southerly orientated habitable rooms will exceed the BRE recommendations for Annual Probable Sunlight Hours (‘APSH’). This demonstrates that a high proportion of the sensitive receptors around the Site will experience daylight and sunlight effects of negligible significance.

▪ In terms of overshadowing, whilst there will naturally be some gardens and amenity spaces surrounding the Site that experience a noticeable alteration in direct sunlight, of the 221 areas assessed, 91% will exceed the BRE guideline recommendations and therefore experience a negligible effect.

20.90The assessment work has also tested the illustrative masterplan, which considers a realistic interpretation of the Outline Component parameters (together with the Detailed Component), rather than the full extent of the Outline Component maximum parameters. This assessment indicates a further reduced daylight and sunlight effect upon the sensitive receptors (when compared to the Outline Component maximum parameters), with 82% of windows meeting BRE recommendations for VSC, 92% meeting the NSL criteria, and 96% meeting the APSH sunlight targets. This demonstrates that the extent of any significant effects arising from the Outline Component can be positively reduced, mitigated and, in many cases, designed out at the future reserved matters stage through the adoption of the illustrative masterplan principles.

20.91In terms of internal daylight and sunlight conditions for the Detailed Component, the detailed assessment work confirms acceptability of living accommodation.

20.92In terms of light pollution and solar glare, there will be negligible to minor adverse effects as a result of the Proposed Development. These effects are not considered to be significant.

Summary

20.93In light of the above and the assessment work undertaken, it is considered that the Proposed Development complies with the Framework, relevant Development Plan policies, and the R19.

Air Quality

Framework

20.94The Framework sets out that planning policies and decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and Clean Air Zones, and the cumulative impacts from individual sites in local areas. Opportunities to improve air quality or mitigate impacts should be identified, such as through traffic and travel management, and green infrastructure provision and enhancement.

London Plan

20.95The London Plan and the Mayor’s Air Quality Strategy (2010) seek to minimise the emissions of key pollutants and to reduce concentrations to levels at which no, or minimal effects on human health are likely to occur.

20.96Policy D1, D3 and SI1 (Improving air quality) states that large-scale redevelopments should propose methods of achieving an Air Quality Positive approach through the development. Air Quality Assessments should be submitted with all major developments unless transport and building emissions will be less than previous or existing uses, and a preliminary AQA should be carried out before designing the development to inform the design process. Where emissions need to be reduced, this should be done on-site unless it can be proven to be impractical or inappropriate and so long as equivalent air quality benefits can be demonstrated.

The Local Plan

20.97The LCS seeks to improve local air quality which the Council will seek to do by minimising negative air quality impacts (Policy 9).

20.98The LTCLP sets out the vision and objectives for the regeneration of thetown centre. Objective 7 seeks to address the high levels of pollution in the town centre and states “To protect, enhance and restore the Rivers Quaggy and Ravensbourne and ensure that the town centre can mitigate and adapt to the risks arising from air pollution and climate change by focusing on protecting the area against extreme weather conditions, mitigating heat island effects and delivering energy efficient and low carbon development.”

Assessment

20.99As part of the Environmental Statement submitted in support of this Application, WSP has carried out an assessment of the likely significant effects arising from the Proposed Development upon local air quality and includes a range of mitigation measures to be implemented in relation to local air quality. The assessment is contained at Section 7 of the Environmental Statement.

20.100 For the construction phase, a qualitative assessment of the potential impacts on local air quality from construction activities has been carried out. This identified that overall, there is a medium to high risk of dust soiling impacts and a medium to high risk to human health due to increases in particulate matter concentrations as a result of construction activities. However, through good site practice and the implementation of suitable mitigation measures, the impact of dust and particulate matter releases would be significantly reduced. The residual effects of dust and particulate matter generated by construction activities on air quality are therefore negligible and not significant.

20.101 The non-road mobile machinery and associated plant equipment that will be used within the Site during the construction phase was assessed qualitatively and found to have a negligible effect on local air quality during the construction phase.

20.102 In addition, a quantitative assessment of emissions to air from construction traffic was undertaken. The results show that the Proposed Development would cause an imperceptible

increase in concentrations and no significant adverse effects are predicted. Therefore, no construction phase traffic mitigation measures are required.

20.103 Whilst the Proposed Development is car free (other than blue badge spaces), an operational phase exposure assessment has been undertaken given the location of the Site within an urban area in a declared AQMA. The modelling determined that future concentrations would be considerably below (more than 5%) the relevant air quality objectives. On this basis, there is no air quality grounds for refusal.

Summary

20.104 It is considered that the Proposed Development complies with the relevant national and development plan policy for air quality.

Noise and Vibration

Framework

20.105 The Framework requires new development to be appropriate to its location when considering the effects of pollution sources including noise (Paragraph 191). Subsequently, planning applications should demonstrate that the development will not unacceptably introduce or be detrimentally sensitive to existing pollution sources, with all applications expected to demonstrate that new noise sources can be successfully mitigated and/or reduced to minimise potential impacts.

London Plan

20.106 London Plan Policy D1 and D3 supports the principle to reduce, manage and mitigate noise to improve health and quality of life.

20.107 In addition, Policy D13 sets out a number of initiatives to reduce, manage and mitigate noise to improve health and quality of life, including avoiding significant adverse noise impacts; mitigating and minimising existing and potential adverse impacts of noise in the vicinity of new developments; and improving and enhancing the acoustic environment.

The Local Plan

20.108 The LCS recognises the need to address climate change through promoting a low-carbon borough, acknowledging that one way this can be done is through minimising the environmental impacts of development including water, noise and air pollution.

20.109 The LDMLP sets out at Policy DM26 the requirements specific to noise and vibration for new development to ensure impacts are minimised.

Assessment

20.110 As part of the Environmental Statement submitted in support of this Application, Hoare Lea has carried out an assessment of the likely significant effects arising from the Proposed Development in terms of noise and vibration. The assessment is contained at Chater 6 of the Environmental Statement.

20.111 An assessment of the potential noise and vibration effects associated with the Proposed Development has been undertaken in line with national and local planning policy and with reference to appropriate standards and guidance documents.

20.112 Mitigation measures will need to be incorporated to reduce noise and vibration from particular activities, for example during construction, to limit the effect on nearby receptors.

20.113 Following the implementation of appropriate mitigation measures, no significant residual effects have been identified. A summary of the potential effects, including details of mitigation measures and the likely residual effects of noise and vibration associated with the Proposed Development are set out in Chapter 6 of the ES (Table 6.21).

Summary

20.114 It is considered that the Proposed Development complies with the relevant national and development plan policy for noise.

21Planning Obligations and Community Infrastructure Levy

21.1 This section provides a summary of the main legislation, policy and guidance relating to planning obligations and Community Infrastructure Levy (“CIL”). Appendix 5 provides a Draft Heads of Terms for proposed Planning Obligations.

National

Legislation

and Policy

Community Infrastructure Levy Regulations 2010 (as amended)

21.2 Regulation 122 (Limitation on use of planning obligations) states that a planning obligation may only constitute a reason for granting planning permission for the development if the obligation is:

▪ (a) necessary to make the development acceptable in planning terms;

▪ (b) directly related to the development; and

▪ (c) fairly and reasonably related in scale and kind to the development.

NPPF

21.3 The tests set out above are also set out in paragraph 57 of the NPPF. The NPPF states in paragraph 55 that local planning authorities should consider whether otherwise unacceptable development could be made acceptable through the use of conditions or planning obligations. Planning obligations should only be used where it is not possible to address unacceptable impacts through a planning condition.

NPPG

21.4 The NPPG provides guidance on CIL. Paragraph 129 Reference ID: 25-129-20190901 relates to phased development and states that the regulations allow for both detailed and outline permissions (and therefore ‘hybrid’ permissions as well) to be treated as phased developments for the purposes of the levy. This is expected to be especially useful for large scale development, which is an essential element of increasing housing supply.

21.5 The paragraph goes onto state that large scale developments which are delivered over a number of years face particular issues in relation to cashflow and the delivery of on-site infrastructure. Each phase of a phased planning permission is a separate chargeable development for CIL purposes and therefore would be liable for separate payments for each phase.

21.6 Finally, the paragraph states that the principle of phased delivery must be expressly set out in the planning permission. Local authorities should work positively with developers to allow such developments to be delivered in phases.

21.7 As set out in the Description of Development and as explained in Section 8 of this Planning Statement, the Proposed Development is a phased development. Phasing plans are provided in the ‘Phasing’ section of the DAS. It is therefore proposed that any planning permission would be phased for CIL purposes and the Applicant will look to agree a suitable condition with LBL during the determination of the planning application.

London Plan

21.8 Policy T9 – ‘Funding transport infrastructure through planning’ states that the Mayor will charge the Mayoral CIL (“MCIL”) to secure funding towards transport infrastructure of strategic importance such as Crossrail 2, and potentially other strategic transport infrastructure.

21.9 Policy DF1 –‘Delivery of the Plan and Planning Obligations’ states that development proposals should provide the infrastructure and meet the other relevant policy requirements necessary to ensure that they are sustainable and to support delivery of the Plan.

21.10. In February 2019 the Mayor adopted the Mayor of London Community Infrastructure Levy 2 Charging Schedule (January 2019) (“MCIL2”). MCIL2 came into effect on 1 April 2019. LBL lies within MCIL2 Charging Band 2 where the rate is £60 per m² for all development aside from health and education uses.

Local Policy and Guidance

21.11Core Strategy policy 21 – ‘Planning Obligations’ describes how the need to provide infrastructure, services and/or facilities to address the impact of new development will be considered by the local planning authority from the outset of the planning application process.

21.12In 2015 the Council published the ‘Lewisham Planning Obligations: Supplementary Planning Document’. This sets out a range of topic areas, including affordable housing, wheelchair housing, local labour and business, transport, public realm and carbon offsetting and describes the required form of obligation.

21.13Draft policy DM2 – ‘Infrastructure funding and planning obligations’ of the Lewisham Local Plan: Submission Version (January 2023) states in Part D that the Council will seek planning obligations on a case-by-case basis having regard to the relevant policy requirements of the statutory Development Plan, development specific impacts, appropriate mitigation (including additional facilities or requirements made necessary by the development), viability and the statutory tests for the use of planning obligations

21.14LBL adopted their CIL Charging Schedule in 2015. The Site is located the Zone 2 where CIL rates are as follows:

▪ Residential - £70 per m²

▪ Use Class B - £0 per m²

▪ All other uses - £80 per m²

22Public Benefits and The Planning Balance

22.1 Within this section, we explain why the Proposed Development accords with relevant development plan policies, and the development plan when read as a whole.

22.2 It confirms that the Proposed Development accords with the Framework and is sustainable development within the meaning of the Framework.

22.3 As such, the Proposed Development benefits from the statutory presumption as set out in Section 38(6) of the Planning and Compulsory Purchase Act 2004; Section 70(2) of the Town and Country Planning Act 1990 (“TCPA 1990”); and further to paragraph 11 c) of the Framework, planning permission should be granted without delay

Public Benefits

22.4 NPPG advises that public benefits may follow from many developments and could be anything that derives from paragraph 8 of the Framework, set out below

▪ an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure;

▪ a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and

▪ an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.

22.5 Public benefits should flow from the Proposed Development. They should be of a nature or scale to be of benefit to the wider public However, benefits do not always have to be visible or accessible in order to be genuine public benefits

22.6 Benefits are a material consideration under 38(6); and case law and NPPG ties them into Framework Paragraph 8.

22.7 Even if conflict was found with development plan policies, this conflict would need to be weighed in the planning balance against the public benefits of the Proposed Development and material considerations

22.8 As such, the Application benefits from the statutory presumption as set out in Section 38(6) of the Planning and Compulsory Purchase Act 2004; Section 70(2) of the Town and Country Planning Act 1990 (“TCPA 1990”); and further to paragraph 11 c) of the Framework, it should be granted planning permission without delay.

Public Benefits of the Proposed Development

22.9 We consider there to be a substantial number of public benefits arising from the Proposed Development which are very significant material considerations and weigh greatly in favour of granting planning permission when undertaking a balanced planning judgement. These material considerations are set out below.

The Framework and Ministerial Statements

22.10The Framework is an important material consideration, carrying significant weight.

22.11It provides the national context for planning in England, including Central Government’s economic and housing policy objectives and promotion of high-quality design

22.12The Framework was last updated in December 2023 and is currently out to consultation in respect of further revisions seeking to apply greater weight to the optimisation of brownfield land, and the application of the presumption in favour of sustainable development.

22.13The government has recently issued many ministerial statements, which we summarise in Section 3 of this statement, and these are material in the determination of the application.

The presumption in favour of sustainable development

22.14There is a shortage of land for housing and employment in the borough and cannot meet its 5 year housing land supply requirement to meet future needs. This is not sustainable.

22.15As the Council has confirmed that it is unable to demonstrate a 5-year housing land supply as required by national policy (the Framework paragraph 11), the presumption in favour of sustainable development applies, as the policies which are most important for determining the application are out-of-date and the benefits of the application significantly and demonstrably outweigh any adverse effects. This presumption carries significant weight.

Optimisation of brownfield land

22.16There is a significant ambition by the Government, the Mayor of London and the Council to boost the supply of homes through the redevelopment first and foremost of accessible brownfield sites

22.17London Plan development plan policies reflect national policy and include many policies which seek the best use and optimisation of land in sustainable locations to meet significant housing needs and to deliver jobs whilst delivering high quality design

22.18The Application responds directly to significant pressure for growth, and in particular housing need within London and the Council by redeveloping a highly sustainable brownfield site as explained below.

The Site

▪ It is brownfield land and is not sustainable in its current form due to extensive vacant floorspace and time expired buildings.

▪ Is a highly sustainable location (PTAL 6b).

▪ Is within the New Cross/Lewisham/Catford Opportunity Area for 13,500 homes and 4,000 jobs by 2041.

▪ Is identified as a location with significant development capacity to accommodate new housing, commercial development and infrastructure (of all types), linked to existing or potential improvements in public transport connectivity and capacity.

▪ Is currently within a Major town centre classification (in London Plan) identified for high residential growth potential and a strategic area for regeneration.

▪ Is crucial to the success of achieving the London Plan’s aspiration to be reclassified as a town centre of Metropolitan importance.

▪ Is the key part of the town centre which is recognised (in the LCS) as the borough’s most important commercial centre and its largest shopping area.

▪ Is subject to its own site allocation in the R19 proving the importance for comprehensive mixed-use redevelopment.

22.19The Proposed Development also directly responds to R19 Site Allocation LCA2 requirements for 2,150 new homes and 60,291sqm of town centre floorspace, making a meaningful contribution to housing delivery, to provide new infrastructure and to contribute positively to the wider regeneration coming forward in the local area which is subject to major growth

22.20The equivalent number of C3 homes proposed is 2,230 homes, and 62,618sqm of town centre floorspace is proposed which is a significant benefit of the Application, particularly given the shortfall that exists within the borough at present.

22.21Paragraph 124(c) of the Framework applies substantial weight to this public benefit.

Economic and employment benefits

22.22The Proposed Development seeks the provision of new Town Centre floorspace.

22.23The Proposed Development will deliver a range of flexible non-residential uses which will complement and support the existing offer within Lewisham Town Centre and contribute to the principal planning objectives of enhancing the potential for Metropolitan Centre classification, whilst also supporting town centre vitality and viability and ensuring a cohesive and complete town centre experience.

22.24The proposed non-residential uses are designed to be flexible and accommodate a range of uses which will not only meet a local need but provide activity and vibrancy throughout the Site, creating a link and connection between the proposed buildings and public open space.

22.25In excess of 2,500sqm GEA of non-residential floorspace is proposed within Phase 1a (the Detailed Component) which is envisaged to accommodate uses such as shops, cafes and restaurants, commercial floorspace and drinking establishments (all within Class E and Sui Generis) helping to create a sense of place and provide facilities for its new residents, in addition to existing workers and residents in the area

22.26A further c. 40,000sqm GEA of non-residential floorspace has been indicatively provided for within the later outline phases which will be capable of accommodating a range of uses akin to Phase 1a, albeit also incorporating community and cultural uses.

22.27Through enhanced connections through this Site and to the wider area these new services and facilities and employment floorspace will be highly attractive.

22.28The Proposed Development will support the economic growth ambition, including by:

▪ The biggest investment in the town centre for nearly 50 years, securing its future and growth with more than £1bn in investment

▪ Widening the offer in the town centre, with improved food and beverage, leisure and cultural provision, improving Lewisham’s place as one of South London’s best town centres.

▪ Reconnecting and tying together the town centre with new pedestrian and cycle routes, removing severance and fragmentation.

▪ Construction employment of c. 770 FTE jobs over the ten-year construction period on site, with a further c. 510 FTE jobs offsite.

▪ A net increase in employment of between 900 and 1,910 FTE jobs, once the development is complete.

▪ The delivery of up to c. 1,719 homes, 445 co-living homes, and up to 661 student bedspaces, contributing 13% of the ten-year London Plan target for LBL.

▪ The development provides a new place for up to around 4,350 people to live in the town centre.

▪ These homes would generate up to £3.8m in New Homes Bonus for local priorities.

▪ This increase in employment will generate gross value added (additional economic activity) of between £30 million and £160 million per year

▪ Securing business rates revenue for the Council.

▪ An increase in resident and employee spending of between £28.7 - £31.8 million annually.

▪ The delivery of publicly accessible open space, including The Park, Northern Square, Eastern Terrace and New Model Market.

▪ New homes for students, supporting the higher education sector in the borough, and developing skills locally.

22.29Furthermore, indirect spending arising from new employees and residents will be up to £38 million per year and the Proposed Development will generate in the region of approximately £27 million of CIL, in addition to s106 contributions.

22.30Paragraph 85 of the Framework applies significant weight to this public benefit.

Delivery of Class C3 housing

22.31The Application will deliver a significant number of new homes for the Borough and London, specifically 119 new homes within the first phase, with indicatively a further 1,524 in the subsequent outline phases. This will result in a meaningful contribution towards the Council’s housing need and delivery targets.

22.32The new homes will include affordable homes which will prioritise social rented homes for the benefit of Lewisham local residents.

22.33A range of sizes will be provided (in both the Detailed Component and the Outline Component), meaning that the Proposed Development can offer housing choice to future potential residents.

22.34These new homes will be designed to the highest standards, providing high quality living space for its residents and creating spaces that people want to live in.

22.35Paragraph 124 of the Framework applies significant weight to this public benefit.

Delivering a genuine choice of living accommodation

22.36The Application will also deliver a significant quantum of of other forms of accommodation for the Borough and London as a whole

22.37445 Co-Living homes (Sui Generis) are proposed in the first phase, with 661 student rooms (Sui Generis) provided in the subsequent phases. These rooms will also result in a meaningful contribution to the Council’s housing need and delivery targets of an equivalent of 511 new homes.

22.38This accommodation will be designed to the highest standards, providing high quality living space for its residents and creating spaces that people want to live in.

22.39Paragraph 124 of the Framework applies significant weight to this public benefit.

Co-Living benefits

22.40The proposed Co-Living use in Building N1 will deliver a number of significant benefits, including social and economic benefits

22.41These benefits include:

▪ Contribution to affordable housing – The smaller residential units within Building N1 create more value relative to their floorspace (versus larger units which result in a less efficient scheme constraining viability and the quantum of affordable housing that can be provided) This in turn enables Co-Living to contribute towards affordable housing delivery.

▪ Economic and social benefits –

▪ Attracting young people: The Co-Living development will broaden the variety of housing types available locally, filling an important gap in provision and helping to

retain a mixed and balanced community. Co-Living is able to attract new people to an area as a result of its differentiate offer.

▪ Local spending: Associated with the above, the new Co-Living homes will bring additional local spending to Lewisham – that is spending that will benefit local shops, leisure and service providers.

▪ Council tax: Co-Living also generates a substantial contribution to local council tax, benefitting the Borough.

▪ Speed of delivery: Co-Living can be delivered and occupied quickly meaning homes can quickly contribute to meeting un-met housing need.

▪ Retaining residents in the borough: The Co-Living building will play a ‘stepping stone’ role in the town and across the Borough. Co-Living buildings foster a genuine sense of community, owing to the nature of the operation and its residents (i.e. single people who live, work and socialise in one building). This community fosters friendships amongst residents, helped by the many social, health and wellbeing events hosted by their operators. In this context, the aim for all Co-Living schemes is to allow residents to become settled in a location, particularly where people are new to the area. This sense of community will provide a stronger platform for those leaving Co-Living to remain in the borough. The future transition from Co-Living to other residential products within the town will clearly be beneficial to the wider community. Lewisham has a history of retaining its residents; the 2021 Census confirmed that 35% of all people who moved into a home in Lewisham in 2020 moved from elsewhere within the borough, with a further 43% moving from elsewhere in London (the Lewisham pattern is higher than the average for inner London (31%)).

Environmental

22.42The Application results in a number of significant environmental improvements The Framework gives substantial weight to the value of using suitable brownfield land within settlements for homes.

22.43Through the landscape led approach to the Proposed Development, an Urban Greening Factor of up to 0.4 (site wide) is achieved in accordance with the London Plan targets. The new open space will deliver enhanced air quality, a sustainable urban drainage solution and new opportunities for biodiversity across the Site.

22.44In particular, the approach to landscaping enables the Proposed Development to achieve a Biodiversity Net Gain of up to 346% (Site-wide)

Open space and greening

22.45The landscape-led approach to the Proposed Development provides significant publicly accessible open space, including the raised landscape area which sits are the heart of the Site (which measures at least 5,255sqm), plus the Northern Square (which measures at least 3,360sqm). These areas are all for the benefit and enjoyment of new and existing residents and the wider community including people working on Site and in the wider town centre.

22.46This open space provision will provide a high-quality space for all which will have a positive impact on the health and wellbeing of the community both on-Site and within the surrounding area.

22.47The proposed publicly accessible open space is supplemented by green and brown roofs, plus private and building-specific areas within specific buildings in the Proposed Development. The two buildings within the Detailed Component include roof top open space.

22.48Furthermore, collectively the proposed open space, public realm and landscaping provide significant opportunities for ecological and local biodiversity improvements

Design

22.49The Proposed Development is of outstanding architectural quality, prepared by four awardwinning architects working collaboratively: Studio Egret West (Outline Component); Mae and Studio Multi (Building N1); and Archio (Building N2).

22.50The approach reflects the unique nature of the Site and lifts the standard of design more generally in the area. A high quality landscape and design led solution ensures a sensitive design approach, but one which also maximises the opportunity for placemaking.

22.51The proposed approach has been considered carefully and has been informed by design review through both pre-application engagement with the Council and the GLA, but also importantly through the Council’s Design Review Panel.

22.52The Proposed Development seeks to create a new high-quality place that sets it apart from other development sites across London, contributing to the aspiration of Lewisham achieving Metropolitan status.

22.53The Proposed Development has been designed in accordance with government guidance on design as well as regional and local design policies.

22.54Paragraph 139 (a) and (b) of the Framework applies significant weight to this compliance and significant weight should be applied to this aspect of the Proposed Development

Heritage benefits

22.55The Proposed Development places a significant emphasis on heritage and conservation matters, enabling an appropriate and viable strategy that respects the existing context which the Site sits within. The Proposed Development seeks to maximise its contribution to the heritage context as part of the design led solution for creating a new and unique place in Lewisham in line with policy requirements.

22.56The proposals do not conflict with the Planning (Listed Building and Conservation Areas) Act 1990. The site does not contain any designated heritage assets, and Historic England do not raise objection. There is no harm to designated heritage assets, and beneficial effects arising.

22.57The Proposed Development would provide a heritage benefit, comprising the improvement of the immediate setting of a number of locally listed buildings along Lewisham High Street, as well as the Grade II listed Clock Tower. The proposals would replace the existing shopping

centre building with a number of buildings of a high architectural quality, as well as substantial public realm and landscaping enhancements.

22.58These positive impacts are to be awarded great weight in accordance with Framework paragraph 205.

Public Engagement

22.59The Application Proposals have been informed by extensive public engagement and consultation with key stakeholders over a period of 4 years.

22.60The Applicant has engaged with the public, securing significant levels of support for the emerging proposals, and many economic, social and environmental benefits of the Proposed Development derive from this engagement, including the following:-

▪ Providing further evening and nighttime options - ‘The Street’ was establishing to accommodate a dedicated food and beverage offer.

▪ The provision of more cultural spaces - introduction of a music venue to the south of the application site.

▪ Maximising the soft landscaping within the public spaces alongside the provision of places to sit and socialise, including areas for younger people - the Eastern Terrace is one example of a space that provides all of these features.

Public Benefits Conclusion

22.61These public benefits weigh heavily in favour of a grant of planning permission and are material considerations which outweigh non-compliance with the development plan should it be found to exists, which we consider that it does not.

22.62The benefits of the Proposed Development are of a nature and scale to be of benefit to the public at large and deliver sustainable development and planning policy aims for economic, social and environmental development objectives.

22.63It will support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes are provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places. The proposal will protect and enhance the natural, built and historic environment whilst making effective use of land and using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy. The significant contribution to the economy is also a significant benefit.

Planning Balance and Compliance with the Development Plan as a Whole

The Tilted Balance

22.64Paragraph 11 of the Framework is enacted. There is a presumption in favour of sustainable development and the Application should be approved and planning permission granted, without delay. The full weight of the presumption applies.

22.65There are no clear reasons for refusing the Proposed Development. Where adverse impacts have been identified these do not significantly and demonstrably outweigh the benefits.

22.66Overall, the Application is consistent with the Framework.

The Planning Balance

22.67The Framework steers the decision maker into applying the necessary weight to certain planning matters.

22.68Substantial weight is applied to the value of using suitable brownfield land within settlements for homes and economic needs

22.69This substantial weight cascades through all considerations related to using suitable brownfield land within settlements for homes and other identified needs, including employment floorspace, due to the importance that the Government attaches to this principle as set out in the Framework, and very recent ministerial statements.

22.70It is considered that this substantial weight is elevated further because of the Site characteristics, and the contextual challenges that Lewisham faces. Each positive impact therefore benefits from the elevated level of very substantial weight applied to it both individually and cumulatively.

22.71The matters set out above are supported by the development plan and carry the statutory provision of s.38 of the Act, and very substantial weight.

22.72Balancing the very substantial weight which cumulatively attaches to the very many benefits of the Proposed Development in favour of the Proposed Development, against the impacts arising which are moderate negative in respect of archaeology; moderate adverse in respect of built heritage, which equate to undertaking a balanced judgement (Framework 209) in respect to one non-designated heritage asset, nos. 156-60 Lewisham High Street, which is to undergo wholesale demolition during the demolition and construction stage of development; moderate adverse effects in respect of townscape and visual (all at the demolition and construction stage); major negative in respect of daylight, sunlight and overshadowing; and major negative in respect of wind (at the operation stage), there is overwhelming support for the Proposed Development and planning permission should be granted without delay.

22.73The proposals accord with relevant policies within the Lewisham Local Plan when read as a whole which benefits from the same statutory presumption set out in Section 38(6) of the Planning and Compulsory Purchase Act 2004 and Section 70(2) of the Town and Country Planning Act 1990. Planning permission should therefore be granted.

22.74We consider that the compliance with policy that we have demonstrated, along with the public benefits that we set out in this section of the statement, would represent other material considerations demonstrating why planning permission should be granted in any event.

22.75Further, as set out above, we consider that compliance with national planning policies set out in the Framework carry significant weight, and individually and cumulatively are material considerations which would outweigh any conflict, if it existed due to the application of weight that the Framework advises should be awarded.

23Conclusions

23.1 This is a unique Site providing a one-of-a-kind regeneration opportunity. The Proposed Development will see the redevelopment of a highly accessible brownfield site, and the retention and repurposing of many existing buildings within the town centre

23.2 The Proposed Development responds directly to adopted and emerging planning policy aspirations at Government, regional and local level by not only curating a new town centre but also through the proposal to deliver a significant number of new homes for Lewisham and London including affordable homes, as well as modern, flexible non-residential floorspace capable of meeting a local need, new publicly accessible open space and new connections through the Site and to the surrounding area.

23.3 The Applicant and design team have adopted a meticulous design-led approach working closely and collaboratively with the Council, the GLA, and the Council’s DRP as well as other key stakeholders and the local community over the last four years. The Applicant considers the feedback received throughout this process to have been critical to the formation of these proposals.

23.4 When considering the need for phased development, improvements to vitality and viability and the acute need for housing in the Borough and across London which is to be focused on highly accessible brownfield sites along with a policy emphasis on high quality design, the case for planning permission is clear.

23.5 The Application accords with the Development Plan. This Statement confirms that at each layer of planning policy there is a need to deliver high quality growth and regeneration with public benefits for all

23.6 The Proposed Development will result in a suite of substantial benefits that weigh strongly in favour of the proposal when undertaking a balanced planning judgement.

23.7 In consideration of Section 38(6) of the Act, we can conclude that:

▪ The Proposed Development accords with the London Plan and Local Plan when read as a whole.

▪ Taking the Development Plan as a whole, the Proposed Development accords with the Development Plan, and having regard to all material planning considerations, should be approved.

23.8 On the basis of the above, the Application can, and should, be granted planning permission.

Appendix 1 Schedule of Existing Floorspace

Appendix 1 – Schedule of Existing Floorspace within Application Boundary

Lewisham Shopping Centre

Appendix 2 Plan Showing Extent of Demo for Phase 1a

Appendix 3 Co Living Summary and Benefits

Lewisham Shopping Centre

Co-Living: Summary of Need and Benefits

Executive Summary

• Single Households Driving Demand Nationally: c.55% of the UK population are single (ONS). 35% of households in the UK Private Rented Sector (PRS) are one-person households, the most significant proportion of households (English Housing Survey 202122).

• An Inability to Buy in London: People are renting for longer due to the inability to buy. Halifax has reported that the average deposit required to buy a property in London in 2021 was £115,759, more than twice the national average of £53,935. The average age of a firsttime buyer is now 34 in the UK and 60% of renters do not expect to be able to buy within five years (English Housing Survey 2021-22). Mean salaries in London are estimated at £44,370, although some sources estimate it could be higher, at £57,362 (ONS). This represents an average house price/salary ratio of between 9.4 and 12.1, meaning that house purchases remain out of reach for many single people.

• Local Single Person Need: Lewisham has a high proportion (44,036) of single person households, the number of which is projected to increase by 15,309 by 2043.

• Local Supply: There is a low stock / new supply of good quality purpose built rental homes. Over 50% of the current rental stock is 2+ bedrooms. In contrast, studios only make up 13% (Rightmove, May 2024).

• Affordability: Local data shows that anticipated Co-Living rent (all inclusive) will be cheaper than the comparative rental costs (plus all bills) for Lewisham studio and 1-bed units.

• Building Community: Co-Living buildings foster a genuine sense of community owing to the nature of the operation and its residents (i.e. single people who live, work and socialise in one building).

• More Stable Than PRS: Young Londoners cannot afford to buy homes, and so are forced into renting. PRS can be an unstable tenure – the 2021 Census found less than 60% of households in PRS in Lewisham had been in the same address a year ago (reasons: rogue landlords, poor quality, no-fault evictions, and landlords taking properties out of the market to sell or convert). By contrast, professional / purpose-built products (Co-Living) offer a more stable and less transient tenancy, meaning that residents can stay as long as they like.

• Length of Stay: The Gerald Eve 2024 Operator Survey confirmed that the most popular letting period is 12 months, with the second most popular letting period being 12-18 months.

• Moving Into Lewisham and Staying: The proposals will attract people to the Town Centre; Co-Living provides a differentiated offer and a great way of providing a more affordable opportunity for people to be attracted to the town centre. In theory, if the scheme is right, people will then stay locally in the Borough. Lewisham has a history of residents moving

within the borough boundary; the 2021 Census confirmed 78% of movers in 2020 were local, with over a third moving within the borough boundary.

• Serving a Local Need: The Co-Living homes will be affordable to local people including key workers. This will help retain key workers in the Borough.

• Serving a Wider Need: The Co-Living will provide an opportunity for those living in Lewisham and working elsewhere to move to the Town Centre and easily commute. The 2011 Census recorded that a significant proportion of Lewisham residents worked in either the City or Westminster (17%), more than within the Borough itself.

• Significant Socio-Economic Benefits: Attracting and retaining young people; local spending; council tax contributions, employment opportunities (construction and operation); speed of delivery.

1 Purpose of Note

1.1 This Note is prepared by Quod on behalf of Landsec in connection with the hybrid planning application (the Application) to comprehensively redevelop Lewisham Shopping Centre and surrounding land (the Site)

1.2 The Application is part detail, part outline and seeks permission for a multi-phased mixed-use development. The first phase (Phase 1a) seeks detailed planning permission for a series of works to include a standalone Co-Living building (Building N1). The Application proposes 445 Co-Living rooms within Building N1.

1.3 This Note seeks to provide a summary of Co-Living in terms of the nature of the operation and the significant benefits it can bring to a community. The Note draws on up-to-date data to explain the national position and the London-wide position, before setting out how Co-Living can have a positive impact on Lewisham.

1.4 Landsec has appointed an experienced technical team to assist in the design and delivery of Building N1. The architectural team comprises Mae (2023 Stirling Prize Winners) and Studio MULTI (experienced Co-Living designers working across London for Co-Living developers). In terms of management and operation, Urban Bubble, one of the leading Co-Living operators in the UK today, are bringing know-how and intelligence from their three operational sites at Sunday Mills, Earlsfield; Florence Dock, Wandsworth; and The Palm House, Harrow (all under the Folk Living brand).

2 Background to Co-Living

What is Co-Living

2.1 The UK housing market is challenged with a lack of homes for the growing population, with the public and private sector looking for ways to ease the supply versus demand pressure

2.2 Co-Living is a product that has emerged in recent years, particularly in London, to help tackle the housing crisis by offering a new rental product to sit alongside existing products, in turn increasing the housing offer to existing and prospective residents.

2.3 Co-Living represents an expanding trend in modern managed rental housing, particularly for single renters. This segment, historically poorly served by traditional rental markets, now finds a viable and attractive option though Co-Living.

2.4 The principal appeal of Co-Living for residents lies in its all-inclusive price, professional management and opportunities to make social connections. It is emerging as an ideal solution for those who do not want to live alone but require greater privacy and an upgrade from Houses in Multiple Occupation (HMOs).

2.5 Co-Living buildings are thoughtfully designed to balance private and communal spaces. This creates an ethos of sleeping in your bedroom, but living in the building.

2.6 Residents have access to their own private studios, which are then complemented by a variety of shared amenities. These often encompass co-working spaces, fitness centres, screening rooms, expansive cooking and dining facilities, along with lounge areas for relaxation and social interaction. Many Co-Living operators curate events and activities fostering a sense of community within the building

2.7 The shared access to significant internal and external amenity means that Co-Living is a completely different model for residential living (i.e. the entire building is designed to be the living environment of the residents).

2.8 Co-Living schemes are typically professionally managed to ensure that resident experience is high as possible. On-site maintenance teams are able to respond to problems quickly and concierge staff are on hand to help with move-in/move-out, parcel deliveries, security and assistance with local services.

Who Lives in Co-Living

2.9 The British Property Federation (BPF) notes that a Co-Living resident is typically someone who is:

▪ A non-home owner;

▪ Typically single occupants;

▪ From all walks of life i.e. mature students, key workers, professionals;

▪ Someone where affordability is a key consideration;

▪ A user of public transport or walks to get around;

▪ An active rental chooser because of the convenience of doing so.

2.10 Recent GLA guidance notes that Co-Living generally provides accommodation for singleperson households who cannot, or choose not to, live in self-contained homes or HMOs.

2.11 For those transitioning out of education into their careers, Co-Living presents an affordable, flexible and alternative to more traditional rental options, coupled with attractive amenities and community activities. With rents and bills steadily rising in the years since the Covid-19 pandemic, there is increasing demand from this age-group for independent living, within a supportive community environment. In addition, Co-Living schemes do not require a deposit, which is appealing to those who have been unable to save for a deposit.

2.12 However, Co-Living is not just for people transitioning out of education. Importantly, it provides an additional alternative to existing rental products for those in all stages of life who require a change to their current housing scenario.

Planning Policy Support

London Policy and Guidance

3.1 The Mayor’s London Plan (2021) specifically recognises the important role that Co-Living (referred to as Shared Living in policy) should play in meeting housing targets and that ‘nontraditional’ housing models make a positive contribution to both the range and supply of accommodation available in the capital.

3.2 In terms of addressing housing need, the London Plan recognises that Co-Living schemes count towards meeting housing targets on the basis of a 1.8:1 ratio.

3.3 The Mayor explains that Co-Living is not restricted to particular groups by occupation or specific need.

3.4 Policy H16 of the London Plan sets out a series of requirements for planning applications to consider when promoting Co-Living, including requirements relating to design quality, tenancy, and management.

3.5 The London Plan builds upon the GLA’s Strategic Housing Market Assessment (2017) which noted that the strongest growth in households is by far expected to be amongst oneperson households, couples, and other childless household types. The SHMA also recognised the need for smaller private unit types (1 and 2 bedrooms) across London for both newly forming and existing overcrowded concealed/shared households (e.g., those living in lower quality buy to let housing).

3.6 Since the adoption of the London Plan, the GLA published the London Plan Guidance on Large-Scale Purpose-Built Shared Living (February 2024). The LPG sets out further detail on siting and developing Co-Living alongside other housing types, and provides space and facilities benchmarks and good practice advice. The LPG was prepared alongside the CoLiving community and reflects the design approach adopted in successful operational schemes (including those managed by Urban Bubble).

Lewisham Policy

3.7 The Draft Lewisham Local Plan (Regulation 19version) follows the approach in the adopted London Plan and is supportive of Co-Living as a residential type.

3.8 Draft Policy H08, Part D sets out a series of requirements for planning applications to consider and suitably demonstrate compliance with. These requirements largely follow those set out in London Plan Policy H16.

4 The Application Proposals

4.1 Landsec is submitting a hybrid planning application to comprehensively redevelop Lewisham Shopping Centre.

4.2 Building N1 is part of Phase 1a which is being applied for in detail within the Application.

4.3 The Application proposes 445 Co-Living rooms (sui generis) within Building N1.

4.4 The Building N1 design has been prepared with all relevant policy and guidance in mind, most notably the recently adopted GLA LPG with respect to provision of communal facilities and recommended benchmarks for amenity and parking provision.

4.5 The Landsec proposals include the following amenities within Building N1:

▪ Concierge with parcel management;

▪ A community management team;

▪ A self-service provisions store (and bar);

▪ Co-working space;

▪ Lounges catering for both large and small groups;

▪ Quiet space for contemplation, reading and study;

▪ Communal cooking and dining space;

▪ Private dining suite for dinner parties;

▪ Gym and wellness suite;

▪ Games rooms for both physical and virtual games;

▪ Laundry;

▪ Household appliance rental;

▪ Storage for suitcases and large items; and

▪ Roof terrace connected to shared amenity space.

5 Market Data

5.1 This section of the Note draws upon recent data to summarise the national and London-wide position on Co-Living.

The National Position

5.2 Bridges Fund Management released a paper entitled ‘The Value of Co-Living: A New Generation of Shared Living’ in February 2024.

5.3 A number of the headline points are set out below.

▪ The rise in single-person households:

▪ Around 8.3m people now live alone – a 25% increase over the last 25 years.

▪ This can also be a driver of social isolation and loneliness - Co-Living can help to combat the scourge of social isolation and loneliness – which has a well-attested link to poor health outcomes

▪ The supply of new homes is failing to keep pace:

▪ Annual house completions are ~50% lower than in the 1960s

▪ On average, ~180k new homes have been built in the UK p/a since 2011, well below the estimated need of 340k

▪ In recent years, higher construction costs and material supply chain issues have also constrained house-building across Europe

▪ Buying a house has become increasingly unaffordable:

▪ In England, the average house now costs nearly 9x the average salary.

▪ There is not enough capacity in the rental market: Last September in London, there were 22,549 individuals seeking a room, and only 10,833 rooms available to rent – a shortfall of 11,7168

▪ Inevitably, this is making rental properties less affordable:

▪ Average private rents in Great Britain have soared by 26% since the start of the Covid pandemic

▪ Co-Living helps to reinvigorate city-centre areas where there are high vacancy rates.

▪ Critically, Co-Living helps to tackle the housing shortage, particularly in major cities

▪ It allows for greater housing density in urban areas.

▪ Since the individual units are smaller, they cost less, making them accessible to a broader range of tenants.

▪ Co-Living can reduce emissions:

▪ Shared communal areas can reduce energy consumption, water usage and waste generation, all reducing the per capita carbon footprint of the building. One research study suggested the relative carbon footprint of a Co-Living community was up to 68% lower than the average UK household (Dr Penny Clark, 2021)

▪ Co-Living combats social isolation and boosts inclusion:

▪ The communal amenity spaces encourage social interaction and the curated events encourage the residents to socialise with one another. This is shown to reduce social isolation and loneliness.

▪ This has clearly become more important in the wake of the pandemic, with more people working from home rather than in offices; but it’s also valuable for older residents and other single-person households;

▪ One study of a Co-Living scheme confirmed that 82% of residents confirmed that this sense of shared community had improved their quality of life (Savills, May 2023)

▪ Shared living spaces often attract individuals from different backgrounds, fostering cultural exchange and understanding

The London Position

5.4 Gerald Eve undertook a Co-Living Operator Survey leading to publication of their paper

‘Emerging Trends in Co-Living; Insights from our Co-Living Operators Survey, 2024’.

5.5 A number of the headline points are set out below.

▪ The Co-Living sector is experiencing dynamic growth and innovation, offering new living solutions catering to a diverse urban population.

▪ The Co-Living sector attracts a diverse range of tenants, both in terms of age and income levels. This highlights its widespread appeal across various demographics and economic backgrounds.

▪ A significant undersupply in London:

▪ Currently 5,000 Co-Living beds;

▪ Potential for an additional 11,500 beds;

▪ Potential Co-Living Demand Pool in London of 600,000

▪ Co-Living operators surveyed said that the average age in their portfolios is around 28, but ages range between 17 and 67.

▪ Length of Stay: most popular letting is 12 months; second most popular letting is 12-18 months.

▪ Average salary: in London was £37,375 (range £0 to £100,000 - lower end of this range being students). This shows that Co-Living appeals to a wide range of people and budgets.

▪ 55% of the UK population are single (ONS). It is therefore not surprising that 35% of households in the UK Private Rented Sector are one-person households (English Housing Survey 2021-22).

▪ People are renting for longer due to the inability to buy. According to Halifax, the average deposit required to buy a property in London in 2021 was £115,759, more than twice the national average of £53,935. The average age of a first-time buyer is now 34 in the UK and 60% of renters do not expect to be able to buy within five years (English Housing Survey 2021-22).

▪ London’s average house price as of August 2023 was £539,074 (all property types).

▪ Mean salaries in London are estimated at £44,370, although some sources estimate it could be higher, at £57,362 (ONS)

▪ This represents an average house price/salary ratio of between 9.4 and 12.1, meaning that house purchases remain out of reach for many single people.

6 Lewisham: Affordability and Availability

6.1 Co-Living successfully provides an alternative to the existing rental products in any location. This is because it typically addresses issues of affordability and availability in terms of residents’ access to good quality rental stock.

6.2 Further detail regarding how Co-Living can address issues of local affordability and availability is set out within the Housing Statement which supports the planning application.

7 Lewisham: Delivering Benefits

7.1 The introduction of Co-Living to Lewisham will also result in a number of additional social and economic benefits.

7.2 A number of these are summarised below.

Contribution to Affordable Housing

7.3 Smaller residential units create more value relative to their floorspace. Conversely, the introduction of larger units results in a less efficient scheme constraining viability and the quantum of affordable housing that can be provided. Therefore, Co-Living contributes towards affordable housing delivery, and in the case of Lewisham helps to increase the number of affordable homes on site. This will allow Landsec to provide social rent housing in the later phases of the Application, benefitting the borough.

Economic and Social Benefits (Contributing to The Borough)

7.4 Co-Living developments deliver a number of socio-economic benefits, which will be the case in Lewisham:

▪ Attracting and retaining single person households: The Co-Living development will broaden the variety of housing types available locally, filling an important gap in provision and helping to retain a mixed and balanced community.

▪ Local Spending: Associated with the above, the new Co-Living homes will bring additional local spending to Lewisham – that is spending that will benefit local shops, leisure and service providers.

▪ Council Tax: Co-Living also generates a substantial contribution to local council tax, benefitting the Borough.

▪ Employment (Construction): The proposed scheme as a whole will employ c. 770 FTE people in any given month over the 10-year duration of the construction period, employing a variety of trades, with good opportunities for local employment. In the case of Building N1 (part of the first phase of development), this benefit will be felt early in the process.

▪ Employment (Operation): Once completed, the Co-Living element of Building N1 will employ 30-45 FTE people, providing new opportunities for local people. These roles offer a huge variety, including on-site management, back-of-house, room cleaning and other services. The high service-level experience which will be offered is different to a usual residential environment

▪ Speed of Delivery: Co-Living can be delivered and occupied quickly meaning homes can quickly contribute to meeting un-met housing need.

▪ Connectivity: Lewisham Shopping Centre is well connected by road and rail, with direct transport links to Canary Wharf and Central London. The affordable rent levels in Lewisham are appealing to commuters working in the City and West End. The 2011 Census recorded that a significant proportion of Lewisham residents worked in either the City or Westminster (17%), more than within the Borough itself.

Local Voters

7.5 Each resident of a Co-Living self-contained home has the ability to join the electoral roll.

Remaining in the Borough

7.6 Co-Living is able to attract new people to an area as a result of its differentiated offer

7.7 Co-Living buildings foster a genuine sense of community, owing to the nature of the operation and its residents (i.e. single people who live, work and socialise in one building). This community fosters friendships amongst residents, helped by the many social, health and wellbeing events hosted by their operators. In this context, the aim for all Co-Living schemes is to allow residents to become settled in a location, particularly where people are new to the area. This sense of community will provide a stronger platform for those leaving Co-Living to remain in the borough.

7.8 This transition from Co-Living onwards within the same borough is clearly beneficial to the wider community.

7.9 Lewisham has a history of retaining its residents. The 2021 Census confirmed that 35% of all people who moved into a home in Lewisham in 2020 moved from elsewhere within the borough. A further 43% moved from elsewhere in London. Therefore, people moving into Lewisham are mostly Londoners, many of them local. The Lewisham pattern is higher than the average for inner London (31%).

7.10 The Lewisham context is important for predicting that a significant number of those leaving the Co-Living building in Lewisham will do so within the borough, potentially within the redeveloped Lewisham Shopping Centre site itself.

Conclusion

7.11 Co-Living meets the demands of a growing single household population and provides an alternative tenure type for people who would otherwise be living in shared housing such as HMOs.

7.12 People choose Co-Living for the high quality accommodation, convenience of on-site management, affordability, social interaction and security that it offers.

7.13 It’s beneficial to the Borough as it provides high density housing, introduces a new demographic and contributes to a higher level of affordable housing across the wider masterplan.

7.14 Overall, it is considered to positively contribute to the Lewisham Shopping Centre masterplan and Lewisham Town Centre as a whole.

Appendix 4 Pre-Application Planning and Policy Meetings with the Council

Appendix 4 (Pre-Application Planning and Policy Meetings with the Council)

Date

2020

July 2020

July 2020

September 2020

Planning Authority / Organisation Meeting

The Council

The Council

The Council

October 2020 The Council

2021

January 2021

July 2021

September 2021

September 2021

November 2021

November 2021

November 2021

The GLA

The Council

The Council

The Council

Pre-application meetingIntroductions

Pre-application meeting –Overview of process

Pre-application meeting –Design

Pre-application meeting –Consultation

Pre-application meeting –Scheme Overview

Pre-application meeting –Update

Planning Policy Meeting –

Local Plan Process and Draft Site Allocation

Pre-application meeting –Vision, Engagement and Site Visit

The Council Lewisham Market Meeting

The Council

The Council

December 2021 The Council

2022

January 2022

January 2022

January 2022

January 2022

The Council

The Council

Pre-application meeting –Design

Pre-application meetingEnergy

Pre-application meeting –Design

Pre-application meeting –Design

Pre-application meeting –Commercial Floorspace

The Council Lewisham Market Meeting

The Council

Pre-application meeting –Transport

Date

January 2022

January 2022

February 2022

March 2022

March 2022

March 2022

April 2022

April 2022

April 2022

May 2022

July 2022

August 2022

September 2022

September 2022

October 2022

October 2022

October 2022

December 2022

2023

February 2023

March 2023

April 2023

May 2023

Planning Authority / Organisation

The Council

The GLA

The GLA

The Council

The Council

The GLA

The Council

TfL

The GLA

The GLA

The Council

The Council

The Council

Meeting

Pre-application meeting –Townscape

Pre-application meeting –Energy and Sustainability

Pre-application meeting –EQIA

Pre-application meeting –Townscape

Pre-application meeting –Public Realm

Pre-application meeting –Design

Pre-application meeting –High Street Heritage

Pre-application meeting –Transport

Pre-application meeting –Circular Economy and Air Quality

Pre-application meeting –Whole Life Carbon

Pre-application meeting –Masterplan

Pre-application meeting –Masterplan

Pre-application meeting –Engagement Update and Design

The Council Planning Policy Meeting

The Council EIA Scoping Meeting

Design Review Panel Design Review 1

The GLA

The Council

The Council

The Council

The Council

The Council

Pre-application meeting –Design

Pre-application meeting –Flood Risk and Drainage

Site Tour

Pre-application meeting –Masterplan

Pre-application meeting –Masterplan

Design Workshop

Date

May 2023

July 2023

July 2023

August 2023

September 2023

November 2023

December 2023

December 2023

December 2023

2024

January 2024

January 2024

February 2024

February 2024

February 2024

March 2024

March 2024

March 2024

March 2024

April 2024

April 2024

April 2024

April 2024

April 2024

Planning Authority / Organisation Meeting

The Council

Pre-application meeting –Transport

The Council Masterplan Workshop

The Council Masterplan Workshop

The Council Masterplan Workshop

The Council Masterplan Workshop

The Council

Pre-application meeting –Masterplan

Design Review Panel Design Review 2

The Council Design Code/Parameter Plans Workshop

The GLA

The Council

The Council

The Council

The Council

The Council

The Council

The Council

The GLA

The GLA

The Council

The Council

The Council

The Council

Pre-application meeting –Design

Pre-application meeting –Lead Local Flood Authority

Pre-application meeting –Southern Masterplan

Pre-application meeting –Highways

Pre-application meeting –Energy/Sustainability

Pre-application meeting –Uses and Construction Sequence

Pre-application meeting –Masterplan, Plots N1 and N2

Pre-application meeting –Masterplan – Residential Quality

Pre-application meeting –Sustainability and Energy

Pre-application meeting –EQIA

Pre-application meeting –Landscape and Townscape

Pre-application meeting –Consultation Findings

Pre-application meeting –Townscape/Heritage

Pre-application meeting –Masterplan, Plots N1 and N2

Design Review Panel Design Review 3

Date

May 2024

May 2024

May 2024

May 2024

June 2024

June 2024

June 2024

June 2024

July 2024

July 2024

July 2024

July 2024

July 2024

July 2024

July 2024

August 2024

August 2024

August 2024

August 2024

August 2024

September 2024

Planning Authority / Organisation Meeting

The Council

The Council

The Council

The GLA

The Council

The Council

The Council

The Council

The Council

The Council

The Council

The Council

Pre-application meeting – Plot N1 and Landscaping

Pre-application meeting –Design Codes

Pre-application meeting –Lead Local Flood Authority and Environment Agency

Pre-application meeting –Design

Pre-application meeting –Phasing

Pre-application meeting –Transport

Pre-application meeting –Parameter Plans and Development Specification

Pre-application meeting –Landscaping, Molesworth Street and Northern Square

Pre-application meeting –Plots N1 and N2

Pre-application meeting –Energy/Sustainability

Pre-application meeting –Design Code

Pre-application meeting –Secure by Design

The Council/TfL Servicing Workshop

The Council

Pre-application meeting –Design Code and UGF

Design Review Panel Design Review 4

The Council

The Council

The Council/TfL

The Council

Design Review Panel

The Council

Pre-application meeting –Consultation Findings

Pre-application meeting –Masterplan, Plots N1 and N2

Pre-application meeting –Transport

Pre-application meeting –Design Code

Design Review 5

Pre-application meeting –Viability

September

Appendix 5 Draft HoTs

1.1 This Appendix sets out the proposed Developer Contributions for the Proposed Development at Lewisham Shopping Centre and adjacent land and comprises a Draft Heads of Terms. Table A-6 below describes the Applicant’s proposed position on financial and other obligations having regard to relevant policy, LBL’s Planning Obligations SPD and pre-application discussions.

1.2 Details of the Applicant’s Solicitors are as follows:

 Eversheds Sutherland (International) LLP

 One Wood Street, London, EC2V 7WS

 + 44 (0)20 7 919 4500

 https://www.eversheds-sutherland.com/en/united-kingdom

1.3 Direct contact details will be provided under separate cover.

Table A-1 – Proposed Heads of Terms (“HoT”)

See Section 7 of the Planning Statement - triggers relating to occupation of buildings in Phase 1a, Phase 1b and Phase 3b.

Plots N1 and N2 calculation at planning application stage - £323,386

Outline Component calculation at planning application – £2,579,539

Updated Energy Strategies will be submitted as the development proceeds through Reserved Matters Applications

Provision of connection points to potential future District Heating Network