1.0 Introduction 1.1
Introduction
1.1.1 This Environmental Statement (ES) has been prepared by Plowman Craven, on behalf of Landsec Lewisham Limited (the ‘Applicant’). 1.1.2 Environmental Impact Assessment (EIA) is a process which provides an assessment of the likely significant effects on the environment of certain types of developments. The EIA assesses these effects, reports and if necessary, provides for mitigation. This ES presents the findings of the EIA that has been undertaken in accordance with the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (as amended) (the ‘EIA Regulations’) (Ref. 1.1). In accordance with the EIA Regulations, the ES reports on the likely significant environmental effects of the Proposed Development during the demolition and construction stage, as well as during the subsequent operational stage. 1.1.3 The EIA has taken into account the mitigation measures that are being proposed by the Applicant, including those measures that have been integrated into the planning and design of the Proposed Development to prevent and, where prevention is not possible, to reduce and/or mitigate likely significant negative effects. It then evaluates the significance of the residual effects. 1.1.4 Further information on how the scope of the EIA was defined and the structure of this ES, is provided in Chapter 2: Approach to the Assessment. 1.1.5 The Applicant intends to submit an application made part in detail and part in outline (the ‘Application’) for the demolition and comprehensive phased redevelopment of land at Lewisham Shopping Centre and adjacent land (the ‘Site’) within the London Borough of Lewisham (‘LBL’) (Figure 1.1). 1.1.6 The Application is submitted as what is sometimes called a ‘hybrid’ application with Plots N1 and N2, associated access roads and infrastructure as well as other highways works submitted in detail (the ‘Detailed Proposals’) and the remaining plots (N3, C1, C2.1, C2.2, C3, C4, C5, S1, S2, S3, S4, MV and M1) and areas of the Site submitted in outline (‘Outline Proposals’). 1.1.7 A description of the development for which planning permission is sought is set out below: ‘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. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 1: Introduction
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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: o
Living Uses, comprising residential (Class C3) and student accommodation (Sui Generis);
o
Town Centre Uses (Class E (a, b, c, d, e, f, g (i, ii) and Sui Generis);
o
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’.
1.1.8 The Detailed and Outline Proposals comprise one comprehensive redevelopment proposal and together form the ‘Proposed Development’. 1.1.9 Full details and the scope of the Application is described in the submitted Planning Statement, prepared by Quod. 1.1.10 As the local planning authority and competent authority, LBL will determine the Application taking into account the likely significant environmental effects of the Proposed Development as determined through the EIA process. 1.1.11 This Chapter provides a general description of the Site, the relevant planning context, planning application details, as well as the content and structure of the ES. More detailed information on the Site is provided in the technical assessments of ES Volume 1, 2 and 3.
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1.2
Development Context Site Location
1.2.1 The Site is bound to the west and south by Molesworth St (A21), the east by Lewisham High Street and the north by Rennell Street (A20). West of Molesworth St is the railway line and Ravensbourne River as well as a mix of green space, residential and commercial buildings. The London Underground DLR and Lewisham railway line are located, respectively, approximately 170m and 240m north of the Site. North east of the Site is a Police Station, east of Lewisham High Street which is then followed by shops and commercial premises running south beyond the southern tip of the Site, as shown in (Figure 1.1 & Figure 1.2).
Figure 1.1: Site Location Plan
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Figure 1.2: Site Boundary Plan
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Immediate Context 1.2.2 The Site’s immediate context is a rich mix of Town Centre functions, see Figures 1.3 and 1.4. 1.2.3 To the north, the Site is neighboured by Lewisham Station and multiple emerging residentialled developments. 1.2.4 Rennell Street currently provides a singular crossing which aligns with the emerging NorthSouth route through Lewisham Gateway. 1.2.5 To the east, the historic High Street and Market form a popular destination for visitors throughout the week. This is partially pedestrianised and includes historically significant structures including the Clock Tower. 1.2.6 To the west, the Site is bound by Molesworth Street that acts as a vehicular thoroughfare. The Site is further split from its western context by the railway line and River Ravensbourne. Molesworth Street functions primarily as a transport link for cars, buses and HGVs, with occasional crossing points and a planted central reservation to serve pedestrians. 1.2.7 The site’s Eastern Elevation is made up of a large area of Lewisham’s High Street frontage. This extends from Rennell Street in the north, along the primary frontage to Lewisham Market and down to the entrance to Molesworth Street.
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Figure 1.3: Immediate Context
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Figure 1.4: Lewisham High Street
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Site Description 1.2.8 The Site is approximately 6.93 ha in size and currently comprises the Shopping Centre, including a Sainsbury’s, multi-storey car-park, a number of retail units and the vacant 18storey office building: Lewisham House, and properties on the High Street. Existing town centre floorspace within the application boundary is measured as 72,970 sqm. 1.2.9 The Shopping Centre was built in 1977. In 1994 the adjacent High Street was pedestrianised, becoming a traffic-free street market and an open space. 1.2.10 The Site benefits from the highest Public Transport Accessibility Level (PTAL) rating, i.e. 6b (excellent). The closest London DLR station is Lewisham, approximately 170m north of the Site, and the nearest National Rail station is Lewisham, located approximately 240m north of the Site. 1.2.11 A review of the Environment Agency’s Flood Map shows the Site lies within flood zone 2 & 3, meaning the risk of flooding is medium-high. 1.2.12 The Site does not lie within a conservation area, but there are a number of statutorily listed buildings within 500m of the Site, the closest of which, the Grade II Listed Clock Tower is located at the northern end of Lewisham High Street. There are a number of non-designated heritage receptors located within the Site boundary, including the locally designated 65-85 Lewisham High Street, 90-100 Lewisham High Street and 180-190 Lewisham High Street, as well as part of an area of local special character. 1.2.13 The Site is located within the Lewisham and Catford/Rushey Green Archaeological Priority Area (APA) designated by LBL for potential to contain remains of medieval settlement that grew up beside the Ravensbourne River, often used for powering mills. 1.2.14 The Site is comprised entirely of buildings and hardstanding, with no other habitats on site. Mature and semi-matured scattered trees are located adjacent to the western boundary of the site. 1.2.15 Noise sources affecting the Site are characterised by road traffic and train movements. 1.2.16 The Site is located within the Lewisham Air Quality Management Area (AQMA), which means that the area exceeds acceptable levels of air pollution for pollutants deemed detrimental for human health. The Proposed Development also lies within an Air Quality Focus Area (AQFA).
The Existing Shopping Centre 1.2.17 The existing 1970s Lewisham Shopping Centre is home to a mix of businesses at ground level; complemented to the east by Lewisham Market and high street shops and businesses. Molesworth Street to the west of the site, acts as a severance to existing green space and is a significant contributor to poor air quality. There are a number of existing structures on the site of varying importance. Lewisham House, the Leisure Box and the multi-storey car park are particularly dominant due to their scale and architecture (see Figure 1.5). 1.2.18 The site’s prominent features include: Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 1: Introduction
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Lewisham House - an existing high-rise office building previously occupied by Citi Bank and now vacant.
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The Leisure Box - a derelict structure that sits above the service deck to the north of the site. The building was previously used as a leisure centre and indoor bowling alley, and has been vacant for over 20 years, resulting in its poor current condition.
•
Access Ramps and Service Deck - two ramps along Molesworth Street provide vehicle access to a level 01 Service Deck, allowing servicing of the retail units within the Shopping Centre below.
1.2.19 The Service Deck forms a complex first floor structure spanning the majority of the site that services the retail and shopping centre below. The existing deck sits at circa 5.8 metres above ground level. This frees the ground floor of servicing movement and vehicles, enhancing the pedestrian experience across the site at ground level, see Figure 1.6.
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Figure 1.5: The Existing Shopping Centre Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 1: Introduction
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Figure 1.6: The Service Deck
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Lewisham Market 1.2.20 Lewisham Market has been established within the centre of Lewisham for at least 120 years, and is now one of London’s last remaining six-day markets. 1.2.21 It was first opened in 1906, surrounding the recently completed Lewisham Clock Tower (built in 1900 to mark Queen Victoria’s Diamond Jubilee). Prior to this, unlicensed market trading was known to take place in the area, suggesting the history of Lewisham market is earlier than its official opening. 1.2.22 For the last century the market has been a constant and unique feature to Lewisham’s centre. Other than a brief halt from 1944-1950 following it being hit by a bomb, the market has remained open. In the 1990s the site was further pedestrianised to provide additional space to market sellers. 1.2.23 In more recent years, Lewisham Council have begun consulting with market traders to develop a future vision for the Market. The process has brought about a series of High Street improvements including artwork, refurbishment of market stalls and improvements to public realm. In July 2024, Lewisham Council approved a planning application (LPA ref. DC/24/136236) for: “Development comprising a market house and canopy structure to cover Lewisham Open Market and provide additional civic function together with associated public realm at Lewisham Open Market.”
Environmental Considerations 1.2.24 A review of the Environment Agency’s Flood Map shows the site lies within flood zone 2 & 3, meaning the risk of flooding is medium-high. 1.2.25 The Site is surrounded by railways and primary roads to the west, north and south (i.e. Molesworth Street (A21), Lewisham Road (A2211), Loampit Hill (A20), Thurston Road (A2210) and Lee High Road (A20)). 1.2.26 The Site is not within a conservation area, but the closest to the Site are St Stephen’s and Belmont, located adjacent to the north-east boundary of the Site. 1.2.27 Whilst the Site does not include any statutorily listed buildings, several listed buildings are located within proximity to the Site. 1.2.28 Listed buildings within a 500m radius of the Site include: • Church of Stephen (Grade II Listed) and St Stephen’s Church War Memorial, Lewisham
(Grade II Listed) to the north; • Belmont Hill No. 10-18 (Grade II Listed, Belmont Hill 91 & 91a (Grade II Listed), Clock
Tower (Grade II Listed), The Priori (Grade II Listed) to the north-east; • Lewisham Bridge Primary School (Grade II Listed) to the north-west;
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• Rileys (Former Temperance Billiard Hall) (Grade II Listed) and United Reformed Church
Sunday School (Grade II Listed) to the south; • Church of St Saviour and St John Baptist and Evangelist (Roman Catholic) (Grade II
Listed), Former Prudential Building (Grade II Listed) and Presbytery Adjoining Church of St Saviour and St John Baptist and Evangelists (Grade II Listed) to the south-east; • Coroner’s Court (Grade II Listed), Garden Walls to South and West of St Mary’s Vicarage
(Grade II Listed), Lewisham High Street No. 40 (Grade II Listed), Old Swimming Baths (Grade II Listed), Police Station (Grade II Listed) and St Mary’s Vicarage (Grade II Listed). 1.2.29 The Site does not form part of any statutory or non-statutory designated nature conservation site. Blackheath, part of the Blackheath and Greenwich Park Site of Metropolitan Importance for Nature Conservation (SMINC), is located approximately 640m north-east of the site. The Lewisham Railway Triangles Site of Borough Importance for Nature Conservation (SBINC) is located approximately 40m west of the Site, on the opposite side of Molesworth Street, and Lewisham to Blackheath Railsides SBINC is located approximately 250m north-east of the Site. The Ravensbourne River is located approximately 70m west of the Site and Cornmill Gardens, a small park is located approximately 100m west of the Site. The site has limited connectivity to these and other areas of open greenspace within the wider area, due to its location surrounded by busy roads. 1.2.30 A number of receptors have been identified that would potentially be sensitive to effects resulting from the Proposed Development, as set out in Table 1.3. Table 1.3: Sensitive Receptors Receptors
Description
Visitors and on-site users
Existing and future users of the Site and surrounding area.
Residential
Existing and future residential properties in the surrounding area.
Commercial and Industrial
Office, retail and industrial buildings within the local area.
Social Infrastructure
Effects of the changes to the demography and socio-economics in the area on education and school facilities, churches and places of worship; health and community facilities such as GP surgeries, child care facilities and local community facilities.
Transport Network
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Existing sensitive receptors comprise: •
Local highway network;
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Users of the surrounding streets;
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Users of the public transport network;
•
Network of footway and pedestrian connections that serve the Site; Plowman Craven 46730 October 2024
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On-street cycle routes in the vicinity of the Site; and
•
Car clubs located in the vicinity of the Site.
Townscape and Views
Surrounding townscape and character.
Ecological Receptors such as fauna and flora
Effect of demolition and construction works on existing habitats within and surrounding the Site.
Air Quality
Potential impacts on air quality during construction and long-term impacts upon the AQMA.
Heritage assets, including archaeological, heritage and landscape features
Surrounding heritage assets, including listed building and buried archaeology.
Hydrological Receptors
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Existing and future users of the Site and surrounding area.
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1.3
Planning Context EIA Guidance and Planning Policy
1.3.1 It is necessary to consider the Proposed Development against relevant policies and guidance at national, regional and local levels. At the national level, planning policy is contained within the National Planning Policy Framework (NPPF). 1.3.2 The updated NPPF was published and became immediately effective in 2023 (Ref. 1.2). It sets out the Government's planning policies for England. It provides within a single document the greater part of national planning policy advice and articulates the Government's vision for delivering sustainable development. The NPPF is a material planning consideration. 1.3.3 The relevant statutory development plan for the Site comprises the: •
London Plan 2021 (Ref. 1.3);
•
Lewisham Core Strategy (2011) (Ref. 1.4);
•
Lewisham Town Centre Local Plan (2014) (Ref. 1.5); and
•
Lewisham Local Plan: Submission Version (January 2023) (Ref. 1.6).
1.3.4 A range of regional supplementary guidance documents are also relevant to the determination of the Applications:
1.4
•
Housing Supplementary Planning Guidance (SPG) (2016) (Ref. 1.7);
•
Affordable Housing and Viability SPG (2017) (Ref. 1.8);
•
Shaping Neighbourhoods: Play and Informal Recreation SPG (2012) (Ref. 1.9);
•
Accessible London: Achieving an Inclusive Environment SPG (2014) (Ref. 1.10);
•
London’s Foundations SPG (2012) (Ref. 1.11);
•
London View Management Framework SPG (2012) (Ref. 1.12);
•
Character and Context SPG (2014) (Ref. 1.13);
•
Sustainable Design and Construction SPG (2014) (Ref. 1.14);
•
Mayor’s Air Quality Strategy SPG (2010) (Ref. 1.15).
Application Details
1.4.1 The description of the Proposed Development as stated on the Application form is: Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 1: Introduction
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‘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:
1.5
o
Living Uses, comprising residential (Class C3) and student accommodation (Sui Generis);
o
Town Centre Uses (Class E (a, b, c, d, e, f, g (i, ii) and Sui Generis);
o
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’.
Project Team & Appropriately Qualified Experts
1.5.1 The Applicant has appointed a design team to assist in the development of the Application and has concurrently appointed an EIA team to undertake the EIA and prepare the ES. 1.5.2
The team members and their respective roles are presented in Table 1.4.
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Table 1.4: Project Team Company
Role
Studio Egret West (SEW)
Masterplan Architect
Mae & Studio Multi
N1 Architect
Archio
N2 Architect
SLR
Transport Consultant EIA: Transport
Bioregional
Sustainability
Miller Hare
Accurate Visual Representations
Quod
Planning Consultant EIA: Socio-Economics Health Impact Assessment Report
WSP
Structural Engineer Energy, MEP EIA: Air Quality EIA: Ground Conditions and Contamination EIA: Wind EIA: Climate Change
Hoare Lea
EIA: Noise and Vibration
MOLA
EIA: Archaeology
Expedition
Flood Risk and Drainage Consultant EIA: Flood Risk and Drainage
Temple
EIA: Ecology
Point 2
EIA: Daylight, Sunlight and Overshadowing
Montagu Evans
EIA: Townscape, Visual and Built Heritage Assessment
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1.6
Plowman Craven
EIA Project Manager and Coordinator
RWDI
Wind Tunnel
Environmental Statement Structure
1.6.1 The structure proposed of the ES is in line with Schedule 4 of the EIA Regulations and other relevant good practice guidance. 1.6.2 The ES will comprise three volumes and a Non-Technical Summary (NTS): Volume 1: Main Text and Figures: Table of Contents Glossary of Terms and Abbreviations 1.0
Introduction
2.0
Approach to the Assessment
3.0
Alternatives
4.0
The Proposed Development
5.0
Demolition and Construction
Technical Chapters 1.6.3 Each technical Chapter will be structured as follows: •
Introduction
•
Legislation, Policy and Guidance
•
Assessment Methodology and Significance Criteria
•
Baseline Conditions
•
Assessment of Effects, Mitigation and Residual Effects
•
Summary and Summary Tables
•
References
6.0
Noise and Vibration
7.0
Air Quality
8.0
Transport
9.0
Flood Risk and Drainage
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10.0
Ground Conditions and Contamination
11.0
Archaeology
12.0
Daylight, Sunlight, Overshadowing, Light Pollution and Solar Glare
13.0
Wind Microclimate
14.0
Ecology
15.0
Socio-Economics
16.0
Climate Change
Concluding Chapters 17.0
Effect Interactions
18.0
Summary of Effects, Mitigation and Monitoring
19.0
Summary of Residual Effects
Volume 2: Built Heritage, Townscape and Visual Impact Assessment (BHTVIA); Volume 3A: Technical Appendices: Volume 3B: Transport Assessment. Non-Technical Summary.
1.7
Environmental Statement Content
1.7.1 The required content of the ES is set out in Schedule 4 of the EIA Regulations. Table 1.5 presents these requirements and indicates where in this ES the requirements have been met. Table 1.5: Required Information Required Information
Location within this ES
A description of the development, including in particular: • •
•
A description of the location of the Proposed Development; a description of the physical characteristics of the Proposed Development, including, where relevant, requisite demolition works, and the land-use requirements during the construction and operational stages;
Chapter 1: Introduction Chapter 4: The Proposed Development Chapter 5: Demolition and Construction ES Chapters 6-16 Volume 2: BHTVIA
A description of the main characteristics of the operational phase of the Proposed Development (in particular any production process), for instance, energy demand and energy used, nature and quantity of the
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materials and natural resources (including water, land, soil and biodiversity) used; •
An estimate, by type and quantity, of expected residues and emissions (such as water, air, soil and subsoil pollution, noise, vibration, light, heat, radiation and quantities and types of waste produced during construction & operation phases.
A description of the reasonable alternatives (for example in terms of development design, technology, location, size and scale) studied by the Applicant, which are relevant to the Proposed Development and its specific characteristics, and an indication of the main reasons for selecting the chosen option, including a comparison of the environmental effects.
Chapter 3: Alternatives
A description of the relevant aspects of the current state of the environment (baseline scenario) and an outline of the likely evolution thereof without implementation of the Proposed Development as far as natural changes from the baseline scenario can be assessed with reasonable effort on the basis of the availability of environmental information and scientific knowledge.
Chapter 3: Alternatives
A description of the factors specified in Regulation 4(2) likely to be significantly affected by the Proposed Development: population, human health, biodiversity (for example fauna and flora), land (for example land take), soil (for example organic matter, erosion, compaction, sealing), water (for example hydromorphological changes, quantity and quality), air, climate (for example greenhouse gas emissions, impacts relevant to adaptation), material assets, cultural heritage, including architectural and archaeological aspects, and landscape. A description of the likely significant effects of the Proposed Development on the environment resulting from, inter alia:
Chapter 4: The Proposed Development Chapter 5: Demolition and Construction ES Chapters 6-16 Volume 2: BHTVIA
Chapter 4: The Proposed Development
a) The construction and existence of the development, including, where relevant, demolition works;
Chapter 5: Demolition and Construction
b) The use of natural resources, in particular land, soil, water and biodiversity, considering as far as possible the sustainable availability of these resources;
Volume 2: BHTVIA
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ES Chapters 6-17
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c) The emission of pollutants, noise, vibration, light, heat and radiation, the creation of nuisances, and the disposal and recovery of waste; d) The risks to human health, cultural heritage or the environment (for example due to accidents or disasters); e) The cumulation of effects with other existing and/or approved projects, taking into account any existing environmental problems relating to areas of particular environmental importance likely to be affected or the use of natural resources; f)
The impact of the project on climate (for example the nature and magnitude of greenhouse gas emissions) and the vulnerability of the project to climate change; and
g) The technologies and the substances used. The description of the likely significant effects on the factors specified in Regulation 4(2) should cover the direct effects and any indirect, secondary, cumulative, transboundary, short-term, mediumterm and long-term, permanent and temporary, positive and negative effects of the development. The description should take into account the environmental protection objectives established at Union or Member State level which are relevant to the Proposed Development, including in particular those established under Council Directive 92/43/EEC and Directive 2009/147/EC. A description of the forecasting methods or evidence, used to identify and assess the significant effects on the environment, including details of difficulties (for example technical deficiencies or lack of knowledge) encountered compiling the required information and the main uncertainties involved. A description of the measures envisaged to avoid, prevent, reduce or, if possible, offset any identified significant adverse effects on the environment and, where appropriate, of any proposed monitoring arrangements (for example the preparation of a post-project analysis).
ES Chapters 6-16 Volume 2: BHTVIA
Chapter 5: Demolition and Construction ES Chapters 6-16 Volume 2: BHTVIA
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avoided, prevented, reduced or offset, and should cover both the construction and operational stages. A description of the expected significant adverse effects of the development on the environment deriving from the vulnerability of the development to risks of major accidents and/or disasters which are relevant to the project concerned. Relevant information available and obtained through risk assessments pursuant to EU legislation such as Directive 2012/18/EU(c) of the European Parliament and of the Council or Council Directive 2009/71/Euratom or UK environmental assessments may be used for this purpose provided that the requirements of this Directive are met. Where appropriate, this description should include measures envisaged to prevent or mitigate the significant adverse effects of such events on the environment and details of the preparedness for and proposed response to such emergencies.
ES Chapters 6-16 Volume 2: BHTVIA
A non-technical summary of the information provided under paragraphs 1 to 8.
NTS
A reference list detailing the sources used for the descriptions and assessments included in the ES.
Volume 1, 2 and 3
1.7.2 As required by Regulation 18(5)(b), Appendix 1.1 presents a statement from the Applicant outlining the relevant expertise or qualifications of the competent experts that have prepared the EIA and this ES. In addition, a short statement is included within each of the technical chapters (Chapters 6 – 16, Volume 2: BHTVIA and Volume 3B: TA).
1.8
ES Availability and Comments
1.8.1 The Planning Application and ES is available for viewing by the public during normal office hours at the LBL’s Planning Department and, is viewable online at the LBL Planning Portal: https://lewisham.gov.uk/myservices/planning/find-comment-planning-applications 1.8.2 Comments on the Planning Application should be forwarded to the LBL at the following address: Planning, London Borough of Lewisham, Laurence House, Catford, SE6 4RU Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 1: Introduction
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1.8.3 Printed and electronic copies of the ES can also be purchased from Plowman Craven; for further details contact webenquiry@plowmancraven.co.uk or Tel: +44 (0)20 7490 7700.
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1.9
References
Ref. 1.1: Secretary of State, 2017. Town and Country Planning (Environmental Impact Assessment) Regulations 2017. London, HMSO. Ref. 1.2: Secretary of State of Housing, Communities and Local Government, 2023. National Planning Policy Framework, 2023. HMSO. Ref. 1.3: Greater London Authority, 2021. The London Plan - The Spatial Development Strategy for Greater London. Greater London Authority. Ref. 1.4: London Borough of Lewisham, 2011. Lewisham Core Strategy. London Borough of Lewisham. Ref. 1.5: London Borough of Lewisham, 2014. Lewisham Town Centre Local Plan. London Borough of Lewisham. Ref. 1.6: London Borough of Lewisham, 2023. Regulation 19 Draft Lewisham Local Plan. London Borough of Lewisham. Ref. 1.7: Greater London Authority, 2016. Housing Supplementary Planning Guidance. London, Greater London Authority. Ref. 1.8: Greater London Authority, 2017. Affordable Housing and Viability Supplementary Planning Guidance. London. Greater London Authority. Ref. 1.9: Greater London Authority, 2012. Shaping Neighbourhoods: Play and Informal Recreation. London. Greater London Authority. Ref. 1.10: Greater London Authority, 2014. Accessible London: Achieving an Inclusive Environment. London. Greater London Authority. Ref. 1.11: Greater London Authority, 2012. London’s Foundations. London. Greater London Authority. Ref. 1.12: Greater London Authority, 2012. London View Management Framework SPG. London. Greater London Authority. Ref. 1.13: Greater London Authority, 2014. Character and Context SPG. London. Greater London Authority. Ref. 1.14: Greater London Authority, 2014. Sustainable Design and Construction SPG. London. Greater London Authority. Ref. 1.15: Greater London Authority, 2010. Mayor’s Air Quality Strategy SPG. London. Greater London Authority.
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2.0 Approach to the Assessment 2.1
Introduction
2.1.1 This Chapter sets out the approach and methodology for the assessment of the likely significant effects of the Proposed Development, in accordance with the requirements of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (as amended) (the ‘EIA Regulations’) (Ref. 2.1). The EIA Regulations set out the types of development which must be subject to an EIA (referred to as Schedule 1 development) and other developments, which may require assessment if they are likely to give rise to significant environmental effects (referred to as Schedule 2 development). 2.1.2 Whilst the overall approach and methodology is described in this Chapter, further detail on how the methodology was tailored to each environmental topic of the EIA is presented in the relevant technical assessment chapters (6 – 16 and Volume 2). 2.1.3 The Proposed Development does not fall under any of the types of development set out in Schedule 1 of the EIA Regulations. However, it constitutes ‘Schedule 2’ development, as an ‘Urban Development Project’ in accordance with Section 10(b) of Schedule 2 of the EIA Regulations. A development is considered to fall within Schedule 2 if: • •
Any part of the development is to be carried out in a sensitive area; or Any applicable threshold or criterion in the corresponding part column 2 of the table in Schedule 2 is exceeded or met in relation to that development.
2.1.4 The Site is not located within a sensitive area (as defined in Regulation 2 (a)-(g)), however, the Site area of 6.93 hectares (ha) exceeds the Schedule 2 10 (b) ‘Urban Development Projects’ threshold of 5 ha. In addition, the proposed number of residential units exceeds the 150 dwelling thresholds introduced as part of the 2015 Amendments to the EIA Regulations and would be defined as ‘EIA Development’. The Proposed Development is also likely to give rise to significant effects on the environment. As such the Applicant has undertaken an EIA and prepared this ES to support the Application. 2.1.5 The ES complies with the EIA Regulations and relevant current best practice planning and environmental guidance including the following: • • • • • •
Planning Practice Guidance ‘Environmental Impact Assessment’ (2011) (updated April 2015) (Ref. 2.2); Amended Circular on Environmental Impact Assessment: A Consultation Paper (2006) (Ref. 2.3); Environmental Impact Assessment: A Guide to Good Practice and Procedures: A Consultation Paper (2006) (Ref. 2.4); Department for Communities and Local Government (DCLG) Amended Circular on Environmental Impact Assessment (consultation paper) (Ref. 2.5); DCLG Environmental Impact Assessment: A guide to good practice and procedures (consultation paper) (Ref. 2.6); DCLG National Planning Policy Framework (Ref. 2.7);
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• •
DCLG Online Resource - Guidance for Environmental Impact Assessment (Ref. 2.8); and Department for Transport, 2008. Design Manual for Roads and Bridges Volume 11: Environmental Assessment (Ref. 2.9).
2.1.6 This guidance provides a common governing framework and methodology for the entire environmental assessment as reported in this ES and described below. Where exceptions have been made to this common approach in a particular discipline, such as Volume 2, that is described and explained in the relevant chapter, as is any occasion where guidance specific to a particular technical discipline has been applied, including assumptions and / or limitations which are particular to a single assessment. 2.1.7 In accordance with the EIA Regulations, this EIA has been undertaken based on the Proposed Development as described in Chapter 4: The Proposed Development and Chapter 5: Demolition and Construction.
2.2
EIA Process
2.2.1 EIA is a process that identifies and assesses the likely significant environmental effects (both positive and negative) of a proposed development. The process aims as far as possible to prevent, reduce and mitigate any significant adverse environmental effects, and to enhance any beneficial effects. Proposed developments to which EIA is applied are those that are likely to have significant effects on the environment by virtue of factors such as their nature, size or location. 2.2.2 The process and outcomes of the EIA are presented in a single document known as an environmental statement (ES). The contents of an ES are prescribed by the EIA Regulations and should be a clear and concise summary of the proposed development and its likely environmental effects - including direct, indirect and cumulative effects - on the natural, built and human environments. The ES is submitted to a relevant competent authority (in the case of planning applications to local planning authorities) to accompany an application for planning permission. In this way, the aim of EIA is to protect the environment by ensuring that a local planning authority, when determining a planning application for a project which is likely to have significant effects on the environment, does so in the full knowledge of the project's likely significant effects and takes this into account in the decision-making process. Alongside this, an EIA's objective is also to ensure that the public and statutory consultees are given early and effective opportunities to participate in decision making procedures.
2.3
EIA Scoping Report
2.3.1 As part of the EIA Scoping process, Plowman Craven submitted an EIA Scoping Report (Appendix 2.1) to LBL on 11th January 2024. 2.3.2 Plowman Craven received a formal Scoping Opinion from LBL on 14th June 2024 (Appendix 2.2), which has been relied upon in producing this ES. In forming their Scoping Opinion, LBL sought advice from their advisors: Temple Group.
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2.3.3 Each technical chapter sets out any topic-specific consultation comments received and how this has been addressed within the ES or design process. The ES is based on the Scoping Opinion as regulated by Regulation 18(4)(a). 2.3.4 Table 2.1 summarises the general Scoping Opinion comments received with corresponding responses. The EIA Scoping Opinion comments received in respect of the individual environmental topics and technical assessments scoped in the EIA are summarised and considered in each of the technical assessments of ES Volume 1 and 2 and are therefore not repeated in Table 2.1. Table 2.1: EIA Scoping Opinion Comments, Responses and Agreements Consultees
Scoping Comments
EIA Team Response
LBL
General Comments
This is covered in Chapter 4: The Proposed Development
There are some uncertainties in the Project Description in the Scoping Report that should be addressed in the ES as follows: It is not understood whether affordable housing is intended to be provided as part of the Proposed Development. The ES should clearly set out what level of affordable housing proposed and provide the relevant assessment. The location of the blue badge parking should be identified within the ES. It is noted that cycle parking will be provided. The ES should identify where cycle parking will be located within the Proposed Development. Section 6.4 of the Scoping Report gives mention to basements; however, does not give clear indication that basements will be included. If they are proposed then the ES will need to outline the extent, depth and location of the proposed basements, including any below ground works. The maximum basement provision must be assessed accordingly in the ES, including (for example) variations to the Application Site set-up, construction compound locations, materials arising, dewatering and traffic Volumes. The ES should also provide information on massing (including sections/elevations), the location of uses within the Proposed Development, the location and nature of public spaces and pedestrian routes, proposals for soft and hard landscaping including ecological enhancements, highway works, access and servicing arrangements (including the drop-off and collection for both deliveries and people, and parking for maintenance and trades vehicles), drainage strategy, waste management proposals, sustainability and climate change resilience measures. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 2: Approach to the Assessment
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Where different floorspace measurements are used e.g. Gross External Area (GEA), Gross Internal Area (GIA) and Net Internal Area (NIA), the ES should clearly identify how these have been calculated, based on which drawings and how the figures relate to one another. The ES should demonstrate that the plant rooms included within the Proposed Development are of a suitable size for a development of this scale e.g. to house the required mechanical ventilations, water supply etc. The ES should also ensure consequential effects of plant are assessed as required, in terms of flue location and noise. Soft landscaping should be prioritised within the Proposed Development which, where possible, should incorporate dual uses e.g. biodiversity benefits, flood attenuation/Sustainable Drainage Systems (SuDS), and wind mitigation. The way in which the Proposed Development is to be serviced should be clearly diagrammatised.
Approach to the EIA The Applicant must ensure all guidance used is relevant, up to date and clearly referenced. A reference list detailing the sources used for the descriptions and assessments must be included in the ES. It is noted that the Scoping Report makes reference to the 2021 National Planning Policy Framework (NPPF) throughout. The ES should ensure to reference the latest version. The spatial scope of the EIA is to be explained in each of the topic chapters. The temporal scope should consider the construction and operation of the Proposed Development. The decommissioning/demolition of the Proposed Development will not be considered; while this is agreed in principle, the climate change assessment has scoped in the end of life of the development. This should consider the measures that can be put in place at the planning and design stage to reduce greenhouse gas emissions from decommissioning, even if these cannot be accurately quantified (such as circular economy principles). Any consideration of climate change resilience and/or adaptation should consider a suitably distant point(s) in the future where its effects will be expected to be clearly observed. Cumulative Effects A figure has not been provided in the Scoping Report, showing the location of all cumulative schemes considered. One should be provided in the ES and we Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 2: Approach to the Assessment
This is covered in Chapter 2: Approach to the Assessment
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would expect that Site boundaries for each cumulative scheme are shown in the cumulative scheme map so that the reader can clearly see the size and footprint of these schemes and their proximity to the Site. Environmental Statement Format The ES main volume should be readable as a standalone document. The ES should not rely on reference to other documents. Noise and Vibration To establish the baseline conditions, the Applicant has undertaken 7 days of monitoring at 4 locations and a number of attended locations. The Applicant should ensure that an updated survey is undertaken for the application as the current ones were undertaken in 2021. Providing that the surveys are repeated, it is agreed that this is a representative baseline to be applied to the acoustic assessment. Air Quality The Scoping Report states that ‘data collected in 2020 and 2021 is not considered representative of typical pollution concentrations due to the COVID-19 pandemic and associated travel restrictions imposed in the UK’ and this is agreed with. However, as LBL have since published the 2023 Annual Status Report with data obtained in 2022, the Applicant should ensure that this data is used as opposed to the 2019 data.
This is covered in Chapter 6: Noise and Vibration
This is covered in Chapter 7: Air Quality
Air Quality Neutral Condition Prior to the commencement of development, an Air Quality Neutral assessment shall be submitted to and approved in writing, by the local planning authority. Air Quality Positive Condition Prior to the commencement of development, an Air Quality Positive Statement shall be submitted to and approved in writing, by the local planning authority. Transport
This is covered in Chapter 8: Transport
It is noted that the years to be assessed are still to be confirmed, and agreed with TfL and LBL. An interim scenario or an additional construction scenario may be required depending on the construction programme. It is not clear from the Scoping Report whether there will be a period where construction is ongoing on part of the Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 2: Approach to the Assessment
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site, while another part of the site remains/becomes operational. Section 5.0 states that there will be phased development. Any interim scenario is particularly relevant for the Multi-Storey Car Park, e.g. if the car park is unavailable but there are vehicular trips associated with the operation of part of the shopping centre. The ES should clearly indicate the demolition and construction programme and state if there are any periods with partial construction/partial operation (of either the existing development or Proposed Development). The ES should either provide an interim scenario or adequate justification for why one is not required. Flood Risk and Drainage It is noted and agreed that background information will be requested from the EA, Thames Water and the LLFA. The ES will be support by a Flood Risk Assessment and Surface Water Drainage Strategy. The mitigation measures secured as part of these documents should be clearly stated in the ES.
This is covered in Chapter 9: Flood Risk and Drainage
It is not clear the extent to which the basements are proposed. The ES chapter and the Flood Risk Assessment and Surface Water Drainage Strategy must be informed by LBL’s SPD which considers basements and any dewatering of these basements should be considered. Ground Conditions and Contamination General comments.
Archaeology The Applicant is strongly advised to consult with the Greater London Archaeology Advisory Service (GLAAS) to confirm the need for predetermination archaeology investigations. Daylight, Sunlight and Overshadowing General comments.
Wind Both comfort and safety will be considered in the assessment. There is no discussion of how gusts will be considered in the safety assessment. Assessment of Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 2: Approach to the Assessment
This is covered in Chapter 9: Ground Conditions and Contamination This is covered in Chapter 11: Archaeology
This is covered in Chapter 12: Daylight, Sunlight and Overshadowing This is covered in Chapter 13: Wind
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safety from strong winds must consider gust velocities using a Gust Equivalent Mean. Ecology It is recommended that the ES provides more detailed information on the bat PRA methodology and a description of buildings, explaining why they were all assessed as providing negligible suitability for roosting bats.
This is covered in Chapter 14: Ecology
A more considered assessment should be made of the possible impacts (dust, noise, lighting) on the Lewisham Railway Triangle SINC. Given its proximity to the development site (40m), it is insufficient to simply state that no impacts will occur, except lighting impacts on bats. Socio-Economics The Scoping Report states that effects on the capacity of dentists, nurseries, leisure and other community facilities will be scoped out of the ES. This has been appropriately justified as the usage of such facilities varies amongst the population. However, as stated by the NHS HUDU consultation feedback, potential effects on secondary NHS capital (such as hospitals) should be considered with the ES, alongside primary healthcare infrastructure (such as GPs). It is advised that further consultation is sought with NHS HUDU to establish an agreed methodology. Climate Change General comments.
Townscape and Visual Impact and Built Heritage As stated in the consultation feedback from Lewisham Conservation, a Heritage Impact Assessment should be produced separately to the EIA and submitted with a planning application, rather than only being addressed in the ES.
This is covered in Chapter 15: Socioeconomics
This is covered in Chapter 16: Climate Change This is covered in Volume 2: BHTVIA
NHS London Healthy Urban Development Unit (HUDU)
As an initial point of note, it is important that the EIA scope does not just include primary healthcare infrastructure but also secondary capital due to NHS aspirations within Lewisham.
This is covered in Chapter 15: Socioeconomics
Historic England GLAAS
Use of historic BGS logs in the DBA will prove invaluable.
This is covered in Volume 2: BHTVIA
Level 1 survey of the standing structures to the provided.
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Royal Borough of Greenwich
The London Borough of Lewisham is advised that the impact of the proposed development on Greenwich Local View 5 and 10 as well as views from Greenwich Park and Blackheath Conservation Area should be included within the Townscape, Heritage and Visual Impact Assessment and submitted with any future planning applications to London Borough of Lewisham.
This is covered in Volume 2: BHTVIA
London City Airport
No building or structure of the development, including temporary structures (cranes) hereby permitted shall exceed 155.93 m AMSL.
Maximum heights are documented in Chapter 4: The Proposed Development.
Conditions Development shall not commence until a Bird Hazard Management Plan has been submitted to and approved in writing by the Local Planning Authority. No cranes or scaffolding shall be erected on the site unless and until construction methodology and diagrams clearly presenting the location, maximum operating height, radius, and start/finish dates for the use of cranes during the Development has been submitted to and approved by the Local Planning Authority
2.3.5 As part of the Scoping and EIA process, consultation was undertaken with the following: • • • • • • • •
Officers at LBL; Greater London Authority (GLA); Environment Agency; Historic England and Greater London Archaeological Advisory Service (GLAAS); Natural England; Network Rail; Transport for London; and Thames Water.
2.3.6 Further detail in relation to the consultation undertaken is included within the technical Chapters (Chapters 6 – 16) and Volume 2.
2.4
Scope of the EIA Non-Significant Issues
2.4.1 As part of the EIA Scoping process, it was agreed that the following topics were unlikely to give rise to significant environmental effects and therefore would not be assessed as part of the EIA process: • • •
Waste; Human Health; Telecommunication Interference;
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• • •
Energy and Sustainability; Utilities; and Major Accidents and Disasters.
2.4.2 Justification for scoping these topics areas out of the EIA was provided in the EIA Scoping Report (Appendix 2.1).
Potentially Significant Issues 2.4.3 The potentially significant environmental issues that were identified during the EIA Scoping Process and that have been addressed within the EIA are as follows: • • • • • • • • • • • • •
2.5
Noise and Vibration (Chapter 6); Air Quality (Chapter 7); Transport and Accessibility (Chapter 8); Water Resources, Drainage and Flood Risk (Chapter 9); Ground Conditions and Contamination (Chapter 10); Archaeology (Chapter 11); Daylight, Sunlight, Overshadowing, Light Pollution and Solar Glare (Chapter 12); Wind (Chapter 13); Ecology (Chapter 14); Socio-economics (Chapter 15); Climate Change (Chapter 16); Effect Interactions (Chapter 17); Townscape, Visual and Built Heritage Impact Assessment (Volume 2).
EIA Approach Alternatives
2.5.1 An outline of the main alternatives considered by the Applicant is provided in Chapter 3: Alternatives. This also includes a description of the main reasons for the preferred building layout and massing taking into account the environmental studies which informed the design. 2.5.2 The EIA Regulations require that the ES contains ‘…A description of the reasonable alternatives (for example in terms of development design, technology, location, size and scale) studied by the developer, which are relevant to the proposed project and its specific characteristics, and an indication of the main reasons for selecting the chosen option, including a comparison of the environmental effects’. 2.5.3 Details of the following alternatives considered are presented in Chapter 3, as follows: • • •
The ‘Do Nothing’ scenario – This would result in the Site continuing in its current form; Alternative Sites; and Alternative Site Layout and land uses – this will describe the iterative process by which the final plans were agreed to identify the layout, scale, transport routes and open space provision were determined.
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Baseline 2.5.4 The baseline for the EIA has been taken as the existing Site and its surroundings in their current form, as described in Chapter 1: Introduction. 2.5.5 The EIA has been undertaken against the current baseline conditions, with the exception of transport; air quality; noise and vibration, where a future baseline (2036), namely the year of the Proposed Development’s completion, has been considered. This is discussed in Chapter 6: Noise and Vibration, Chapter 7: Air Quality and Chapter 8: Transport. 2.5.6 The baseline conditions have been characterised by means of desk studies, site visits, surveys and modelling.
Receptors 2.5.7 Consistent with the EIA Regulations, the aspects of the environment likely to be significantly affected by the Proposed Development have been identified and include in particular; population, soil, water, air, climate factors, material assets, including the architectural and archaeological heritage, landscape and inter-relationship between the above factors. 2.5.8 A number of receptors have been identified that would potentially be sensitive to effects resulting from the Proposed Development, as set out in Table 2.2. Table 2.2: Sensitive Receptors Receptors
Description
Visitors and on-site users
Existing and future users of the Site and surrounding area.
Residential
Existing and future residential properties in the surrounding area.
Commercial and Industrial
Office, retail and industrial buildings within the local area.
Social Infrastructure
Effects of the changes to the demography and socio-economics in the area on education and school facilities, churches and places of worship; health and community facilities such as GP surgeries, child care facilities and local community facilities.
Transport Network
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Existing sensitive receptors comprise: •
Local highway network;
•
Users of the surrounding streets;
•
Users of the public transport network;
•
Network of footway and pedestrian connections that serve the Site;
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•
On-street cycle routes in the vicinity of the Site; and
•
Car clubs located in the vicinity of the Site.
Townscape and Views
Surrounding townscape and character.
Ecological Receptors such as fauna and flora
Effect of demolition and construction works on existing habitats within and surrounding the Site.
Air Quality
Potential impacts on air quality during construction and long-term impacts upon the AQMA.
Heritage assets, including archaeological, heritage and landscape features
Surrounding heritage assets, including listed building and buried archaeology.
Hydrological Receptors
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Existing and future users of the Site and surrounding area.
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2.5.9 Further details of the likely significant effects on the above sensitive receptors are included within the technical chapters of this ES (6 – 16 and Volume 2).
2.6
Impact Assessment Basis of EIA
2.6.1 The EIA will be undertaken in the context of relevant planning policy at national ((National Planning Policy Framework (NPPF)), strategic and local levels. Legislation, policy or guidance which relates to a specific technical discipline will be considered as appropriate within the ES and discussed within the relevant technical chapters 2.6.2 The EIA has been undertaken on the basis of the Site, as shown in Chapter 1: Introduction and the Proposed Development as shown and described in Chapter 4: Proposed Development and Chapter 5: Demolition and Construction. 2.6.3 The Proposed Development will comprise an outline component (the ‘Outline Proposals’) and a detailed component (the ‘Detailed Proposals’). Plots N1 and N2 and associated access roads and infrastructure as well as other highways works are submitted in detail and the remaining plots, and areas of the Site are submitted in outline. It is anticipated that the Outline Proposals will seek to reserve all matters associated with land use; scale and massing; internal layout; appearance; and landscaping. 2.6.4 The spatial parameters of each Development Plot which are comprised within the Outline Proposals are defined by a series of drawings, referred to as the Parameter Plans. The Parameter Plans are accompanied by a Development Specification and Design Code, which together contain parameters in relation to the use, layout, scale, appearance and access for the Outline Proposals. Together the Parameter Plans, the Development Specification and the Design Code are referred to as the Development Control Documents. The Development Control Documents are submitted for approval and all future applications for the approval of the reserved matters would be required to be in conformity with them. 2.6.5 Where all matters are reserved the principles (but not the details) of the Outline Proposals in terms of the land uses, quantum and scale are described and assessed as part of the Proposed Development for which planning permission is sought. The spatial parameters defined by the Parameter Plans include: •
Demolition and Retention Plan;
•
Maximum Horizontal Extents of Development Plots;
•
Maximum Vertical Extents of Development Plots;
•
Access and Circulation Plan;
•
Land Use Plan; and
•
Public Realm and Open Space Plan.
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2.6.6 For the Outline Proposals, the above would define the maximum quantum of individual use classes and provide a controlling set of design codes and design principles, within which the reserved matters will be brought forward. Consideration will be given to the provision of minimum quantum parameters for any proposed employment generating uses to allow a robust assessment to the conducted. The parameters will be imposed on the planning permission by condition so it will be clear that any development that comes forward pursuant to the outline element of the permission will have been assessed for EIA purposes. 2.6.7 The Detailed Proposals will be defined by the means of the following: • •
Detailed planning application drawings; and Detailed area schedule and residential unit mix.
2.6.8 The following supporting documents will be considered during the EIA for the Proposed Development: • • • • • • • • •
2.7
A Transport Assessment (TA) (Volume 3B); A Flood Risk Assessment (FRA) (Appendix 9.1); Utilities Report; Energy and Sustainability Statement; Planning Statement (and appendices); Design and Access Statement (including Landscape Strategy); Statement of Community Involvement; Arboricultural Survey and Impact Assessment; Waste Management Strategy.
Assessment Methodology
2.7.1 The aim of the EIA is not to assess the Proposed Development's overall compliance/performance against planning policy as this is considered within the Planning Statement. Instead reference has been made in each chapter to national, regional and local policy to inform the scope of technical assessments in those chapters, the assessment methodologies applied and the existence of any sensitive receptors to be considered. Detailed methodologies for the assessment of each of the environmental topic areas scoped into the EIA are provided within each technical chapter; however, in general terms, the assessments have been based upon: •
• • • • •
Review of the existing conditions at and surrounding the Site for the environmental topic area under consideration via various sources of existing information, data and reports; Desk-top studies; Site surveys; Consideration of relevant legislation; Consideration of relevant planning policies (national, regional and local); Consultations with stakeholders and consultees as appropriate;
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•
Consideration of potentially sensitive receptors that could be affected by the Proposed Development; • Use of technical guidance and best practice; • Use of quantitative and qualitative assessment methods, professional judgement and expert opinion; • Identification of potential environmental impacts and likely effects, with an evaluation of their likely duration, magnitude and significance, taking into consideration embedded mitigation; and • Recommendation for additional mitigation and/or enhancement measures, followed by an assessment of the significance of the residual effects. 2.7.2 How the Proposed Development might affect the environment relies on predictions about what impact a certain action would have. Some predictions can be made using mathematical or simulation models, particularly where there are well known relationships between cause and effect. For example, the degree to which noise levels may increase as a result of additional traffic flows can be predicted using a mathematical equation. The level of air pollution from a known traffic flow can also be predicted from a computer-based simulation model. The visibility of a building can be predicted by accurately superimposing its outline and position over a photograph. Other impacts are less easy to predict in quantitative terms; for example, whilst the extent of a loss of a habitat can be measured, the effect on the abundance of individual species is more difficult to predict. In such cases, the EIA attempts to quantify the anticipated scale of impact using empirical experience, literature and professional judgement. 2.7.3 In all cases, the overall approach and specific methods of predicting the likely nature and magnitude of impact, as well as the scale of effect is set out in each of the technical assessments. Where used, recognised specific predictive methods are referenced. Any assumptions or limitations to knowledge are stated. In either case the thought process leading to the conclusions is based on reasonably reliable data and so is considered to be prudent and robust. 2.7.4 Where detailed information on the Proposed Development has not been available, reasonable assumptions have been made, and have been clearly set out, based on experience of developments of similar type and scale to enable assessment of likely significant effects. 2.7.5 The Proposed Development has not yet been approved so the conditional tense (‘would’) has been used to describe the development proposals, situations, potential impacts and likely effects that could/would arise from the introduction of the Proposed Development, as well as the mitigation measures that would be delivered or would be required upon approval of the Proposed Development. This approach does not lessen the Applicant’s commitment to deliver the Proposed Development as presented within this ES. Furthermore, each technical assessment (and in particular summary tables at the conclusion of each chapter) clearly sets out the means by which any required mitigation measures relied upon, would be secured.
Proposed Development Scenarios 2.7.6
The EIA considers the following stages of the Proposed Development: • • •
Demolition and Construction Stage; Completed Development Stage; and Cumulative Stage.
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Assessment Scenarios – Demolition and Construction Stage 2.7.7 On the basis that the demolition and construction programme of the Proposed Development would be sequenced 10 years, 2 scenarios (‘timeslices’) across this 10 year programme have been selected for some of the technical assessments to ensure a robust assessment. Further details are provided in Chapter 5: Demolition and Construction and each of the technical assessments (Chapters 6 – 16 and Volume 2).
Assessment Scenarios – Completed Development Stage 2.7.8 As flexibility is being sought by the Applicant within the Outline Proposals, particularly in regard to the scale and layout of the Proposed Development and the amount of floor area that could come forward for each land use class, the EIA has determined appropriate assessment scenarios that have been applied to each of the technical aspects, on a topic by topic basis, to ensure that a reasonable worst case assessment is being undertaken and the likely significant environmental effects are identified and addressed. 2.7.9 In general, the following scenarios have been considered within this ES which have been specifically chosen to ensure a reasonable worst-case scenario has been tested for each technical assessment, further detail is provided in the technical chapters as relevant 2.7.10 The different testing scenarios are discussed in detail within each technical chapter (ES Volume 1, Chapters 6 to 16 and Volume 2 and are summarised below. The detailed element will be assessed in full as that is fixed. And the outline element will be assessed alongside it. Some topics have also referred to the Illustrative Masterplan (which shows one way the Outline Element of the Proposed Development could be interpreted/achieved, in accordance with the principles set out in the control documents). • •
Scenario 1: Existing Baseline; Scenario 2: Maximum Development Parameters (For the Outline Elements);
2.7.11 However, in accordance with standard practise, Chapter 6: Noise and Vibration, Chapter 7: Air Quality and Chapter 8: Transport consider a ‘future baseline’ which comprises the year in which the Proposed Development would be fully completed, occupied and operational (2036). Accordingly, these assessments consider the following scenarios: • •
Scenario 1: Existing Baseline. Scenario 2: Future Baseline + Proposed Development + Cumulative Development (2036).
2.7.12 For the purposes of assessment, the EIA and TA have been based on total residential floorspace, which equates to the following across the detailed and outline elements. •
Detailed – 119 Homes and 445 Co-Living.
•
Outline – 1,600 homes and 661 Student Homes.
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2.7.13 In respect of the Outline Proposals, it is noted that the Applicant is seeking flexibility in respect of the location of non-residential floorspace to be delivered, albeit a minimum quantum of Town Centre related use floorspace is proposed. 2.7.14 The flexibility in Use Classes sought for approval for the Outline Proposals, generates a degree of uncertainty for the potential effects which could be derived. In order to address this, where relevant, the Socio-economics assessment has considered the minimum parameters set for non-residential uses within the Outline Proposals. Further detail is provided in Chapter 15: Socio-economics.
Design and Environmental Interface 2.7.15 Throughout the design process for the Proposed Development, the environmental specialists involved in the assessment and the project team have worked together to ensure that where possible, negative environmental effects are avoided through revisions to the scheme design before the Application Plans, as submitted for approval, were finalised. In addition, enhancement opportunities have been identified to optimise the benefits and positive aspects of the Proposed Development. For example, the design and layout as shown on the Application Plans was informed by ecology, acoustics, air quality, wind and daylight/sunlight and overshadowing input such that the scheme as presented includes inherent mitigation measures which are described further where relevant in the relevant chapters and within Chapter 3: Alternatives of this ES
Mitigation Measures 2.7.16 Mitigation measures have been identified to prevent, reduce or remedy any likely significant negative environmental effects that remain. Such measures will be implemented during the construction and / or operation phase of the Proposed Development. Where mitigation measures are identified, they will be secured via planning conditions or via a Section 106 Agreement as appropriate. 2.7.17 Each technical chapter details the measures which are recommended to mitigate any identified significant negative effects, and a summary of the recommended mitigation measures identified from within each of the technical chapters of this ES (Chapters 6 – 16 and Volume 2). A summary is provided in Chapter 18: Summary of Effects and Mitigation Measures. 2.7.18 Mitigation measures that are ‘embedded’ i.e. part of the Proposed Development, are identified within each of the technical chapters. These embedded measures are incorporated as part of the impact assessment and any mitigation required in addition is provided, to be secured by condition or section 106 obligation.
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Identification of Likely Significant Effects and Evaluation of Significance 2.7.19 Various methodologies were applied in order to determine the potential for likely significant environmental effects as a result of the demolition and construction works, and the operation of the Proposed Development. The specific methodologies for each discipline are provided in the technical chapters of this ES. 2.7.20 The technical assessments within the ES have included consideration of the following, in accordance with the EIA Regulations: • • • • •
Positive and negative effects; Short (0 – 2 years), medium (2 – 10 years) and long (> 10 years) term effects; Direct and indirect effects; Permanent and temporary effects; and Cumulative effects (Intra & Inter).
2.7.21 Several criteria have been used to determine whether or not the likely environmental effects of the Proposed Development will be deemed ‘significant’. The effects have been assessed quantitatively, where possible. Generally, the significance of effects has been assessed using international, national and local standards. 2.7.22 Where no published standards exist, the assessments presented in the technical chapters describe the professional judgements (assumptions and value systems) that underpin the attribution of significance. For certain technical topics, such as air quality, widely recognised published significance criteria and associated terminology have been applied and these are presented in the technical chapters and associated appendices where relevant. 2.7.23 The assessment of significance considers the magnitude of change (from the baseline conditions (2021), the sensitivity of the affected environment / receptors and (in terms of determining residual effects) the extent to which mitigation and enhancement measures will reduce or reverse negative effects. 2.7.24 In addition, further influences such as those listed below have been factored into the assessment using professional judgement: • • • • • • • • • • •
Likelihood of occurrence; Geographical extent; Adherence of the proposals to legislation and planning policy; Adherence of the proposals to international, national and local standards; Sensitivity of the receiving environment or other receptor; Value of the affected resource; Whether the effect is temporary or permanent; Whether the effect is short, medium, or long-term in duration; Whether the effect is reversible or irreversible; Inter-relationship between effects (both cumulatively and in terms of potential effect interactions); and The consultation responses.
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2.7.25 The magnitude (scale) of change for each effect has been identified and predicted as a deviation from the established baseline conditions, for the site preparation, demolition and construction phase, and the operational phase of the Proposed Development. The scale used (high, medium, low, and negligible) is shown in Table 2.3. 2.7.26 The sensitivity of the receptors / receiving environment to change has been determined using professional judgement, consideration of existing designations (such as Conservation Areas and Air Quality Management Areas (AQMAs)) and quantifiable data, where possible. The scale used (high, medium, low, and negligible) is also shown in Table 2.3. 2.7.27 Each effect has been assessed against the change of magnitude and the sensitivity of the receptor as shown in Table 2.3. Table 2.3: Matrix for Determining the Significance of Effects
MAGNITUDE OF CHANGE
SENSITIVITY OR RECEPTOR / RECEIVING ENVIRONMENT TO CHANGE
HIGH
MEDIUM
LOW
NEGLIGIBLE
HIGH
Major
Major
Moderate
Minor
MEDIUM
Major
Moderate
Minor
Negligible
LOW
Moderate
Minor
Negligible
Negligible
Negligible
Negligible
Negligible
NEGLIGIBLE Minor
2.7.28 The likely significance of effects reflects judgements as to the importance or sensitivity of the affected receptor(s) and the nature and magnitude of the predicted changes. For example, a moderate negative effect on a feature or site of low importance will be of lesser significance than the same effect on a feature or site of high importance. 2.7.29 The following terms are used to describe the significance of effects, where they are predicted to occur: • • • •
Major positive or negative effect: where the Proposed Development would cause a significant improvement (or deterioration) to the existing environment; Moderate positive or negative effect: where the Proposed Development would cause a noticeable improvement (or deterioration) to the existing environment; Minor positive or negative effect: where the Proposed Development would cause a barely perceptible improvement (or deterioration) to the existing environment; and Negligible: where the Proposed Development would result in no discernible improvement or deterioration to the existing environment.
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2.7.30 Residual effects that are typically deemed to be significant are those that are described as being moderate or major positive or negative, although this is dependent on the relevant technical assessment. 2.7.31 Specific criteria have been developed for certain technical studies and are provided in the respective technical chapters of this ES. The inter-relationship between likely significant environmental effects and residual effects following implementation of mitigation measures has also been discussed.
2.7.32 Residual effects that are typically deemed to be significant are those that are described as being moderate or major positive or negative, although this is dependent on the relevant technical assessment. 2.7.33 Specific criteria have been developed for certain technical studies and are provided in the respective technical chapters of this ES. The inter-relationship between likely significant environmental effects and residual effects following implementation of mitigation measures has also been discussed. 2.7.34 Tables summarising the likely significant effects associated with an environmental topic area, potential mitigation measures and residual effects are provided at the end of each technical chapter. A distinction between direct and indirect, short and long-term, permanent and temporary; primary and secondary, positive and negative effects has also been made in the summary of effects tables. 2.7.35 The characteristics of an effect will vary depending on the duration of the activity causing the effect, the sensitivity of the receptor and the resultant change. It is therefore necessary to assess whether the effect is short, medium or long term; temporary or permanent; positive and negative, and reversible or irreversible. Effects that are temporary are reversible and generally confined to the construction period. 2.7.36 For the purposes of this ES the terms used in the assessment of effects are generally defined as follows: • • • • • • • •
Short-term: where the effect would be of short duration and would occur for up to 2 years; Medium-term: where the effect occurs for a period of between 2 - 10 years; Long-term: where the effect occurs for 10 years or more and includes permanent effects; Temporary: where the effect occurs for a limited period of time and the change at a defined receptor can be reversed; Intermittent: where the effect occurs for short periods of time and may re-occur occasionally at regular or irregular intervals; Permanent: where the effect represents a long-lasting change at a defined receptor; Direct: where the effect is a direct result (or primary effect) of the Proposed Development; Indirect: a secondary effect which occurs within or between environmental components, may include effects on the environment which are not a direct result of the Proposed Development, often occurring away from the proposals or as a result of a complex biological or chemical pathway; and
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•
Cumulative: the collective effects of changes that may be insignificant individually but in combination, often over time, have the potential to be significant (see Section on cumulative below).
2.7.37 Where a more appropriate effect duration scale or definition of the above terms is applicable to a technical discipline this is clearly outlined with the technical chapters (Chapter 6 – 16 and Volume 2). 2.7.38 Following identification of an effect, the scale of the effect, its nature, geographic extent and duration and whether the effect is direct or indirect using the above summarised terminology, a clear statement is then made as to whether the effect (pre-mitigation) is significant or not significant. Each technical topic addressed within the ES is clear on which effects are significant and those which are not. 2.7.39 As a general rule, the following applies: • •
‘Moderate’ or ‘major’ effects are deemed to be ‘significant’; and ‘Minor’ or ‘Negligible’ effects are ‘not significant’.
2.7.40 Following identification of the significance of the potential or ‘unmitigated’ effects, the requirement for any mitigation to either eliminate or reduce likely significant adverse effects is identified. 2.7.41 Where mitigation measures have been identified to either eliminate or reduce likely significant adverse effects, these have been incorporated into the Proposed Development, (for example through the design), or they will comprise demolition and construction commitments or operational or managerial standards / procedures which will be imposed by condition or section 106 obligation. 2.7.42 The ES then highlights whether the ‘residual’ effects remain significant following the implementation of suitable mitigation measures and, classifies these in accordance with the terminology defined above. 2.7.43 In all cases, the overall approach and specific methods of predicting the likely magnitude of impact and resultant scale, nature, geographic extent, duration etc and significance of an effect is set out in each of the technical assessment chapters of this ES. Where used, recognised specific predictive methods are referenced. Any assumptions or limitations to knowledge are stated.
Residual Effects 2.7.44 Following the implementation of mitigation measures, an assessment of the significance of residual effects has been undertaken. The findings are presented in each technical chapter of this ES and a summary included of all residual effects for this ES are provided in Chapter 19: Summary of Residual Effects.
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2.8
Cumulative Effects In-Combination Effects / Effect Interaction
2.8.1 In-combination effects (otherwise referred to as effect interactions) from the Proposed Development itself on surrounding sensitive receptors during the enabling and construction works and once the Proposed Development is completed are considered within this ES (Chapter 17: Effect Interactions). 2.8.2 The assessment has focused on key individual receptors and receptor groups considered to be most sensitive to potential interacting effects and includes an assessment on residential amenity. 2.8.3 Only residual effects that are minor, moderate or major in scale have been considered within this assessment, as negligible effects are, by definition, imperceptible in their scale. 2.8.4 Professional judgement has been used to determine whether the residual effects of the Proposed Development could interact to result in a potential in-combination effect or effect interaction on the receptor in question. 2.8.5 The scale of an effect interaction is not assigned as part of this assessment; however, whether the in-combination effects / effect interaction is considered to be significant or not is identified. For example, when one or more residual significant effects (i.e. effects that are moderate or major in scale) from different EIA topics (i.e. air quality, noise and vibration, HGV traffic or visual impact) coincide on a receptor, the effect interaction has been identified as significant.
Cumulative Effects with Other Developments 2.8.6 Developments that have been included within the cumulative assessment have been discussed and agreed with LBL as part of the Scoping process. Where there have been any changes to this position (i.e. buildings are now built out and therefore included in the baseline) this is discussed in Table 2.4 below. The inter-project cumulative assessment is provided at the end of each individual technical Chapter (Chapter 6 – 16 and Volume 2). A plan of the developments is included in Figure 2.1. 2.8.7 The developments in Table 2.4 have been selected based on the following agreed criteria: Approximately within a 1km radius Predominately developments with full planning consent or a resolution to grant consent; and Produce an uplift of more than 10,000m (Gross External Area (GEA)) of mixed-use floorspace, or over 150 residential units.
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2.8.8 The TA and traffic data utilised for the assessment of road traffic effects in respect of local air quality and noise includes the predicted total future traffic generation on the local highway network including relevant cumulative developments within the local area, thus providing a quantitative cumulative transport, air quality and noise assessment. The cumulative assessment for these topics is therefore also reported in their relevant topic chapter of the ES as it forms a modelling scenario of their impact assessment. 2.8.9 Cumulative effects have been identified and assessed for the majority of disciplines (Chapter 17: Effect Interactions) through a desk based qualitative study using professional expertise to make a judgment as to the likely significance of changes in baseline conditions in the area surrounding the Site arising from the completion of the Proposed Development together with surrounding cumulative developments. 2.8.10 A quantitative assessment approach has been adopted where appropriate and possible, and where data is available. Consideration has been given to the timing and spatial influence of the Proposed Development and the identified cumulative developments. 2.8.11 The inter-project cumulative assessment presents the findings of the assessment of cumulative effects arising from the Proposed Development’s interactions with surrounding cumulative developments and provides the context for this assessment. This assessment is reported at the end of each technical Chapter (6 – 16 and Volume 2). 2.8.12 Where specific developments are either so far constructed or occupied, they have been included in the baseline assessment in each of the technical Chapters. This is specified in Table 2.4 below.
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Table 2.4: Developments Included in the Cumulative Assessment
No.
Scheme
Developer(s)
1)
Carpetright, Loampit Vale, SE13 7SN
Lewisham Exchange & Tide Construction Ltd
Description
Planning Reference
The comprehensive redevelopment of the Carpetright site, DC/20/118766 Loampit Vale, SE13 including the demolition of the existing Carpetright building and the construction of two buildings of 20 storeys and 35 storeys in height plus basement comprising: 838.2 sqm non-residential floorspace, comprising (A1) Shops, (A2) Financial & Professional Services, (A3) Restaurants & Cafes, (B1) Business, (D1) Non-residential Institutions and (D2) Assembly & Leisure uses; 67 (C3) self-contained housing units with private and communal amenity space; 758 (Sui Generis) student housing bedspaces with communal amenity space; associated ancillary space, including refuse stores and cycle parking; and landscaping and public realm works. In December 2020, minor material amendment to planning permission to change the use of unit 1b from flexible commercial space to a gym ancillary to the student accommodation
2)
1 Silver Road, London, SE13 7BQ
London Square Demolition of existing buildings (Axion House), 1 Silver Road, DC/18/109972 Development SE13 and the construction of buildings ranging between 5 to 16 Ltd. storeys in height, to provide 141 residential units, and flexible B1/A1/A3/D2 commercial uses, associated landscaping works, vehicular access, cycle and car parking
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Status
Notes
Approved: March 2019
0.4-mile walk from Lewisham Shopping Centre
Approved: October 2019 This planning permission is being built out. Some units occupied in September 2021.
Approved: December 2020 Approved: 15th May 2020
Construction commenced Q3 2021
20-35 Storeys Update as of October 2024, this development is built out and occupied so considered as part of the baseline. 0.5-mile walk from Lewisham Shopping Centre
5-16 Storeys
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this development is built out so considered as part of the baseline. 3)
Land at former car parks, Tesco Store, Conington Road, Lewisham
Brock Carmichael & Watkin Jones Group
Construction of three buildings, measuring 8, 14 and 34 storeys DC/21/121768 in height, to provide 365 residential dwellings (use class C3) and 554.sqm gross of commercial/ community/ office/ leisure space (Use Class A1/A2/A3/ B1/ D1/ D2) with associated access, servicing, energy centre, car and cycle parking, landscaping and public realm works. In May 2021, minor material amendment to change the description of development.
Lewisham Gateway, London SE13
Lewisham Gateway Developments Ltd and Balfour Beatty
Construction commenced Q2 2021 Approved May 2021
Application for minor material amendments. The amendments include for minor amendments to residential mix, internal layouts, elevational treatment, the introduction of an additional storey (at level 34) to Block B1, a reduction in floor to floor heights to 3metres, a reduction in heights of all three buildings, landscape and access changes. 4)
Approved at appeal January 2020
Approved December 2021
S73 application for minor material amendments to original DC/18/105218 planning permission (LPA reference. DC/06/62375) dated May 2009. The amendments comprise the reduction of the overall floorspace to 97,545m², amendments to the floorspace allocated to the approved uses, introduction of co-living accommodation (sui generis) and co-working/business space (B1), amendments to the physical parameters of Blocks C1, C2, D1, D2 and E including increasing the height of blocks, changes to the footprints and massing, omission of Block F and basement car parking, and associated changes.
Approved: 31st March 2015
0.3-mile walk from Lewisham Shopping Centre 8-34 Storeys Update as of October 2024, this development is built out and occupied so considered as part of the baseline. 0.2-mile walk to Lewisham Shopping Centre 15-22 Storeys Update as of October 2024, this development is built out and occupied
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5)
Lewisham Retail Park
Legal and General Assurance Society Ltd
Approval of Reserved Matters for Blocks C (part 3/10/12 storeys), D1 (16-19 storeys), D2 (30 storeys) and E (4 storeys) to provide a total of 530 residential units (comprising 16 studio units, 238 one-bedroom units, 271 two-bedroom units and 5 three-bedroom units), 6,308m² (GEA) of co-living floorspace (comprising 119 co-living units and communal facilities (Use Class sui generis), 4,381m² (GEA) of retail/restaurant/cafe, floorspace (Use Class A1 and/or A3), 1,525m² (GEA) of coworking floorspace (Use Class B1), a cinema, (2,472m² GEA) and gym (1,606m² GEA) (Use Class D2), and associated hard and soft landscaping works, pursuant to condition 2, relating to layout, scale, appearance and landscaping for the comprehensive mixed use redevelopment of the outline approval DC/18/105218 (granted on 29 November 2018) under Section 73 of the Town & Country Planning Act 1990 as a Minor Material Amendment in connection with the planning permission DC/06/62375 (granted on 8 May 2009) for the comprehensive mixed use redevelopment of the Lewisham Gateway Site, SE13 (land between Rennell Street and Lewisham Railway Station) for up to 100,000m² comprising retail (A1, A2, A3, A4 and A5), offices (B1), hotel (C1), residential (C3), education/health (D1) and leisure (D2) with parking and associated infrastructure, as well as open space and water features.
Approved: 28 February 2023
The comprehensive redevelopment of the Lewisham Retail Park DC/16/097629 and Nos. 66 - 76 Loampit Vale including the demolition of all buildings on site to facilitate the provision of 4,343sqm of nonresidential floorspace comprising (A1) Shops, (A2) Financial & Professional Services, (A3) Restaurants & Cafés, (B1) Business, (D1) Non-Residential Institutions and (D2) Assembly & Leisure uses and 536 residential units in buildings ranging from 4 - 24 storeys in height with private and communal open spaces, onsite energy centre, car and cycle parking, and associated landscaping and public realm works.
Approved:
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28th March 2019
so considered as part of the baseline.
0.3-mile walk to Lewisham Shopping Centre
Construction 4-24 Storeys status unknown No precommencement conditions discharged Plowman Craven 46730 October 2024
6
Lewisham Market
London Borough of Lewisham
Development comprising a market house and canopy structure DC/24/136236 to cover Lewisham Open Market and provide additional civic function together with associated public realm at Lewisham Open Market, Lewisham High Street SE13
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Approved 30th July 2024
Adjacent to the east of the existing Shopping Centre.
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Figure 2.1: Developments Included in the Cumulative Assessment
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2.9
Assumptions and Limitations
2.9.1 The key assumptions that have been made and any limitations that have been identified in producing this ES are set out below. Assumptions specific to certain topics are identified in the appropriate technical chapters: • • • •
• • •
Information received from third parties is complete and up to date; Impact assessments for each EIA topic are based upon current or emerging (as identified) legislative and policy framework; The scheme description is as confirmed in Chapter 4: The Proposed Development and assessments are based upon the application plans and schedules submitted as part of the planning application; Construction activities will be as outlined in Chapter 5: Demolition and Construction and undertaken during normal construction industry working hours, assumed to be 07h30 – 18h00 Mondays to Fridays, Saturdays 08h00 – 13h00 and no noisy activities to occur on Sundays and Bank Holidays (out of hours works / deliveries will be subject to prior agreement and / or notice of LBL); The design, construction and completed scheme will satisfy minimum environmental standards and be consistent with contemporary legislation, good practice and knowledge; Conditions will be attached to the planning permission, if approved, that will minimise disturbance during construction works including the provision of a construction environmental management plan (CEMP); Developments included within the cumulative effects assessment will be implemented as per the information pertaining to the application that is publicly available. It is assumed that these developments will be subject to the relevant environmental standards, legislation, policy and good practice conditions;
2.10 Structure of the Technical Chapters 2.10.1 Each technical chapter is generally structured as follows: • • • • • • • • • •
Introduction; Competence; Legislation, Planning Policy and Guidance; Consultation; Assessment Methodology and Significance Criteria; Baseline Conditions; Sensitive Receptors; Assessment of Effects, Mitigation and Residual Effects for both stages: o Demolition and Construction; and o Operation. Limitations and Assumptions; and Summary.
2.10.2 Volume 2 broadly follows the same structure outlined above.
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2.11 References Ref. 2.1: Secretary of State, 2017. Town and Country Planning (Environmental Impact Assessment) Regulations 2017. London, HMSO. Ref.2.2: Secretary of State of Housing, Communities and Local Government, 2018. National Planning Policy Framework and relevant planning practice guidance 2018. HMSO. Ref.2.3: Secretary of State of Housing, Communities and Local Government, 2006. Amended Circular on Environmental Impact Assessment: A Consultation Paper 2006. HMSO. Ref.2.4: Secretary of State of Housing, Communities and Local Government Environmental Impact Assessment: A Guide to Good Practice and Procedures: A Consultation Paper, 2006. HMSO. Ref.2.5: Secretary of State of Housing, Communities and Local Government, 2006. Amended Circular on Environmental Impact Assessment: A Consultation Paper 2006. HMSO. Ref.2.6. Secretary of State of Housing, Communities and Local Government, 2006. Environmental Impact Assessment: A guide to good practice and procedures (consultation paper) 2006 Ref.2.7: Secretary of State of Housing, Communities and Local Government, 2023. National Planning Policy Framework, 2023. HMSO. Ref.2.8: Secretary of State of Housing, Communities and Local Government. Guidance for Environmental Impact Assessment. Ref.2.9: The Highways Agency, 2008. Design Manual for Roads and Bridges Volume 11: Environmental Assessment Techniques. 2008. Department for Transport, London
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3.0 Alternatives 3.1
Introduction
3.1.1 This Chapter summarises the main design alternatives considered by the Applicant and provides a qualitative comparison of their relevant environmental effects. The main environmental aspects that have informed the design include townscape, daylight and sunlight, wind and pedestrian connectivity.
3.2
Consideration of Alternatives
3.2.1 The EIA Regulations (Ref. 3.1), require an ES to provide: “… an outline of the main alternatives studied by the applicant or appellant and an indication of the main reasons for the choice made, taking into account the environmental effects”. 3.2.2 The main alternatives which have been considered by the Applicant during the iterative design process to reach the defined position now proposed in the Application for the Proposed Development are described below. 3.2.3 Further details can be found in the Design and Access Statements (Ref. 3.2, 3.3 & 3.4).
Proposed Development – Key Objectives
3.3
3.3.1 In the evolution of the Proposed Development a range of approaches to the town centre have been considered. A comprehensive approach has been selected as delivering the optimal outcome for the Site and the maximum package of public benefits. 3.3.2 Comprehensiveness delivers: • • • • • • •
Compliance with the objectives of the development plan and national policy overall; A strategic approach to the whole of the site whether buildings are retained, part retained or demolished; A crafted approach to massing which allows large scale interventions in less sensitive parts of the site to support the viability of smaller scale but important interventions elsewhere; A balance of uses and tenures that is carefully curated and aligned with policy that could not be delivered by smaller individual schemes; The inclusion of benefits which on their own would not be viable but become deliverable through the optimisation of residential floorspace in areas of the site, such as community buildings; A coherent design for public space across the site; A common framework for post development estate management.
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3.3.3 In addition the extant policy support for a comprehensive approach is being significantly strengthened in the emerging Local Plan which is explicit about its preference for a comprehensive approach, designating the site within Site Allocation LCA 2. Only comprehensive development will be able to deliver the strategic objectives for Lewisham town centre and the emerging site allocation while also being mindful of other policies. 3.3.4 The Site represents an opportunity to regenerate currently underutilised land to provide new housing, town centre uses, employment and open space. In addition to this is the desire to meet and provide for the comprehensive regeneration of the Site as per the London Plan (Ref. 3.5), Lewisham Core Strategy (Ref. 3.6) and Lewisham Town Centre Local Plan (Ref.3.7). 3.3.5 The images below identify some of the key aims and objectives that have been considered by the project team.
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3.4
Consultation and Community Engagement
3.4.1 The proposals have been subject to extensive pre-application discussions with LBL planning, design, highways and other officers since 2021. Detailed pre-application discussions have also taken place with the GLA and TfL. 3.4.2 There has been a comprehensive programme of consultation and engagement with the local community including more informal consultation at public events in the local area and a number of formal public exhibitions have been held. 3.4.3 The list of consultees includes the following:
• • • • • • • • •
LBL / GLA Officers: Environment Agency; Historic England and Greater London Archaeological Advisory Service (GLAAS); Natural England; Transport for London; Network Rail; Thames Water; The local community; Shopping centre tenants, landowners within the proposed development area, neighbouring owners and occupiers, and town centre stakeholders as a whole, such as the market traders; Design Review Panel.
•
3.4.4 The Proposed Development has evolved throughout the pre-application process in direct response to comments raised by consultees. Amendments have been made to the proposed land uses, design and layout as a direct response of these pre-application discussions. 3.4.5 The 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. 3.4.6 Alongside the pre-application process of consulting with public bodies, an extensive programme of consultation with the public has been ongoing for the past two years, taking 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;
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•
Themed public workshops;
•
Existing Site Tours;
•
Engagement with local youth group Circle Collective.
Design Champions 3.4.7 Set up in September 2022, the Design Champions were a carefully selected group of 16 local residents, appointed by the Applicant 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 (November 2022);
•
Movement (November 2022);
•
Public Realm (November 2022);
•
Northern Square (April 2024).
3.4.8 The detailed consultation process is set out and explained in full in the submitted Statement of Community Involvement (SCI) (Ref. 3.8).
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3.5
Alternatives Analysis
3.5.1 The following sections review the alternatives to the Proposed Development that have been considered by the Applicant, including:
3.6
•
The Do-Nothing / No Development Alternative;
•
Alternative Sites; and
•
Alternative Design /Design Evolution.
The ‘Do Nothing’ Scenario / No Development Alternative
3.6.1 The Do-Nothing / No Development Alternative refers to the option of leaving the Site in its current state. The ‘Do Nothing’ scenario was not considered given the identification of the Site in the Lewisham Town Centre Local Plan and emerging Local Plan. There is a clear policy imperative to secure its redevelopment. 3.6.2 If the Site was left in its current state, it would result in the following:
• • • • •
No delivery of housing (including affordable housing), new town centre floorspace and employment opportunities in accordance with planning policy objectives; No additional community facilities; No improvement in neighbourhood connectivity and permeability; No improvement in public realm or creation of open space; and No ecological and habitat enhancements.
3.6.3 As a result, the 'Do-Nothing’ Scenario was not considered by the Applicant considering that this would not be an efficient or optimal use of the land.
3.7
Alternative Sites
3.7.1 The Site represents an opportunity to regenerate currently underutilised previously developed land to provide new housing, town centre uses, employment and open space. 3.7.2 No other site in the town centre offers similar regeneration opportunities in terms of opportunity for change, location, accessibility and scale. 3.7.3 In addition, as above, this position is supported by the London Plan and Local Plan. 3.7.4 Given the above policy position and the clear need for this Site to be regenerated, no alternative Sites have been considered.
3.8
Considerations for the Proposed Development Site Constraints and Environmental Considerations
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3.8.1 An analysis of the Site and the existing conditions in the surrounding area has been undertaken as part of the EIA process. Key constraints and sensitive receptors have been documented in Chapter 1: Introduction and the technical chapters. 3.8.2 As a result of this analysis, the following constraints have been taken into account in the design evolution process. Flood Risk, Drainage and Site Levels 3.8.3 The Environment Agency Flood Zone Map indicates the Site lies within flood zone 2 & 3, meaning the risk of flooding is medium-high. As a result, a wide range of Sustainable Drainage Systems, including permeable paving, temporary storage areas and underground storage tanks have been incorporated into the final design based on discussions with the EA, LBL and Thames Water. Arboriculture 3.8.4 No trees within the Site are subject to a Tree Protection Order (TPO). However, consideration was given to minimising impacts to retained trees during the demolition and construction works, with continued measures for protection once the Proposed Development has been completed. In this regard, an arboricultural survey was undertaken and advice sought in respect of impact to existing trees and where mitigation was needed. Ecology 3.8.5 Ecological surveys were undertaken to determine any constraints in respect of ecology. Any habitat lost has been carefully replaced within the proposals and this re-provision has played a key part in the proposals to achieving a significant biodiversity net gain across the Site. Contamination 3.8.6 Due to the Site’s previous use and Site Investigations carried out (Chapter 10: Ground Conditions and Contamination), contamination and the potential for remediation was a consideration in the design process. Noise and Air Quality 3.8.7 Baseline noise and vibration surveys were undertaken at the Site to characterise existing conditions. Existing constraints include road noise. 3.8.8 The Site is located within an AQMA. The AQMA has been designated due to NO 2 and PM10 concentrations in excess of the current National Air Quality Standard objectives. 3.8.9 As a result, technical design input has been undertaken to ensure that the Site is suitable for residential use. Consideration was given to:
• • •
Location of habitable rooms; Location of residential units at higher level to avoid ground level exposure to noise and NO2 / particulates, as far as possible; Location of open space and playspace relative to high levels of noise to maximise acoustic separation; and
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•
Required ventilation requirements and glazing performance to ensure target criteria would be achieved and internal spaces would be suitable for use. Measures to minimise noise emissions from the Proposed Development (such as those from demolition and construction works, plant, servicing and delivery arrangements and vehicle movements) were actively explored during the design evolution process.
Wind 3.8.10 Numerous wind assessments using a 3D computational model were undertaken during the design evolution process to inform the design evolution of the Proposed Development, to inform the most appropriate locations for amenity space and building entrances, as well as to highlight any areas for refinement and further development. Daylight, Sunlight and Overshadowing 3.8.11 The proposals were subject to numerous daylight, sunlight and overshadowing assessments to consider impacts and effects to the surrounding sensitive receptors, as well as at the proposed on-site residential units, amenity spaces and play spaces. 3.8.12 These assessments resulted in the refinement of building heights and massing, and where possible, buildings were set back or reduced in height to improve daylight and sunlight levels. Townscape and Visual Impact 3.8.13 Townscape and visual image assessments have been carried out using CGI to superimpose building designs into the existing landscape from a range of viewpoints. A number of viewpoints were used ranging from immediately adjacent to the site to higher vantage points in public spaces. This technique of visualising unbuilt architecture has enabled the refinement of the Proposed Development. Transport 3.8.14 Increased connectivity and permeability throughout the Site has been a common theme throughout the design process. 3.8.15 Measures to minimise the demolition and construction transport impacts and effects of the Proposed Development were explored, including alternative construction systems and methodologies, as well as potential routes for construction traffic to and from the Site.
3.9
Alternative Forms of the Proposed Development
3.9.1 As part of the evolution of the Proposed Development, and as outlined above, consideration was given to the site history and the existing environmental constraints and opportunities within and surrounding the Site and the adjoining areas, to inform the land uses, nature, scale and massing and proposed layout of the built form and the areas of open space and public realm of the Proposed Development. Such considerations have occurred over a period of time in the context of relevant national and local planning policies, best practice guidance and development standards as operated by LBL and other decision-making bodies.
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3.9.2 The over-arching objective has been to ensure the creation of a deliverable, sustainable development and comprehensive regeneration of the area as defined by the NPPF (Ref. 3.9), which responds to local needs, environmental conditions and the Site context, and development plan policies and objectives. 3.9.3 Key objectives for the Proposed Development have been to create a new destination in the town centre including new cultural and leisure attractions, vibrant retail and food markets and spaces for new and existing businesses, as well as a new residential neighbourhood with a high quality public realm and integrated public transport links to wider parts of the vicinity and to central London and beyond, with the following key design aspects: •
Comprehensive re-development of the Shopping Centre;
•
Creation of a new cultural hub at the centre of the Site;
•
Lewisham House retained, extended and converted to residential use;
•
Covered shopping centre replaced with permeable external streets running through the Site, extending the existing High Street market into the Site; and
•
A mixed-use approach including commercial, student, co-living and residential uses.
3.9.4 The Proposed Development design has been informed by key elements of the Site’s context and by an understanding of the Site’s constraints. The Applicant selected the proposed design, taking into account the sunlight, daylight and overshadowing, wind, townscape, transport and access, and technical issues (including engineering and avoidance of key constraints), as well as the issues raised during consultation with officers at LBL, TfL, and Thames Water and in response to the pre-application meetings and public consultation events held. 3.9.5 Three key alternatives are set out below, including the Proposed Development, demonstrating the design evolution over time. This focuses on engagement with the Local Authority but also captures feedback from other stakeholders including public consultation, and the environmental response of the proposals.
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November 2021
Key Design Features • • • • • •
Approximately 2,500 homes. 21 buildings. Demolition and redevelopment across the site including on the High Street. Maximum heights around 40 storeys. General reduction in retail floorspace with internal shopping centre replaced with part open / part covered street. Lewisham House excluded from development proposals.
Environmental Effects • Height, scale and number of tall buildings creating visual and microclimate effects on public realm and neighbouring buildings. • Impacts on local character and heritage assets due to significant demolition of existing buildings and redevelopment of High Street. • Socio-economic impacts of reduction in retail employment floorspace as against existing condition. • Townscape impacts of height, scale and number not supported by Local Planning Authority • Issues with wind conditions across site.
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August 2022
Key Design Features • • • • •
Reduction in quantum of residential development leads to a reduction in number, scale and massing of taller buildings. Increases in retail quantum at ground floor. Roof of shopping area proposed as public green space. Increased retention of buildings along High Street. Lewisham House plot included in scheme, existing building demolished and replaced with two towers.
Environmental Effects • • • • • • •
Increased embodied carbon impact through demolition of Lewisham House. Reduced townscape impact vs previous scheme due to reduction in height and number of tall buildings. Improved sunlight and daylight microclimate across the site. Improved wind conditions at base of buildings. Increased access to green spaces for residents and public in areas with improved air quality Increases in green space giving rise to ecologic uplift and improved Urban Green Factor. Reduced effects on local character and heritage assets through reduced redevelopment on High Street and reduced scale of new buildings adjacent to High Street.
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May 2024
Key Design Features • • • • • •
Plots N1 and 2 developed as detailed designs to be submitted as a detailed planning application with co-living as a use. Lewisham House (plot N3) hybrid proposal with part re-use of existing structure and extension onto adjacent land. Further reduction in C3 floorspace. Fully enclosed shopping centre and first floor retail street further increases town centre uses floorspace. 2 community / cultural buildings included. Additional east / west routes crossing site. Environmental Impacts
• • • •
Further reduction in height scale and massing reduces townscape impacts. Less demolition and further retention on hight street buildings and reduction of new development on High Street reduces local character and heritage effects and improves embodied carbon. Improved sunlight / daylight microclimate including all proposed playspace meeting BRE standards for sun on ground. Wind impacts at ground level tested and satisfactory.
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• •
Retained and new town centre floorspace comparable to the base line floorspace currently in use, and Site Allocation LCA2 town centre capacity, with greater opportunities for employment densities to increase. Full demolition of Lewisham House rejected on carbon impact grounds. Revised hybrid approach significantly improves carbon outcome without losing optimised delivery of homes and achieving emerging site allocation across the masterplan area.
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3.10 Conclusions 3.10.1 The reasonable alternatives, layouts and massing options (including development-wide and building specific design, location, size and scale) were explored in the context of physical and environmental considerations, effects and constraints facing the Proposed Development. 3.10.2 Critical developments through a long pre-application with Lewisham Council are summarised as: •
General reduction in residential scale and quantum in order to reduce the height and number of tall buildings across the site.
•
Focussing density and height in those parts of the site (west and north) where height impact is less sensitive, and reducing density elsewhere (central spine and east).
•
Introducing other living uses which support masterplan wide viability in the context of reduced overall quantum.
•
Increasing the retention of buildings with local character and heritage merit along the high street.
•
Minimising the impact of town centre servicing, while maximising the provision of town centre uses.
•
Maximising public space, and especially public green space, across the masterplan.
3.10.3 The May 2024 represents the preferred option, which provides an improvement on both previous options for the following environmental reasons: • • •
Reduced townscape impacts. Less demolition, improving embodied carbon and built heritage impacts. Improved wind, sunlight and daylight.
3.10.4 This has led to the final design proposals of the Proposed Development.
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3.11 References Ref. 3.1: Secretary of State, 2017. Town and Country Planning (Environmental Impact Assessment) Regulations 2017. London, HMSO. Ref. 3.2: Studio Egret West, 2024. Design and Access Statement – Masterplan. Ref. 3.3: Mae, 2024. Design and Access Statement – N1. Ref. 3.4: Archio, 2024. Design and Access Statement – N2. Ref. 3.5: Greater London Authority, 2021. The London Plan - The Spatial Development Strategy for Greater London. Greater London Authority. Ref. 3.6: London Borough of Lewisham, 2011. Lewisham Core Strategy. London Borough of Lewisham. Ref. 3.7: London Borough of Lewisham, 2014. Lewisham Town Centre Local Plan. London Borough of Lewisham. Ref.3.8: Something Collective, 2024. Statement of Community Involvement. Ref.3.9: Department for Communities and Local Government, 2023. The National Planning Policy Framework. HMSO.
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4.0 The Proposed Development 4.1
Introduction
4.1.1 This Chapter of the ES presents a description of the Proposed Development. It provides sufficient information on the Proposed Development to aid the identification and assessment of potential environmental impacts and likely environmental effects across the environmental topic areas addressed by the EIA and as presented in Chapters 6 - 16 and Volume 2. Further details on the Proposed Development can be found within the Design & Access Statements (Ref. 4.1, 4.2, 4.3) that have been submitted in support of the Application. 4.1.2 In accordance with the EIA Regulations, this Chapter sets out the physical characteristics of the Proposed Development; the main characteristics of the operational stage; as well as estimations of the resources, emissions, residues and wastes envisaged as part of the Proposed Development. The environmental effects arising from the demolition and construction phases are considered within Chapter 5: Demolition and Construction. 4.1.3 As set out in Chapter 2: Approach to the Assessment, the EIA is based on the assessment of the maximum floorspace for the Proposed Development, including 119 new homes (Class C3) for the Detailed Proposals, and we have assumed (for the purposes of this assessment) that 1,600 new homes (Class C3) will be comprised in the Outline Proposals. In addition, 445 Co-Living Units (Sui Generis) are provided in the Detailed Proposals, and 661 Student Homes (Sui Generis) in the Outline Proposals. Further details are provided below, including the nonresidential provision across the Detailed and Outline Proposals. 4.1.4 As outlined in Chapter 2: Approach to the Assessment, the Outline Proposals have been defined by the means of Parameter Plans, which fix the maximum envelope for assessment of the Proposed Development. The Development Specification defines the minimum and maximum quantum of individual use classes and in combination with the Design Code, provide a controlling set of design principles, within which subsequent reserved matters applications would have to be brought forward. 4.1.5 Further information on the Proposed Development can be found within the following planning application documents: • • •
•
Design and Access Statements (Ref. 4.1, 4.2, 4.3); Design Code (Ref. 4.4); Detailed Plans, Sections and Elevations for the Detailed Proposals; Parameter Plans for the Outline Proposals; Development Specification
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4.1.6 Other documents submitted in support of the Application and which assist in the understanding and evaluation of the Proposed Development include: • • • • • • •
4.2
Illustrative Masterplan, plans and diagrams included within the Design and Access Statements; Public Realm and Landscaping strategy, included within the Design and Access Statements; Planning Statement (Ref. 4.5); Transport Assessment (Volume 3B of this ES); Energy Strategy (Ref. 4.6); Sustainability Statement (Ref. 4.7); Waste Management Strategy (Ref. 4.8).
The Application
4.2.1 The Application is submitted as a hybrid application with Plots N1 and N2, associated access roads, shopping centre interface and infrastructure as well as other highways works submitted in detail (the ‘Detailed Proposals’) (Parts of Phase 1a) and the remaining Plots (N3, C1, C2.1, C2.2, C3, C4, C5, S1, S2, S3, S4, MV and M1) and areas of the Site submitted in outline (‘Outline Proposals’). 4.2.2 A description of the development for which planning permission is sought is set out below: ‘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: o Living Uses, comprising residential (Class C3) and student accommodation (Sui Generis); o Town Centre Uses (Class E (a, b, c, d, e, f, g (i, ii)) and Sui Generis); o 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;
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•
• • • • •
4.3
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’.
Description of the Proposed Development General Arrangement, Layout and Quantum of Development
4.3.1 The Application has been split into a 15 Plots, identified on Figure 4.1 and discussed in the sections below.
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Figure 4.1: Illustrative Plan Identifying the Location of the Plots Across the Site
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Table 4.1: Detailed Proposals: General description of the Plots and Land Use Distribution Plot
N1
N2
Phase 1a Finish Works
Description, including Proposed Land Use and Quantum This Plot is located to the north-east of the Site and forms part of the detailed proposals. It is intended to provide a mix of Co-Living (Sui Generis) at the upper levels and Flexible Commercial (Use Class E, Sui Generis) at ground floor level. The Plot is up to 89m AOD in height, 23 storeys, including rooftop plant. This Plot is located to the north-east of the Site, to the south of Plot N1 and forms part of the detailed proposals. It is intended to provide a mix of Residential (C3) at the upper levels and Flexible Commercial (Use Class E, Sui Generis) at ground floor level. The Plot is up to 62m AOD in height, 15 storeys, including rooftop plant. Class E / Sui Generis. The Phase 1a Finish Works are those structures (and their use) which are required to connect the existing shopping centre and public realm into the permanent and completed finished state of N2. The Phase 1a Finish Works may need to be changed when the detail of Phase 3 comes forward. 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 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 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.
4.3.2 Details of those ‘matters to be reserved’ and ‘no matters reserved’ across the Plots are provided in Table 4.2. Table 4.2: Matters Reserved for the Outline Proposals Plots
Detailed / Outline
Access
Appearance
Landscaping
Layout
Scale
N1 and N2
Detailed Proposals (no matters reserved)
X
X
X
X
X
N3, C1, C2.1, C2.2, C3, C4, C5, S1, S2, S3, S4, MV and M1
Outline Proposals (matters reserved)
✓
✓
✓
✓
✓
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Land Use – Detailed Proposals 4.3.3 The area schedule for the Detailed Proposals is presented in Table 4.3 and 4.4 and shows the maximum quantum of each use-class. Table 4.3: Total Floorspace by Use for the Detailed Proposals Use
Amount sqm GEA
Amount sqm GIA
Amount sqm NIA
N1: Co-Living (Sui Generis)
20,444.8
18,486.4
10,752.8
N1: Flexible Commercial (Use Class E, Sui Generis)
912.2
780.7
739.1
N1: Site Wide Ancillary Plant Total
756.2
675.5
N2: Residential and Residential Ancillary (Use Class C3)
N2: Flexible Commercial (Use Class E, Sui Generis) Phase 1a Finish Works (Class E / Sui Generis)
12,990
11,867
7,698 (excluding plant, amenity and ancillary) 10,697 including the above.
1,864
1,717
1,513 including access and temporary use
345
310
Table 4.4: Proposed Residential Unit Mix for the Detailed Proposals Unit Type
Home No.
Percentage
Hab Room No.
Percentage
Co-Living Room
445
100%
445
100%
Total
445
100%
445
100%
Studio
10
8%
10
3%
1 bed
55
46%
110
38%
2 bed
46
39%
138
48%
3 bed
8
7%
32
11%
Total
119
100%
290
100%
N1
N2
Land Use – Outline Proposals 4.3.4 The Outline Proposals are divided into 13 Plots, which are defined on Figure 4.1. The total development floor space across the Plots is set out in schedule contained in Table 4.5.
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Table 4.5: Outline Proposals – Proposed Uses and their Maximum Quantum Item
1
Type
Living
2
3
Town Centre
4
5
Service Deck
Description
Use Class
Development Specification (GEA) sqm Minimum
Up to (maximum)
Residential
C3
none
164,894
Student Accommodation
Sui Generis
none
26,134
Town Centre Uses
Class E (a, b, c, d, e, f; g (i, ii)); and Sui Generis
23,333
Community & Cultural Uses
Class F.1; F.2; and Sui Generis
1,751
Elevated service deck to be shared between uses for servicing and loading
C3, Class E (a, b, c, d, e, f, g (i, ii)); a Class F.1; F.2; and Sui Generis
none
46,666
Total
6
Public Realm
5,940
243,634
The Park
Open space
5,255 sqm
None
7
Northern Square
3,360 sqm
None
8
Eastern Terrace
1,970 sqm
None
Class E Commercial, business and service (a, b, c, d, e, f, g (i, ii)) •
Use, or part use, for all or any of the following purposes: (a) for the display or retail sale of goods, other than hot food, principally to visiting members of the public, (b) for the sale of food and drink principally to visiting members of the public where consumption of that food and drink is mostly undertaken on the premises,
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(c) for the provision of the following kinds of services principally to visiting members of the public: (i) financial services, (ii) professional services (other than health or medical services), or (iii) any other services which it is appropriate to provide in a commercial, business or service locality, (d) for indoor sport, recreation or fitness, not involving motorised vehicles or firearms, principally to visiting members of the public, (e) for the provision of medical or health services, principally to visiting members of the public, except the use of premises attached to the residence of the consultant or practitioner, (f) for a crèche, day nursery or day centre, not including a residential use, principally to visiting members of the public. (g) for: (i) an office to carry out any operational or administrative functions, (ii) the research and development of products or processes, Class F.1 (Learning and non-residential institutions) •
Any use not including residential use: (a) for the provision of education, (b) for the display of works of art (otherwise than for sale or hire), (c) as a museum, (d) as a public library or public reading room (e) as a public hall or exhibition hall, (f) for, or in connection with, public worship or religious instruction, (g) as a law court Class F.2 (Local community)
•
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•
(a) a shop mostly selling essential goods, including food, to visiting members of the public in circumstances where: (i) the shop’s premises cover an area not more than 280 metres square, and (ii) there is no other such facility within 1000 metre radius of the shop’s location, (b) a hall or meeting place for the principal use of the local community, (c) an area or place for outdoor sport or recreation, not involving motorised vehicles or firearms, (d) an indoor or outdoor swimming pool or skating rink
•
Sui generis – No class specified (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, (m) as a casino, (n) as a betting office, (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, Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 1: The Proposed Development
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(x) a dance hall Proposed Unit Mix and Tenure 4.3.5 The residential provision across the Outline Proposals would include a range of unit types. The proposed unit and tenure mix that has been tested is based on the Illustrative Masterplan, is presented in Table 4.6, 4.7 and 4.8. Table 4.6: Proposed Residential Unit Mix and Tenure tested for the Outline Proposals Unit size
Affordable (LAR)*
Private
Affordable (DMR)*
Units
Habitable Rooms
Units
Habitable Rooms
Studio
169
169
0
0
1 bed
582
1164
14
2 bed (3 person)
248
744
2 bed (4 person)
286
3 bed (4 person) 3 bed (5 person)
Habitable Rooms
Units
Hab Rooms
0
0
169
169
29
84
168
680
1361
14
44
34
101
295
889
859
18
54
43
129
347
1042
0
0
8
34
0
0
8
34
77
305
17
67
7
29
101
402
3,241
71
228
1,600
3,897
Total (Indicative scheme)
Units
Total
1,361
427 168
*London Affordable rent ** Discount market rent
Table 4.7: Proposed Residential Unit Numbers tested for the Outline Proposals Plot
Homes
N3
452 homes
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C1
85 homes
C2.1
59 homes
C2.2
120 homes
C3
149 homes
C4
323 homes
C5
174 homes
S2
174 homes
S3
64 homes
Table 4.8: Proposed Student Accommodation tested for the Outline Proposals Plot
Provision
S1
107 studios 252 cluster beds 350sqm GEA amenity space
S4
302 cluster beds 468sqm GEA amenity space
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Land Use Distribution 4.3.6 A general arrangement plan for the Proposed Development at ground floor level (Level 00), Level 1 (01), Level 2 (02) and Level 4 (Level 04) is provided in Figures 4.2, 4.3, 4.4 and 4.5. This is provided as ‘illustrative’ for the Outline Proposals i.e. one possible way the Plots might be built-out within the parameters.
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Figure 4.2: Illustrative Masterplan – Level 00
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Figure 4.3: Illustrative Masterplan – Level 01 Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 1: The Proposed Development
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Figure 4.4: Illustrative Masterplan – Level 02 Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 1: The Proposed Development
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Figure 4.5: Illustrative Masterplan – Level 04 Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 1: The Proposed Development
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The Detailed Proposals 4.3.7 The Detailed Proposals consists of 2 plots: N1 and N2, and the Phase 1a Finish Works. The Plots will accommodate Co-Living, Residential, Flexible Non-Residential, together with all landscaping, public realm, and associated works. Plot N1
Figure 4.6: Detailed Proposals – N1 - Ground Floor Plan
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Figure 4.7: Detailed Proposals – N1 – Eight Floor Amenity
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Plot N2
Figure 4.8: Detailed Proposals – N2 - Ground Floor Plan
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Figure 4.9: Detailed Proposals – N2 - Roof Plan
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Phase 1a Finish Works
Figure 4.10: Phase 1a Finish Works – Level 00
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Outline Proposals 4.3.8 The Outline part of the Planning Application is supported and informed by an Illustrative Masterplan, Parameter Plans, a Development Specification and Framework and a Design Code. 4.3.9 The accompanying Parameter Plans set out the planning application red line showing the overall Application Boundary, the Detailed Planning Application Component (pink hatching) and existing buildings excluded from the Application Boundary (grey hatching). 4.3.10 The Parameter Plans referred to below are submitted for approval in relation to that part of the Site for which outline planning permission is sought. These Parameter Plans set the parameters or building envelope for the Outline Proposals, and all reserved matters submitted pursuant to the Planning Permission must be in accordance with the approved Parameter Plans. 4.3.11 The details of the Outline Proposals would be approved in future reserved matters applications. Demolition and Retention Plan 4.3.12 Parameter Plan 03 – Demolition and Retention Plan - Level 00 (0386-SEW-ZZ-00-DR-APL6003), Parameter Plan 04 - Demolition and Retention Plan - Level 01 (0386-SEW-ZZ-ZZDR-A-PL6004), Parameter Plan 05 - Demolition and Retention Plan - Level 02 and Above (0386-SEW-ZZ-ZZ-DR-A-PL6005) 4.3.13 sets out the proposed demolition and retention for the Outline Proposals, split into the following elements: • • • • •
Demolition; Retention without works; Existing basement retention without works; Retention of facades as a minimum; Retention with significant alteration.
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Maximum Horizontal Extents of Development Plots 4.3.14 Parameter Plan 06 – Maximum Horizontal Extents of Development Plots Plan - Level 00 (0386-SEW-ZZ-00-DR-A-PL6006), Parameter Plan 07 - Proposed Maximum Horizontal Extents of Development Plots - Level 01 (0386-SEW-ZZ-ZZ-DR-A-PL6007), Parameter Plan 08 - Proposed Maximum Horizontal Extents of Development Plots - Level 02 (0386-SEW-ZZZZ-DR-A-PL6008), Parameter Plan 09 - Proposed Maximum Horizontal Extents of Development Plots - Level 03 and above (0386-SEW-ZZ-ZZ-DR-A-PL6009) sets out the maximum footprint / extent of each Plot.
Maximum Vertical Extents of Development Plots 4.3.15 Parameter Plan 10 - Maximum Vertical Extents of Development Plots (0386-SEW-ZZ-ZZ-DRA-PL6010) and Parameter Plan 11 - Maximum Vertical Extents of Building Maintenance Units (0386-SEW-ZZ-ZZ-DR-A-PL6011) sets out the maximum height of each Plot. Access and Circulation Plan 4.3.16 Parameter Plan 12 - Access and Circulation Plan - Level 00 (0386-SEW-ZZ-ZZ-DR-APL6012) and Parameter Plan 13 - Access and Circulation Plan - Level 01 (0386-SEW-ZZZZ-DR-A-PL60123 sets out the access points. Land Use Plan 4.3.17 Parameter Plan 14 - Land Use Plan Level 00 (0386-SEW-ZZ-ZZ-DR-A-PL6014), Parameter Plan 15 - Land Use Plan Level 01 (0386-SEW-ZZ-ZZ-DR-A-PL6015), Parameter Plan 16 Land Use Plan Level 02 (0386-SEW-ZZ-ZZ-DR-A-PL6016) and Parameter Plan 17 - Land Use Plan Level 03 and above (0386-SEW-ZZ-ZZ-DR-A-PL6017) set out the land uses across the Site. Public Realm and Open Space Plan 4.3.18 Parameter Plan 18 - Public Realm and Open Space Plan - Level 00 (0386-SEW-ZZ-ZZ-DRA-PL6018), Parameter Plan 19 - Public Realm and Open Space Plan - Level 01(0386-SEWZZ-ZZ-DR-A-PL6019) and Parameter Plan 20 - Public Realm and Open Space Plan - Level 02 and above (0386-SEW-ZZ-ZZ-DR-A-PL6020) sets out the locations of the public realm and open space.
4.4
Building Heights Outline Proposals
4.4.1 Proposed building heights across the Outline Proposals are provided in Table 4.9 below. For the Outline Proposals, the maximum building heights have been assessed for the Wind, Daylight/Sunlight and Townscape assessments.
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Table 4.9: Building Heights – Outline Proposals
4.5
Building
Height (AOD)
Storeys
N3
+124.255m
23 & 33
C1
+60.610m
7 & 12
C2.1
+50.935m
9
C2.2
+63.835m
13
C3
+90.685m
21
C4
+137.285m
35
C5
+100.360m
24
S1
+91.085m
21
S2
+103.585m
25
S3
+57.060m
11
S4
+78.185m
17
MV
+29.735m
5
M1
+32.810m
3
Car Parking
4.5.1 Car parking for the Detailed Proposals is provided in Table 4.10. Table 4.10: Detailed Proposals Parking Type Car Parking N1
No. Blue Badge
Co-Living
1
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Commercial N2
0
Residential
3
Commercial
0
Total
4
4.5.2 Car parking for the Outline Proposals is provided in Table 4.11. Table 4.11: Outline Proposals Parking Type
No.
Car Parking
Long Stay
Residential
46
Non-Residential
10
4.6
Cycle Parking
4.6.1 Cycle parking for the Detailed Proposals is provided in Table 4.12. Table 4.12: Detailed Proposals Parking Type Cycle Parking
No. Long Stay
Short Stay
336
12
200
4
N1 Co-Living N2 Residential Phase 1a Total Commercial
32
4.6.1 The 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.
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4.7
Public Realm and Landscaping
Detailed Proposals 4.7.1 Landscaping provided as part of the Detailed Proposals (N1 and N2) is shown in the Figures below. 4.7.2 Amenity space provided across N1 and N2 includes the following: • •
N1 Communal internal amenity: 1,392 sqm. Private external (terraces (426.9 sqm). N2 private external amenity (balconies and terraces): 399.54 sqm.
Figure 4.11: N1 – Level 00 Landscaping
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Figure 4.12: N1 – Roof Plan Landscaping
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Figure 4.13: N2 – Roof Plan Landscaping
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Phase 1 Public Realm 4.7.3 A number of considerations affect the design and delivery of the 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.
4.7.4 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 . 4.7.5 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. 4.7.6 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. 4.7.7 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. 4.7.8 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.
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Figure 4.14: Illustrative Plan Phase 1a and Phase 1b Public Realm
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Outline Proposals 4.7.9 Key spaces within the Outline Proposals include: •
Northern Square – Level 00 – 3,360 sqm;
•
The Street – Level 01 – 1,050 sqm ;
•
Eastern Square – Level 01 – 1,970 sqm ;
•
The Park – Level 02 – 5,255 sqm; and
•
Southern Square – Level 00 - 1,300 sqm.
Figure 4.15: Outline Proposals – Key Spaces Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 1: The Proposed Development
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Northern Square 4.7.10 The Northern Square is an urban arrival square combining generous circulation space, building spill out zones, seating areas and a central gathering space, with an intensity of meadow style planting. Permanent water bodies and integrated SuDS features are important to the character of the square. 4.7.11 As the northern square sits adjacent to the River Ravensbourne and within the flood zone of the river, the design has been inspired by organic patterns and shimmering pools of water meadows. 1. Existing trees retained along Molesworth Street. 2. New crossing to Cornmill Gardens. 3. Gathering space. 4. Vertical access up to Level 01 ‘The Street’. 5. Permanent water bodies to create sense of water meadow all year round. 6. Spill out zones. 7. Shopping Centre entrance. 8. Arrival point from Rennell Street crossing. 9. Sculptural bench. 10. Stepped and ramped access to Molesworth Street.
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Figure 4.16: Illustrative Plan of the Northern Square
Eastern Square 4.7.12 The Eastern Square is an elevated square facing onto Lewisham High Street with a focus on providing space for young people. Active edges and seating structures amongst planting create a variety of social opportunities. 1. Rocky heath meadow planting ensures the meadow concept extends to the high street, providing a tranquil green space in the a key town centre location. 2. Large south facing spill out and seating area adjacent to places to eat and drink. 3. Spill out and gathering space adjacent to potential cultural, community and leisure use animating the southern side of The Eastern Square.
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4. Prominent stair to the park level and extensive terracing with views onto The Eastern Square and Lewisham High Street. 5. Retained and integrated Woolworth’s building with potential for more leisure or community use. 6. A place for young people. Interesting and bespoke structures where young people are welcome to hang out and feel safe and welcome. Ideally, these structures would be codesigned with the young people who will use them. 7. Boardwalk that makes direct connection between lower and upper levels. 8. Lift access between The Eastern Square and The Park. 9. Escalator and stepped access between Lewisham High Street and The Eastern Terrace. 10. Intermediate planting level, extending the meadow to Lewisham High Street.
Figure 4.17: Illustrative Plan of the Eastern Terrace
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The Street 4.7.13 The Street is an active, linear route connecting the squares. The Street provides a food and drink destination within the town centre. Somewhere people can pick up lunch and also stay later into the evening for dinner and drinks. The robust public realm aims to support these uses by allowing for spill out whilst maximising planting where possible. The robust rocky heath meadow character supports this greater level of footfall and activation. The Street also forms an important connecting route, so a clear zone is maintained in the centre to allow easy circulation. 1. Continuous active frontages of food, drink and leisure on both sides. 2. Spill out areas for seating from restaurants and bars. 3. Clear circulation route for pedestrian movement that is clear of activity on both sides. 4. Additional mid level terrace between street and park, with views up and down and the potential for additional active frontage 5. Residential connection to the park at upper level. 6. Lush planting and trees break down space, creating purposefully meandering routes and encouraging dwell. 7. Hanging lighting to create an ambient atmosphere in the evening and minimise clutter in the public realm.
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Figure 4.18: Illustrative Plan of the Street
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The Park 4.7.14 The Park is a generous, elevated green space at the heart of the proposals for Lewisham Shopping Centre. It provides a much needed green space within the town centre. A place to relax, away from the busy activity of the high street and ground level squares. The planting aims to be the most vibrant meadow in this location, allowing people to sit amongst an ever changing display of seasonal meadow species. The more flexible, heavily planted meadow is activated by a destination play space to north of the park, a community pavilion to the east, a social use to the south such as a nursery, and residential entrances to the west. The park is composed of the following elements: 01 Designed for dwell. Carefully mounded wildflower planting ensures the park is protected, suitable for sitting and picnics. 02 An open clearing is located at the centre of the park. The wildflower meadow is cut short in this location, allowing a more flexible area for people to sit or play informal sports. 03 Directional paths allow fully accessible routes across the space, connecting stepped and lift access points to residential cores. 04 The house amongst the meadow. Community pavilion providing direct access by lift to other levels, and supporting park use through baby change, WCs and buggy storage. Hard standing and shaded canopies allow activity of the pavilion to spill out into the park. 05 Significant destination play space to north of the park, visible from the northern square below. The play space is split to provide an area in a sunny environment and one in a less exposed, more shady environment. 06 Buffer planting mitigating the noise and pollution of Molesworth Street. 07 Integrated stepped seating looking over The Eastern Square and Lewisham High Street. 08 Mid level walkway access. 09 Ecological planting zone to the south of the park. This area is less programmed allowing an quieter space, to sit amongst nature. Greater number of trees and scrub planting to create important town centre habitats. 10 Active family, community and food uses, increasing attractiveness and dwell for families. 11 Direct stepped access to park level.
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Figure 4.19: Illustrative Plan of the Park
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The Southern Square
Figure 4.20: Illustrative Plan of the Southern Square
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4.8
Pedestrian Routes
4.8.1 Links through the Site are proposed between the new open spaces, Lewisham Gateway and the High Street.
Figure 4.21: Pedestrian Routes
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4.9
Vertical Access
4.9.1 Movement up to L01 The Street and L02 Podium Park legible from entry points into the development. There are a number of vertical circulation points throughout.
Figure 4.22: Vertical Access Routes
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4.10 Vehicle Movements 4.10.1 Plots will be serviced from surrounding entry points off Lewisham High Street and Molesworth Street. The Outline Proposals will also accommodate for blue badge parking and loading bays within the public realm.
Figure 4.23: Vehicle Movements
4.11 Refuse N1 4.11.1 Resident interface with waste management services in N1 is based on a resident bring system (i.e. residents access the refuse room and place waste directly into the respective bins). The refuse room is located and accessed at ground floor level with entry adjacent to the building core and the single route of exit from the building (see blue arrows indicating the resident exit / entrance).
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N2 4.11.2 The resident interface with waste management services in N2 is a ‘post box’ style resident bring system, with access at ground floor level. The refuse post room is located next to the main core housing the lifts and stair to access the residential units. The designs accommodate 3 ‘post box’ openings in the refuse post box wall into the only refuse room, which will allow residents to deposit the three separate waste streams (recycling, food waste and residual waste). Outline Proposals 4.11.3 There are a variety of resident interface options available for waste management. The specific residential waste management strategies for the respective Masterplan plots are yet to be defined and will be developed accordingly as these plots go through the detailed development stages towards reserved matters application. 4.11.4 Each building plot will be reviewed independently based upon the evolving building design, residential tenure and space allocation to determine the most appropriate residential waste management solution. 4.11.5 It is envisaged that the resident interface with waste management for the Masterplan plots will use one, or a combination, of the following strategies: •
Resident bring system.
•
Partial resident bring system.
•
Fully managed refuse chute system.
4.12 Proposed Lighting 4.12.1 An integrated lighting strategy will ensure that the public realm is safe and accessible after dark. Light levels will be specified in accordance with the with relevant standards including BS 5489-1:2013 and ILE Guidance. 4.12.2 Wherever possible, light sources will be integrated within architectural features. Key pedestrian routes through the Site will be emphasised.
4.13 Ecological Enhancements 4.13.1 The Proposed Development will provide ecological benefits by including native species, evergreen and semi evergreen species which will provide shelter for wildlife during winter months, RHS ‘plants for pollinators’ species, and fruits/seeds for wildlife. 4.13.2 A Biodiversity Net Gain (BNG) assessment has been undertaken (Appendix 14.4) leading to a gain of 346% based on the introduction of the new habitat and planting across the site.
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4.14 Building Systems N1 4.14.1 There are 4 No. Multi-function Heat Pump Units located on the external roof level of N1 which provides heating and cooling to the building. 4.14.2 The heat pumps have been designed to use low GWP refrigerant R290, and operate efficiently. When providing cooling heat can be recovered to simultaneously supply heat to the building. 4.14.3 There are 3 No. CO2 Air Source Heat Pumps located on the external roof level of N1 which provides domestic hot water to the building. 4.14.4 The primary heating/cooling plant regulates an LTHW/CHW network. The LTHW serves fan coils in each residential apartment to provide space conditioning. 4.14.5 Each residential unit will be provided with a Mechanical Ventilation Heat Recovery (MVHR) unit. This will be located and ducted at ceiling level. 4.14.6 Terminal units are designed to achieve a specific fan power in operation significantly lower than the Part L 2013 limiting SFP. 4.14.7 All spaces will include 100% low energy lighting. N2 4.14.8 There are 2 No. Multi-function Heat Pump Units located on the external roof level of N2 which provides heating and hot water to the building. 4.14.9 The heat pumps have been designed to use low GWP refrigerant R290, and operate efficiently supplying heat at 60 degrees. 4.14.10 The primary heating/cooling plant regulates an LTHW network serving HIUs in each residential apartment to provide space heating and hot water. 4.14.11 Each residential unit will be provided with a Mechanical Ventilation Heat Recovery (MVHR) unit. This will be located in a utility cupboard and ducted to the façade at ceiling level. 4.14.12 A small number of apartments require cooling due to acoustic constraints, in this case, cooling will be supplied by an active cooling coil within the MVHR unit. All apartments have been future proofed by allowing space in utility cupboards for cooling if required in the future. Terminal units are designed to achieve a specific fan power in operation significantly lower than the Part L 2013 limiting SFP. 4.14.13
All spaces will include 100% low energy lighting.
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Outline Plots 4.14.14 The remaining phases will also be served via ASHPs located on their respective roof levels. 4.14.15 The primary heating/cooling plant regulates an LTHW network. The LTHW serves inapartment HIUs which in turn provide heating and hot water. 4.14.16
Lewisham Shopping Centre will be fully electric.
4.15 Utilities Electricity 4.15.1 The Site will be served by a High Voltage (HV) ring from the Distribution Network Operator’s (UKPN’’s) network. The HV ring will connect the transformers sited in the dedicated substation rooms within buildings. Gas 4.15.1 No gas is intended to be provided to the site for heating production purposes, nor for apartments cooking. Potable Water 4.15.2 The residential water supply is to be provided from storage tanks located within each Plot. The service from the tanks will be metered once the boosted service reaches the end users (apartments etc). Foul Water 4.15.3 All foul water drainage from the proposed development will drop to the below ground drainage network. This network will be routed to the external courtyard and access road, and then outfall via a new 100mm diameter gravity connection to the 600mm diameter Thames Water foul sewer to the North of the site, via a demarcation manhole 4.15.4 Further information is provided in Chapter 9: Water Resources, Drainage and Flood Risk and Appendix 9.1 and 9.2. Surface Water 4.15.5 Run-off will be controlled at source, with green roofs, extensive soft landscape of the two-level podium and SUDS features at ground level. 4.15.6 At podium level attenuation is proposed in modular shallow drainage units, typically 150mm deep, installed within the podium build-up above the waterproofing. For the associated catchments, this storage can provide the majority of the volume required for restriction to peak greenfield runoff rate and therefore plays a key role in the overall strategy. Remaining attenuation is provided in downstream catchments to meet the peak discharge rates and ensure there is no flooding on site.
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4.15.7 At ground level SUDS features are maximised as attenuation provision within the public realm, with use of raingardens, filter drains and permeable paving.
4.16 Energy and Sustainability 4.16.1 An Energy Strategy and Sustainability Statement been developed to outline how the Proposed Development would perform across a number of areas, including: • • • •
Compliance with Building Regulations Part L energy analysis; The Greater London Authority (GLA) London Plan; Overheating in line with CIBSE Guidance and future climate change; and Social value review and enhancements.
4.16.2 The key principles are as follows: •
Zero carbon development through energy efficient design, low carbon heating, renewable energy systems and local carbon offsetting; • A landscape led design that enables easy access to green spaces, helping people to relax and improving mental health; • A holistic flood risk and drainage design integrated into the natural environment increases site resilience to climate change; • Diverse transport connections promote an active community, improving mental and physical wellbeing of the wider community; • Homes are designed to provide natural daylight, reduced energy bills and a comfortable internal environment. 4.16.3 Low energy and carbon approach, as follows: •
The energy strategy would minimise energy use and CO2 emissions through the incorporation of a highly efficient thermal envelope, efficient building services systems, as well as ASHP technology.
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References Ref. 4.1: Studio Egret West, 2024. Design and Access Statement – Masterplan. Ref. 4.2: Mae, 2024. Design and Access Statement – N1. Ref. 4.3: Archio, 2024. Design and Access Statement – N2. Ref. 4.4: Studio Egret West, 2024. Design Code. Ref. 4.5: Quod, 2024. Planning Statement. Ref. 4.6: WSP, 2024. Energy Strategy. Ref. 4.7: Bioregional, 2024. Sustainability Statement. Ref. 4.8: SLR, 2024. Waste Management Strategy.
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5.0 Demolition and Construction 5.1
Introduction
5.1.1 This Chapter provides a factual summary of the proposed demolition and construction works associated with the Proposed Development to provide a basis for the technical assessments of the likely significant effects of the demolition and construction of the Proposed Development and the proposed mitigation measures as reported in the technical chapters (Chapters 6 16) and Volume 2. 5.1.2 This Chapter should be read in conjunction with Chapters 1 – 4, and the respective appendices. It is supported by an outline Construction Environmental Management Plan (CEMP) (Appendix 5.1) which will be submitted in full under a planning condition, as well as a Construction Logistics Plan (CLP) (for Phase 1a) which is presented in Volume 3B. 5.1.3 This Chapter has been informed by LBL’s guidance, including the Good Practice Guide: Control of pollution and noise from demolition and construction sites (Ref. 5.1) and information provided by the Applicant which sets out how the construction works would be carried out and the Applicant’s intentions for managing the construction process. 5.1.4 Once a principal contractor has been instructed, it is proposed that a formal CEMP would be prepared for the Proposed Development. The CEMP would include all details of relevant environmental management controls necessary for environmental protection during the demolition and construction works. The Contractor would use the appended CEMP (Appendix 5.1) as a framework for the CEMP submission, following the principles and approaches set out. 5.1.5 It should be noted that planning for demolition and construction is necessarily broad at this stage (as Demolition Method Statements (DMS) and Construction Method Statements (CMS) and specifications have not yet been prepared and a contractor not yet appointed) and so may be subject to modification during any future detailed demolition and construction planning. For this reason, the information following on the anticipated demolition and construction works is based on reasonable assumptions, particularly with regard to the demolition and construction programme, and the collective experience of the Applicant and the wider design and planning teams with similar projects. 5.1.6 It is important to note that this chapter does not assess the magnitude of potential impacts, nor the significance of likely effects during the demolition and construction works. These are included within individual technical assessments in ES Volume 1 (Chapters 6 - 16) and ES Volume 2.
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5.2
Programme and Phasing Phasing Overview
5.2.1 A detailed development programme has not yet been finalised. The programme presented within this ES Chapter is an indicative, feasible, programme that has been developed by the Applicant based on a number of assumptions. It is considered robust for the purposes of the assessment of the likely environmental effects within this ES and presents a reasonable worst-case scenario for the basis of the assessment. 5.2.2 Subject to the granting of planning permission by LBL, and the discharge of relevant planning conditions, the anticipated Site demolition and construction phases are outlined in Figures 5.1 and 5.8. 5.2.3 It is expected that a condition would be imposed on the Planning Permission that would require the submission of a phasing plan prior to commencement. This is expected to be similar to the indicative phasing below. If the submitted plan is substantially different, and is likely to result in new or different significant environmental impacts, a supplementary Environmental Statement (ES) would accompany the updated phasing plan. 5.2.4 The phasing is split into three main phases, starting at the north of the Site, before undertaking the second phase in the south. The third phase is arranged so as to demolish and re-build the main extent of the shopping centre in sub-phases, with the ambition of keeping the shopping centre functional in some capacity throughout the duration of construction.
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Figure 5.1 Indicative Phasing Plan Overview Levels 00 and 04
Phase 1A: Plot N1, N2, Northern Square and Music Venue Refurbishment 5.2.5 01 86-102 Lewisham High Street will be divided: the eastern half will remain as existing town centre and residential use, while the western half will be demolished to create a construction zone and service yard for Plot N1. This demolition will include Riverdale Hall, the leisure box and Boots. 5.2.6 02 On the western boundary, demolition will extend to the service strip adjacent to the eastern elevation of Lewisham House at the service deck level. The phasing line will be moved as far west as possible to create a larger public space with a mix of permanent and temporary landscape works. As Lewisham House is a large structure sitting close to the phase 1a demolition line, a Building Impact Assessment has been prepared by WSP which reports that the impact of the Phase 1a works on this property will be “negligible” with predicted movement of less than 1mm. Nevertheless a Monitoring Action Plan will be prepared to monitor the works as they progress.
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5.2.7 03 A new shopping centre entrance will be created at the south of the northern square, including a retail entrance into Plot N2 that will be replaced by the landscaped steps in the final scheme. 5.2.8 04 The existing building at the south of the site will be refurbished to include music venues and workspaces for creative industries on the upper levels.
Figure 5.2 Indicative Phase 1A, Levels 00 and 04
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Phase 1B: Plot N3 & Northen Square Completion 5.2.9 01 A temporary ramp will be installed on the south side of the site to serve the service deck. 5.2.10 02 Once the southern temporary ramp is operational, demolition of the northern core of Lewisham House and the Northern Ramps will proceed. 5.2.11 03 Following this, main construction works for Plot N3 will commence. 5.2.12 04 The remaining area of the northern square adjacent to Plot N3 can be completed. 5.2.13 05 A new temporary route through to Molesworth Street will be created between plot N3 and the retained multi-storey car park
Figure 5.3 Indicative Phase 1B, Levels 00 and 04
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Phase 2A: Plots S1, S2 and permanent southern ramp 5.2.14 01 The southern parts of the Multi-storey-car-park will be reduced to allow for the construction of Plot S1 and a new southern ramp. 5.2.15 02 The shopping centre’s southern entrance will close for the phase 2A construction of Plots S1 and S2. These plots will be procured under the same contract to enable efficient construction of permanent ramps. 5.2.16 03 A temporary ramp will provide access to the service deck until the permanent southern ramp is finished 5.2.17 Plots S1 and S2 will be occupied once construction on both buildings is complete. 5.2.18 Temporary landscaping work east of Plots S1 and S2 will be needed for the Phase 2B construction.
Figure 5.4 Indicative Phase 2A, Levels 00 and 04 Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 5: Demolition and Construction
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Phase 2B (Part 1): Plot S3 and temporary entrance to the south of the shopping centre 5.2.19 01 After demolition of the shopping centre in this area, Plot S3 with its private external amenity space will be constructed. 5.2.20 02 The permanent public area for the east-west route connecting the high street to Molesworth Street will be built (New Romer Place). 5.2.21 03 This will enable a temporary entrance to the south of the shopping centre will be established, similar to that now operational in Phase 1a.
Figure 5.5 Indicative Phase 2B, Levels 00 and 04
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Phase 2B (Part 2): Plot S4 & completion of phase 2 public realm 5.2.22 01 Plot S4 would be constructed adjacent to the permanent ramp. 5.2.23 02 Phase 2 public realm works will be completed with the creation of Model Market Square and improvements to the rear of the existing Primark building, which will feature kiosks for active use along this facade.
Figure 5.6 Indicative Phase 2B, Levels 00 and 04
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Phase 3A: Plots C1, C2 and the Eastern Terrace 5.2.24 01 To ensure the shopping centre continues operating, a hoarding line will be placed along the eastern edge of the existing concourse. The eastern portion will be demolished, while the western portion operates with the new northern and southern temporary entrance and the existing western entrance. 5.2.25 02 Plots C1, C2.1, and C2.2 will then be constructed along with the eastern half of the new shopping centre. 5.2.26 03 The eastern terrace at level 01 and the southern portion of the F&B street at level 01 will be completed in their permanent conditions.
Figure 5.7 Indicative Phase 3A, Levels 00 and 04
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Phase 3B: Plots C3, C4, C5 and Level 02 podium park 5.2.27 01 The western portion of the shopping centre can now be re-built whilst the new eastern area is in operation 5.2.28 02 After demolition, Buildings C3, C4, and C5 will be constructed sequentially from south to north 5.2.29 03 Permanent entrances will be built at the north and south ends of the shopping centre, along with the level 02 podium park. 5.2.30 04 The remaining portion of the L01 street can also be completed, opening up the route from the northern square to the eastern terrace.
Figure 5.8 Indicative Phase 3B, Levels 00 and 04 Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 5: Demolition and Construction
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Indicative Programme Overview 5.2.31 Demolition and construction work for the Proposed Development are planned to commence in 2026 on the Site and finished in 2036. The Indicative Development Programme is shown in Figure 5.9.
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Figure 5.9 Indicative Development Programme
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Indicative Timeslices 5.2.32 To provide a robust assessment of the demolition and construction effects within some of the technical Chapters of this ES (Chapters 6 – 16 and Volume 2), 2 No. ‘timeslices’ are presented within this Chapter. These are extracted from a set of graphical ‘snapshots’ of the development at key points in the Indicative Development Programme that aid understanding of the critical works, activities taking place and key interfaces in that period. 5.2.33 At this stage, the number of vehicles has been derived from benchmarking against similar schemes with comparable construction and unit numbers. The estimate is based on the indicative programme described earlier in this ES Chapter. The estimate included here is expected to cover a realistic worst-case scenario, and any future alterations in the programme or scheme would yield an equal or lower number of construction vehicles to satisfy this EIA and related assessments. 5.2.34 Using industry experience regarding capacity of each vehicle for specific materials, the number of vehicle trips for each building was calculated and adjusted for benchmarking against the Proposed Development. Then the totals for each building were averaged over the period of construction for that building. Finally, all building estimates were combined using the proposed indicative programme and phasing to arrive at the maximum average vehicle numbers at any point in the construction programme. With this scale of development and the early stage of design, this is believed to be the most relevant method of presenting estimated construction vehicle numbers. 5.2.35 The timeslices have been chosen for the following reasons: -
Timeslice 1: 2028 – Phase 1a and Phase 1b Overlap: This timeslice is a busy period for construction and demolition, with Phase 1a nearing completion and demolition of Phase 1b commencing. This also represents a high peak in construction vehicles 72 HGV movements per day (144 two-way movements).
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Timeslice 2: Q2 2030 – Occupation of Phase 1a with new residents and construction and demolition across the entire site with 1b, 2a, 2b and 3a.This also represents the highest peak in construction vehicles 168 HGV movements per day (336 two-way movements).
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5.3
Key Principles
5.3.1 Throughout the construction period, security and safety for existing nearby residents and visitors surrounding the Site is of paramount importance. Secure and safe pedestrian and vehicular routes will be maintained at all times. It is envisaged that there will be no disruption to public transport services as a result of the construction activities. 5.3.2 Construction works will be carried out in a manner (to align with the discharge planning conditions) so as to minimise disruption to residents and other sensitive receptors, in particular, the works will not adversely impact on the continuity of utility/heat supply to existing nearby residents. These measures will be implemented through a programme of enabling works prior to demolition works commencing to ensure the necessary utility/heat supply diversion and protection works and temporary supplies are undertaken to maintain continuity of supply. 5.3.3 Close liaison will be maintained between the Applicant, LBL, neighbouring properties and local residents groups throughout the development period.
5.4
Materials and Resources Materials Management
5.4.1 Materials and waste would be managed in accordance with the targets set in the Sustainability Statement for the Proposed Development, submitted with this Application. 5.4.2 The design of the Proposed Development should also maximise the potential to use prefabricated elements, and standard profiles and sections which can be easily assembled and disassembled for reuse elsewhere. Selection 5.4.3 Local material selection and procurement would be explored with the Principal Contractor and would be a sustainability target for the design team. Sustainable procurement tools such as Sedex (Ref. 5.2) would be used to investigate the full sustainability background to materials supplied by subcontractors, for example to understand if they use child labour, renewable energy during production or source from sustainable forests. 5.4.4 Vulnerable areas of the buildings and wider scheme would be identified to ensure impact protection features are incorporated (for example, effects of climate change such as flooding) and durable materials would be specified, to reduce the degradation and use of additional materials over the lifetime of the development. 5.4.5 Materials selection and procurement would also be informed by the increasing availability of healthy certified materials, where feasible, including but not limited to materials and products that:
• Meet testing and emissions standards for low or zero VOC as defined by Building Research Establishment’s Environmental Assessment Method (BREEAM) (Ref. 5.3), Leadership in Energy and Environmental Design (LEED) (Ref. 5.4) and/or WELL (Ref. 5.5); Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 5: Demolition and Construction
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• Meet the toxic materials reduction standards set by the WELL standard; • Are Declare (Ref. 5.6) label certified; • Are Cradle to Cradle (Ref. 5.7) Certified Products. 5.4.6 Mitigation measures to minimise the quantity of materials used and to maximise recycling could include, but not be limited to:
• agreements with material suppliers to reduce the amount of packaging or to participate • •
in a packaging take-back scheme; attention to material quantity requirements to avoid over-ordering and generation of waste materials, including ordering materials that are cut to size, rather than standard sizes; and securing the Proposed Development Site to avoid theft and vandalism.
Key Construction Materials 5.4.7 Key materials are envisaged to include those indicated in Table 5.1. Table 5.1 Key Construction Materials
Construction Material
Use for the Proposed Development
Reinforced Concrete (Cement, aggregate)
Piling, pile caps, superstructure frame, lift cores, stairs, shear walls, base slab and basement liner walls
Steel Reinforcement
Piling, pile caps, superstructure frame, lift cores, stairs, shear walls, base slab and basement liner walls
Secondary Steelwork
Façade masonry supports and windposts, MEP plant supports, riser floor steelwork
Brick / Blockwork
External envelope, some internal walls
Glazing
External envelope
SFS and Timber
Inner leaf of external envelope, formwork, joinery, internal partitions
Plasterboard
Internal partitions, wall linings
Structural Fill
Surrounding and beneath foundations and base slabs
Screed / Blinding
Floor finish screed, blinding beneath substructure
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Bituminous Material
Highway finishes, waterproofing membranes, roof finishes
Storage and Handling 5.4.8 As there is limited storage space on-site, deliveries would generally be ‘just-in time’ to avoid storing large volumes of materials. However, any construction materials that are stored onsite would be protected to minimise damage by vehicles, vandalism, weather or theft. 5.4.9 Oils and hydrocarbons would be stored in designated locations with specific measures to prevent leakage and release of their contents, include the siting of storage areas away from surface water drains, on an impermeable base with an impermeable bund that has no outflow and is of adequate capacity to contain 110 % of the contents. Valves and trigger guns would be protected from vandalism and kept locked up when not in use. Details of appropriate storage and handling measures would be presented within the CEMP. 5.4.10 All liquids and solids of a potentially hazardous nature (e.g. diesel fuel, oils and solvents) would be stored on surfaced areas, with bunding, and within secure areas, in accordance with the Environment Agency’s requirements. Demolition Materials and Waste Management 5.4.11 Table 5.2 provides a summary of the materials likely to be generated as a result of the demolition of the existing buildings, structures, hardstanding, below ground features and foundations on-site. Table 5.2 Demolition Materials and Waste Management
Demolition Material
Comment
Reinforced Concrete (RC)
Where foundations and retaining walls are not re-used, the RC removed would be crushed and used for piling mat, fill or as landscaping material where possible, otherwise removed off site for re-use elsewhere. Reinforcement would be separated and recycled off-site.
Steelwork
Deconstruction would allow for recycling of steelwork, expected to be mainly off-site as the Proposed Development does not generally require structural steelwork.
Brick / Blockwork
Generally crushed for piling mat or landscaping material, but whole bricks / blocks could be re-used on site in landscaping features.
Asbestos Composite Materials
If found in existing buildings, this would be removed in accordance with health and safety legislation, classed as
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hazardous waste and removed to a suitable licenced processing site. General
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Where possible re-use within hard landscaping and play space e.g. façade materials in keeping with Circular Economy principles and Statement.
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5.5
Transport and Construction Logistics
5.5.1 A Construction Logistics Plan has been submitted as part of the Planning Application (Volume 3B) and future updates would be co-ordinated between the Contractor and Transport Consultant in conjunction with LBL Highways and TfL. 5.5.2 Construction vehicles used on the public highway would include large articulated flatbed HGV lorries, high-sided HGVs, rigid fixed axle vehicles, concrete mixers, large tipper trucks, vans and cars. Where possible, loads would be consolidated into the minimum number of deliveries to reduce the vehicle trips associated with the Proposed Development. Vehicle Routing 5.5.3 The logistics plans for each phase will be developed as part of each detailed phase which will be developed by the appointed main contractor. Due to the nature of the existing shopping centre and the existing road network construction access will generally be as follows. Phase 1A 5.5.4 Access & egress to Phase 1A will primarily be from Salisbury Yard which is located just off Lewisham High Street to the North. During construction of Phase 1A woks an egress route will also be required onto Lewisham High Street to the east with vehicles turning left. Phase 1B 5.5.5 Access & egress to Phase 1B will primarily be from Lewisham High Street to the North and Molesworth Street to the West. During early demolition and construction works construction vehicles will enter the site off the existing highway. During construction the logistics strategy will evolve and a pitlane will need to be established on Lewisham High Street and Molesworth Street. 5.5.6 Details for the access / egress strategy on Phase 1B will be developed as part of the detailed works. Phase 2A 5.5.7 Access & egress to Phase 2A will primarily be from Molesworth Street to the West. During early demolition and construction works construction vehicles will enter the site off the existing highway. During construction the logistics strategy will evolve and a pitlane will need to be established on Molesworth Street. 5.5.8 Details for the access / egress strategy on Phase 1B will be developed as part of the detailed works.. Phase 2B (Part 1 & Part 2): 5.5.9 Access & egress to Phase 2B part 1 will primarily be from Molesworth Street to the West. During early demolition and construction works construction vehicles will enter the site off the existing highway. During construction the logistics strategy will evolve and a pitlane may need to be established on Lewisham High Street and Molesworth Street. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 5: Demolition and Construction
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5.5.10 During construction of Phase 2B an egress route will also be required onto Lewisham High Street to the east with vehicles turning left. 5.5.11 Details for the access / egress strategy on Phase 2B will be developed as part of the detailed works. Phase 3A 5.5.12 Access & egress to Phase 3A will primarily be from Lewisham High Street to the East. During early demolition and construction works construction vehicles will enter the site off the existing highway. During construction the logistics strategy will evolve and a pitlane may need to be established on Lewisham High Street. 5.5.13 Details for the access / egress strategy on Phase 3A will be developed as part of the detailed works. Phase 3B: 5.5.14 Access & egress to Phase 3B will primarily be from Molesworth Street to the West. During early demolition and construction works construction vehicles will enter the site off the existing highway. During construction the logistics strategy will evolve and a pitlane may need to be established on Molesworth Street. 5.5.15 Details for the access / egress strategy on Phase 3A will be developed as part of the detailed works.. 5.5.16 The primary routes detailed below identify the optimum route for not only HGVs, but all other vehicle types arriving and leaving the site.
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Figure 5.10 Routes from Greater London to the Proposed Development
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5.6
Site Management Working Hours
5.6.1 Normal working hours permitted by LBL are expected to be in place for the Proposed Development, subject to agreement. LBL’s standard working hours for construction sites are:
• Monday to Friday from 8am to 6pm; • Saturday from 8am to 1pm; and • No working is permitted on Sundays, Bank Holidays and Public Holidays. 5.6.2 To maintain the above working hours, at certain times, the Contractor may require a period of up to one hour before and one hour after normal working hours to start and close down activities (this would not include any works that are likely to be described as ‘excessively noisy works’ in accordance with the LBL guidance). 5.6.3 Specialist construction operations and deliveries may occasionally be carried out outside these core hours for short periods in agreement with LBL and other relevant parties in advance, unless in emergency situations. 5.6.4 Out of Hours working is generally not envisaged for the Development, but if required, would be agreed in consultation with LBL and other relevant parties General Site Management Site Access 5.6.5 A site-specific security strategy would be developed to ensure the construction sites remain secure and protected from threats such as: theft, trespass, sabotage or arson and to maintain public and workforce safety. 5.6.6 Secure robust hoarding would be provided around each Site area and CCTV may be fitted to supplement any security guard presence agreed with the Applicant, LBL and local police.
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Site Housekeeping 5.6.7 A 'clean site' policy would be implemented, and contractors and their subcontractors would be expected to maintain a tidy site. For example, material spills would be cleaned up immediately, dust mitigation measures such as damping down loose earth in dry periods would be carried out, and welfare facilities would be kept in good working order. 5.6.8 Waste would be removed regularly from the site, with food waste removed daily to avoid the risk of infestation by vermin or other pests. Measures such as sealing old drains and voids would also assist in reducing this risk to health. Any poison laid to deal with an infestation would comply with the relevant Health and Safety requirement and eliminate any danger to children, household pets and other wildlife. 5.6.9 Smoking areas would be located away from sensitive receptors. Site Health & Safety 5.6.10 The Principal Contractor would carry out their duties in accordance with the Construction Design and Management Regulations (CDM) (Ref. 5.8). They would ensure that all site personnel have the correct training and qualifications, every site visitor would have a site induction, there would be a programme of toolbox talks for site operatives and the Site would be tidy and well maintained with all safety measures in place. Appropriate Personal Protective Equipment (PPE) would be worn by all operative at all times when on the construction site. 5.6.11 The construction teams would be required to prepare detailed written health and safety plans, specific fire and emergency procedures, risk assessments and method statements for each stage of demolition or phase of construction. 5.6.12 Compliance with all relevant health and safety legislation would be enforced including the most current versions of the following legislation:
• • • • • • • • • • • • • • • • •
Health and Safety at Work Act 1974; Management of Health and Safety at Work Regulations 1999; Control of Asbestos Regulations 2006 (revoked); Air Quality Standards Regulations 2010; The Contaminated Land (England)(Amendment) Regulations 2012; Special Waste Regulations 2001; Confined Spaces Regulations 1997; COSHH (Control of Substances Hazardous to Health) (Amendment) 2004; Lifting Operations and Lifting Equipment Regulations 1998; Manual Handling Operations Regulations 1992; Control of Noise at Work Regulations 2005; Personal Protective Equipment at Work Regulations 2002 (revoked) Temporary arrangements in place for Coronavirus, 2020 for above, England; Provision and Use of Work Equipment Regulations 1998; The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013; Control of Vibrations at Work Regulations 2005; and Work at Height Regulations (Amendment) 2007.
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Typical Construction Plant and Equipment 5.6.13 Consideration has been given to the types of plant that are likely to be used during the demolition and construction works. The plant, machinery and other equipment associated with the demolition and construction process is set out in Table 5.3. A more detailed schedule of plant to be used, along with technical data for noise and vibration monitoring and assessment would be included in the CEMP on appointment of the Principal Contractor.
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360° tracked excavators
✓
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Concrete crushing plant
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Concrete ready-mix lorries Concrete splitters and concrete saws
✓
✓
✓
✓
OUT WORKS ROADWORKS, PUBLIC REALM LANDSCAPING
MEP AND FIT
CLADDING WORKS
SUPERSTRUCTURE
✓
✓
✓
Cranes and hoists Lorries/vans
FOUNDATIONS AND UNDERGROUND STRUCTURES
REMEDIATION
CONSTRUCTION PLANT AND EQUIPMENT
ENABLING WORKS
Table 5.3 Indicative Construction Plant and Equipment
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Scaffolding and hydraulic platforms Cranes and hoists Temporary supports
✓
Mini excavators
✓
High reach demolition rigs
✓
Generators
✓
✓
✓
✓
✓
✓
✓
Cutters, drills and small tools
✓
✓
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Hydraulic benders and cutters
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Floodlights
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Fork lift trucks
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Excavators and breakers
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Water bowsers
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Piling rigs
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Concrete Pumps
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✓
✓ ✓
Mortar Silos
✓
Tarmac laying equipment Tipper lorries
✓
✓
✓
Road Brush /sweepers
✓
✓
✓
✓
✓
✓
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Wheelwashers
✓
✓
✓
✓
✓
✓
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Considerate Constructors Scheme 5.6.14 All Contractors would be required to register the Site under the Considerate Constructors Scheme (Ref. 5.9), and any local requirements, and would provide registration details on appointment. This scheme is a voluntary code of practice that ensures contractors and subcontractors carry out their operations in a safe and considerate manner and with due regard to passing pedestrians, road users, neighbouring properties and other sensitive receptors. 5.6.15 The Code of Considerate Practice describes the basic expectations of registration within the scheme and outlines five key aspirations related to these requirements. The five key aspirations for members are:
• Care about Appearance; • Respect the Community; • Protect the Environment; • Care about Safety; and • Value their workforce. 5.6.16 These expectations, outlined in the Code, include:
• Consulting regularly with people who live in the area and keeping them informed at every stage of the process;
• Careful consideration to be given to the impact of construction on neighbours and the • • • • •
public, including in relation to parking, deliveries and works on the public highway; Promoting respectable and safe standards of behaviour and dress from the workforce; Enhancing and properly maintaining the appearance of the site to give a positive impression of the construction industry; Minimising the impact of vibration, and air, light and noise pollution and reducing waste; Embedding attitudes and behaviours that enhance safety performance and protect the public and workforce; and Providing and maintaining high standards of welfare for the workforce, and caring for their health and wellbeing.
Construction Employment Opportunities 5.6.17 The Applicant is committed to producing a ‘Training and Employment Strategy’ that would outline their approach to enabling local people to access future job opportunities, including a jobs brokerage service. They would continue their ongoing community investment strategy to support local people to develop their skills and enterprise and have already committed funds to such initiatives. 5.6.18 The Contractor would help develop schemes for construction-related employment, training, education and procurement for local residents and businesses,
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5.7
References
Ref. 5.1 London Borough of Lewisham, Undated. GOOD PRACTICE GUIDE: Control of pollution and noise from demolition and construction sites, London Borough of Lewisham. Ref. 5.2 http://www.sedex.com (Accessed September 2024) Ref. 5.3 BRE, Building Research Establishment’s Environmental Assessment Method, http://www.breeam.com (Accessed September 2024) Ref. 5.4 U.S. Green Building Council, Leadership in Energy and Environmental Design, https://www.usgbc.org/ (Accessed September 2024) Ref. 5.5 International WELL Building Institute, IWBI, https://www.wellcertified.com/ (Accessed September 2024) Ref. 5.6 International Living Future Institute, Declare, https://declare.living-future.org/ (Accessed September 2024) Ref. 5.7 Cradle to Cradle Products Innovation Institute, Cradle to Cradle Certified Products Program, https://www.c2ccertified.org/ (Accessed September 2024) Ref. 5.8 Health and Safety Executive, 2015. Construction (Design and Management) Regulations 2015, HSE. Ref. 5.9 Considerate Constructors Scheme. https://www.ccscheme.org.uk/ (Accessed September 2024)
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6.0 Noise and Vibration 6.1
Introduction
6.1.1 This Chapter reports the likely significant effects of the Proposed Development on the Site and the surrounding area in terms of Noise and Vibration matters. Where appropriate, it also identifies proposed mitigation measures to prevent, minimise or control likely negative effects arising from the Proposed Development and the subsequent anticipated residual effects. 6.1.2 The effects of the Proposed Development are considered over both the demolition & construction and operational phases. 6.1.3 The main Noise and Vibration issues covered in this Chapter include the following: •
•
•
Noise and vibration from demolition and construction activity, including from construction traffic. The assessment has been undertaken to both existing noise sensitive receptors, and also considers the effect of noise and vibration from demolition and construction on early occupied phases of the Proposed Development itself. An assessment of the Site’s suitability for residential development with regards to noise. Consideration has been given to the need to achieve suitable internal sound levels within dwellings and the impact of environmental noise on external amenity areas. Noise effects during the operational phase of the Proposed Development, including changes in noise associated with road traffic from the Proposed Development, noise emissions from the introduction of new building services plant and operational activity noise from within the Proposed Development.
6.1.4 This Chapter (and its associated figures and appendices) should be read together with the Introductory Chapters of this ES (Chapters 1 – 5), as well as Chapter 17: Effect Interactions. 6.1.5 This Chapter is accompanied by the following appendices: •
Appendix 6.1 – Noise and vibration technical appendix
Competence 6.1.6 This assessment has been undertaken by Matt Brown, an Associate Engineer at Hoare Lea with 12 years continuous experience in acoustic consultancy. 6.1.7 Matt holds a MSc in Environmental and Architectural Acoustics from London South Bank University, is a full Member of the Institute of Acoustics (MIoA) and has significant past experience of preparing Noise and Vibration chapters for Environmental Statements across multiple sectors, including residential, workplace, town centre redevelopment, film studio and mission critical buildings.
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6.2
Legislation, Planning Policy and Guidance
6.2.1 The following national, regional and local planning policy and guidance is of relevance to the assessment of the effects of the Proposed Development in relation to Noise and Vibration.
Planning Policy Context Legislation 6.2.2 In England, there are two legislative instruments which address environmental noise and vibration nuisance from construction activities. The Environmental Protection Act 1990Ref 6.1 (EPA) and the Control of Pollution Act 1974 Ref 6.2 (CoPA). 6.2.3 The EPA provides powers to control noise where a statutory noise nuisance exists. Section 80 describes the powers of the Local Authority to serve a notice requiring the abatement of a nuisance or prohibition of its occurrence/reoccurrence. Section 82 gives individuals subject to a statutory nuisance the right to make representations to the courts and for the courts to take action against the originator of that nuisance such that it is abated. 6.2.4 The CoPA provides two means of controlling construction noise and vibration. Section 60 provides Local Authorities with the power to impose operating conditions on a construction site at any time for the purpose of minimising noise. Section 61 allows the developer to negotiate a set of operating procedures for the Local Authority prior to commencement of site works. 6.2.5 The Noise at Work Regulations 2005Ref 6.3 provides legal limits for noise exposure to employees. It sets thresholds at which employers need to undertake workplace noise risk assessments and provide training, a further threshold at which employers must provide mandatory hearing protection, and a limiting noise exposure value not to be exceeded on a daily, or weekly, basis. National 6.2.6 The following national level policy and guidance documents are of relevance to the Proposed Development: National Planning Policy Framework (2023) 6.2.7 The National Planning Policy FrameworkRef 6.4 (NPPF) sets out the Government’s planning policies for England and how they are expected to be applied. Paragraph 180 of the NPPF states that: “Planning policies and decisions should contribute to and enhance the natural and local environment by […] e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability”.
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6.2.8 Paragraph 185 of the NPPF states: “Planning policies & decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development. In doing so they should: a) mitigate and reduce to a minimum potential adverse impacts resulting from noise from new development – and avoid noise giving rise to significant adverse impacts on health and the quality of life; b) identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason” Noise Policy Statement for England (NPSfE) (2010) 6.2.9 The Noise Policy Statement for EnglandRef 6.5 (NPSE) advises that noise impacts should be assessed on the basis of adverse and significant adverse effect. The NPSE does not provide any specific guidance on assessment methods or noise limits. However, the concepts summarised in Table 6.1 are introduced and can be applied when considering the significance of noise impacts. Table 6.1: Observed effect levels from NPSfE Effect level
Description
No Observed Effect Level (NOEL)
The noise level below which no effect can be detected. Below this level of noise, there is no detectable effect on health and quality of life due to the noise being assessed.
Lowest observed adverse effect level (LOAEL)
This is the level of noise above which adverse effects on health and quality of life can be detected.
Significant observed adverse effect level (SOAEL)
This is the level of noise above which significant adverse effects on health and quality of life occur.
Planning Practice Guidance (NPPG) (2019) 6.2.10 Online Planning Practice Guidance Ref 6.6 (PPG) has been published to provide greater details in relation to the relevance of noise to the planning process following the introduction of the NPPF and NPSE. 6.2.11 PPG explains that “where noise is not perceived to be noticeable, there is by definition no effect”. As noise exposure increases, a point will be reached where it becomes noticeable. PPG sets out a hierarchy of noise exposure which relates example responses back to the effect levels set out within the NPSE, which is reproduced overleaf. 6.2.12 As with the NPSE, PPG does not provide any specific guidance on numeric limits or specific noise parameters. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
Plowman Craven 46730 October 2024
6.2.13 It is explained that there is no simple relationship between noise levels and the impact on those affected, and that the impact could be affected by other factors such as: • • • • •
The source and absolute level of the noise, together with the time of day that noise is occurring, For a new noise source, how the noise from it relates to the existing sound environment, For non-continuous sources of noise, the number of noise events and the frequency and pattern of occurrence of the noise, The spectral content of the noise (i.e. whether the noise contains particular tonal characteristics or other features), Cumulative impacts of more than one noise source.
6.2.14 PPG also sets out that there are several approaches that can be taken to mitigate noise; whether through engineering methods to reduce noise at source, optimising layouts to reduce noise effects, securing mitigation with planning conditions, or the introduction of physical mitigation to reduce noise (e.g. building envelope design, acoustic screens). Table 6.2: Example responses to increased noise effect Perception
Examples of outcomes
Increasing effect level
Action
No specific measures required
No observed effect level (NOEL) Not noticeable
No Effect
No observed effect
Noticeable and not intrusive
Noise can be heard but does not cause any change in behaviour or attitude. Can slightly affect the acoustic character of the area but not such that there is a perceived change in the quality of life.
No observed adverse effect
Lowest observed adverse effect level (LOAEL) Noticeable and intrusive
Noise can be heard and causes small changes in behaviour and/or attitude, e.g. turning up volume of television; speaking more loudly; closing windows for some of the time because of the noise. Potential for non-awakening sleep disturbance. Affects the acoustic character of the area such that there is a perceived change in the quality of life.
Observed adverse effect
Mitigate and reduce to a minimum
Significant observed adverse effect
Avoid
Significant observed adverse effect level (SOAEL) Noticeable and disruptive
The noise causes a material change in behaviour and/or attitude, e.g. having to keep windows closed most of the time, avoiding certain activities during periods
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
Plowman Craven 46730 October 2024
of intrusion. Potential for sleep disturbance resulting in difficulty in getting to sleep, premature awakening and difficulty in getting back to sleep. Quality of life diminished due to change in acoustic character of the area. Noticeable and disruptive
Extensive and regular changes in behaviour and/or inability to mitigate effect of noise leading to psychological stress or physiological effects, e.g. regular sleep deprivation/awakening; loss of appetite, significant, medically definable harm, e.g. auditory and non-auditory.
Unacceptable adverse effect
Prevent
Regional London Plan 2021 6.2.15 The London PlanRef 6.7 sets out an overall strategic plan for London for the development of the capital over the next 20 to 25 years. 6.2.16 The plan brings together the Mayor’s strategies, including policy on a range of environmental issues, such as climate change, air quality, noise and waste. London Boroughs’ local plans need to be in general conformity with the London Plan, and its policies guide decisions on planning applications by councils and the Mayor. 6.2.17 The current version of the London Plan was adopted in March 2021. Policy D13 relates to noise, stating: “In order to reduce, manage and mitigate noise to improve health and quality of life, residential and other non-aviation development proposals should seek to manage noise by: 1. Avoiding significant adverse noise impacts on health and quality of life; 2. Reflecting the Agent of Change principle as set out in Policy D13 Agent of Change 3. Mitigating and minimising the existing and potential adverse impacts of noise on, from, within, as a result of, or in the vicinity of new development without placing unreasonable restrictions on existing noise-generating uses; 4. Improving and enhancing the acoustic environment and promoting appropriate soundscapes (including Quiet Areas and spaces of relative tranquillity); 5. Separating new noise sensitive development from major noise sources (such as road, rail, air transport and some types of industrial development) through the use of distance, screening or internal layout - in preference to sole reliance on sound insulation; 6. Where it is not possible to achieve separation of noise sensitive development and noise sources, without undue impact on other sustainable development objectives, then any potential adverse effects should be controlled and mitigated through the application of good acoustic design principles; 7. Promoting new technologies and improved practices to reduce noise at source, and on the transmission path from source to receiver.”
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
Plowman Craven 46730 October 2024
6.2.18 Item 2 refers to Policy D13 Agent of Change. This places the onus for mitigating noise and vibration from existing business uses on the new development, in order to protect the existing uses against potential noise complaints which could otherwise affect their business. Sustainable Design and Construction Supplementary Planning Guidance (2014) 6.2.19 Section 4.4. of the Sustainable Design and Construction Supplementary Planning Guidance Ref 6.8 document provides guidance on design in relation to the control of noise and vibration. It reinforces the National and Regional policy documents already described above, and provides practical examples of physical noise control measures, management protocols and good-practice measures to design out noise at source. Local London Borough of Lewisham: Core Strategy (2011) Lewisham Site Allocations Plan (2013); Lewisham Development Management Local Plan (2014) Lewisham Town Centre Local Plan (2014) Draft Lewisham Local Plan (Regulation 18 stage) (2021) 6.2.20 London Borough of Lewisham (LBL)’s local policy is set out within the Core Strategy Ref 6.9 document and shapes the strategic direction of the borough between 2011-2026. 6.2.21 Although little reference is made to noise, the document does recognise the need to address climate change through promoting a low-carbon borough, and recognises that one way this can be done is through minimising the environmental impacts of development including water, noise and air pollution. 6.2.22 Whilst the Site Allocations PlanRef6.10 does not provide any guidance specific to the Lewisham Shopping Centre Site, it does recognise the need to consider noise impacts as part of the sustainability appraisal for a Proposed Development. 6.2.23 Policy DM 26 of the Lewisham Development Management Local PlanRef 6.11 is specific to noise and vibration and aims to minimise the impacts of excessive noise and vibration on human health and wellbeing. Policy DM26 states: “The Council will require: a) Noise and/or vibration generating development or equipment to be located in the Strategic Industrial Locations (SILs) and Local Employment Locations (LELs) as shown on the Local Plan Policies map b) New noise sensitive developments are to be located away from existing or planned sources of noise pollution, except if it can be demonstrated through design or mitigation that i) internal and external noise levels can be satisfactorily controlled and managed by the noise sensitive development and, ii) there will be no adverse impact on the continued operation of any existing or proposed business or operation Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
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c) a noise and vibration assessment for noise and/or vibration generating development or equipment and new noise sensitive development, where appropriate, to identify issues and attenuation measures, prepared by a qualified acoustician. Where development is permitted, conditions may be attached to the planning permission to ensure effective noise insulation or other mitigation measures are undertaken”. 6.2.24 Several other policies relating to particular types of development (e.g. Food and Beverage units, Minicab ranks etc) seek to ensure that there are no detrimental effects to amenities of adjoining properties caused by noise disturbance. 6.2.25 The Lewisham Town Centre Local Plan Ref6.12 recognises that noise within the town centre poses a challenge and recognises the need to address noise in the design of a new development, but does not define a specific policy or provide further guidance. 6.2.26 Finally, the Draft Lewisham Local Plan shapes the future of the borough beyond the expiry of the current Local Plan. The Regulation 18 summary Ref 6.13 states that new development should provide a high standard of amenity, which prevents or mitigates the impacts of noise and vibration. 6.2.27 Draft policy QD8 is specific to noise and vibration. QD8 states: “A. Development proposals should be designed to avoid or minimise the harmful impacts of noise and vibration at all stages of the development, having regard to the Agent of Change principle. B. New noise and vibration generating development must be appropriately located away from noise sensitive uses and suitably demonstrate that measures will be implemented to mitigate any adverse impacts. C. New noise sensitive development should be located away from existing or planned sources of noise pollution. Where this is not reasonably practical proposals must demonstrate that: a). Internal and external noise levels can be satisfactorily controlled and managed; and b). There will be no adverse impact on the continued operation and amenity of adjoining and neighbouring uses, having regard to Policy QD7 (Amenity and agent of change) D. A Noise Assessment and/or Vibration Assessment will be required to be submitted with proposals where they are noise sensitive developments or involve a noise or vibration generating use.” 6.2.28 Whilst largely similar to policy DM 26 in terms of strategy, there are some key differences. The new policy introduces the ‘Agent of Change’ principle, which aligns with the latest version of NPPF, which was introduced after the adoption of the current Local Plan. This aligns with the London Plan. 6.2.29 The new policy QD8 also removes the specific need for new noise generating development to be located within the allocated SIL or LEL areas. There is still a requirement to minimise the impact of noise generating development on noise sensitive uses under bullet B. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
Plowman Craven 46730 October 2024
Guidance British Standard (BS) 5228 Parts 1 and 2 (2009 + A1 2014) 6.2.30 British Standard 5228 ‘Code of practice for noise and vibration control on construction and open sites’ provides guidance on a range of considerations relating to construction noise including the legislative framework, general control measures, example methods for estimating construction noise levels and example criteria which may be considered when assessing the significance of any effects. 6.2.31 BS 5228-1Ref 6.14 relates to construction noise, whilst BS 5228-2 Ref 6.15 relates to construction vibration. 6.2.32 Further information on the control of noise from demolition and construction specifically within Lewisham is available in the LBL document ‘Good Practice Guide: Control of pollution and noise from demolition and construction sites’ Ref 6.16. This document advises on limits on working hours and advises of good practice noise control measures, including the use of localised screening and calling up the need for noise monitoring throughout construction. BS 6472-1 (2008) 6.2.33 BS 6472-1Ref 6.17 ‘Guide to Evaluation of Human Exposure to Vibration in Buildings, Part 1: Vibration Sources Other Than Blasting’ presents recommended frequency weighted vibration spectra for continuous vibration, and vibration dose values (VDV) for intermittent vibration, above which negative comment is likely to occur in residential properties. BS 8233 (2014) 6.2.34 BS 8233Ref 6.18 ‘Guidance on sound insulation and noise reduction for buildings’ provides criteria for the assessment of internal sound levels for various types of development and building uses. BS 8233 Table 4 provides desirable internal ambient sound levels for spaces in residential dwellings when they are unoccupied; reproduced below in Table 6.3. Table 6.3: Indoor ambient sound levels in dwellings Activity
Location
Day (07:00 to 23:00)
Night (23:00 to 07:00)
Resting
Living room
35 dB LAeq, 16hour
-
Dining
Dining room / area
40 dB LAeq, 16hour
-
Sleeping (daytime resting)
Bedroom
35 dB LAeq, 16hour
30 dB LAeq, 8hour
6.2.35 A number of supporting notes to the table are provided; with key notes reproduced below: NOTE 2 - the levels shown in Table 4 are based on the existing guidelines issued by the WHO…
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
Plowman Craven 46730 October 2024
NOTE 4 - regular individual noise events (for example, schedule aircraft or passing trains) can cause sleep disturbance. A guideline value may be set in terms of SEL or LAmax,T depending on the character and number of events per night. NOTE 7 – Where development is considered necessary or desirable, despite external noise levels above WHO guidelines, the internal target levels may be relaxed by up to 5 dB and reasonable conditions still achieved”. 6.2.36 BS 8233 also provides guidance on external sound levels within amenity spaces. The standard advises that, for traditional external amenity spaces such as gardens or patios, it is desirable that external noise levels do not exceed 50 dB LAeq,16hr, with an upper guideline value of 55 dB LAeq,16hr . 6.2.37 These noise levels are derived from the World Health Organization “Guidelines for community noise” Ref 6.19 (1999). BS 8233 recognises that these guideline levels are not achievable in all circumstances where development may be desirable. Clause 7.7.3.2 states: “[…]it is also recognized that these guideline values are not achievable in all circumstances where development might be desirable. In higher noise areas, such as city centres or urban areas adjoining the strategic transport network, a compromise between elevated noise levels and other factors, such as the convenience of living in these locations or making efficient use of land resources to ensure development needs can be met, might be warranted. In such a situation, development should be designed to achieve the lowest practicable levels in these external amenity spaces, but should not be prohibited” 6.2.38 For small private balconies in apartment blocks, which may only be used for activities such as drying washing or growing pot plants, BS 8233 advises that the setting of noise limits is not necessarily appropriate. 6.2.39 The standard also provides guidance on typical sound reductions that can be achieved for certain building elements. BS 8233 states that a conventional façade with double glazed windows is advised as providing a level of sound reduction from outside to inside of typically 35 dB Rw. BS 4142 (2014 + A1 2019) 6.2.40 BS 4142 Ref6.20 ‘Methods for rating and assessing industrial and commercial sound’ describes an objective method for the assessment of sound from commercial activities; including noise emissions from fixed building services plant. 6.2.41 The standard is based upon the evaluation of a ‘rating level’ of sound from a new source experienced at a noise sensitive receiver. The rating level is assessed against the prevailing background sound levels at the same receiver. Where the sound displays a particular acoustic characteristic, such as tonality, the sound rating attracts a penalty. The size of the penalty is relative to the significance of the acoustic feature. 6.2.42 The general principle is that the lower the rating level relative to the existing background sound, the less likely that the new sound source will have an adverse effect on the noise sensitive receiver. The standard states that: •
A difference of around +10 dB or more is likely to be an indication of a significant adverse effect, depending upon the context,
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
Plowman Craven 46730 October 2024
• •
A difference of around +5 dB is likely to be an indication of an adverse impact, depending on the context, Where the rating level does not exceed the background sound level, this is an indication of the specific sound source having a low impact, depending on the context.
6.2.43 It is noted within the standard that not all adverse impacts will lead to complaint, and equally that not every complaint is proof of an adverse impact. 6.2.44 A working group as part of the Association of Noise Consultants (ANC) prepared a technical note in March 2020Ref 6.21 which provides further guidance on the application of BS 4142. The technical note highlights that the numerical outcome (shown above) only represents the initial estimate of impact, and that to determine what the potential impact is, contextual matters should be considered. World Health Organisation Guidelines (various) 6.2.45 The WHO has published a series of guidelines that relate to acceptable levels of noise from a health perspective. These are detailed in three separate documents: the Guidelines for Community Noise (1999)Ref 6.19 ; the Night Noise Guidelines for Europe’ (2009) Ref 6.22 ; and the Environmental Noise Guidelines for the European Region (2018) Ref 6.23. 6.2.46 The Guidelines for Community Noise provides guidance on internal sound levels within dwellings and external amenity space that could result in adverse health effects; ranging from sleep disturbance to annoyance. These sound levels formed the basis of the recommendations made within BS 8233 as described above. 6.2.47 The Night Noise Guidelines for Europe provide further criteria that relate external noise levels at dwellings to specific health effects. These criteria were produced with the intention of supplementing the criteria that were given in the ‘Guidelines for Community Noise’. 6.2.48 The Night Noise Guidelines are, however, set in terms of the Lnight, outside, which is the average night time noise level experienced outside the building over a year. It does not take into account mitigation measures that may be designed into the building envelope and requires knowledge of the noise levels experienced at the development site over the course of a full year. As such, the Lnight, outside measurement descriptor is not appropriate for assessing the acceptability of noise affecting the Proposed Development and will therefore not be considered further in this assessment. 6.2.49 Although the Environmental Noise Guidelines for the European Region supersede the Guidelines for Community Noise, they do not provide recommendations for indoor noise levels. Therefore, the indoor sound values in the Guidelines for Community Noise are still valid.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
Plowman Craven 46730 October 2024
ProPG Professional Practice Guidance on Planning and Noise (2017) 6.2.50 ProPG Planning & Noise Ref6.24 is a document aimed at providing practitioners with guidance on a recommended approach to the management of noise in the context of the planning system. The document was published jointly by the three professional bodies in the acoustics industry: Acoustics and Noise Consultants (ANC); the Institute of Acoustics (IOA); and the Chartered Institute of Environmental Health (CIEH). 6.2.51 The guide is focussed on new residential development being affected by transport noise. Its primary goal is to assist in the delivery of sustainable development by promoting good health and wellbeing through the effective management of noise. It seeks to do this by encouraging good acoustic design processes in and around proposed new residential development, having particular regard to national policy on planning and noise. 6.2.52 One consideration of the ProPG is that of access to space providing some respite from noise during those times when homes may be noise affected. This may include at least one façade of a home being exposed to lower noise levels, thus allowing windows to be opened on that façade for ventilation purposes in situations where occupants may choose to close windows on a more noise exposed façade. Similarly, where external amenity directly associated with a property is noise affected, easy access to external amenity space on an acoustically screened side of the property, or indeed to nearby public open space where the noise levels are lower, may both reasonably be considered as contributory mitigating factors. Approved Document O – Overheating (2022) 6.2.53 Approved Document ORef6.6.25 (ADO) ‘Overheating’ was adopted in June 2022 and sets out requirements under the Building Regulations to control heat build up in residential dwellings. ADO lists Lewisham (postcode SE13) as an area subject to a high risk of overheating. 6.2.54 Section 3 provides expectations with regard to noise, stating that “windows are likely to be closed during sleeping hours” when noise exceeds an internal sound level of 40 dB LAeq,8hr between 23:00 and 07:00, or 55 dB LAFmax more than 10 times per night. 6.2.55 Draft guidance published by the ANC in July 2022 ‘Guide to demonstrating compliance with the noise requirements of Approved Document O’Ref 6.26, advises a reduction of 4 dB for an open window in areas subject to a ‘high’ overheating risk. It is noted that this value is empirically derived, based upon the ‘open area’ requirements to satisfy the overheating criteria within Approved Document O. The level of sound reduction does not represent what might be provided by a real window where the degree of opening may be constrained by a number of different factors including the basic size of the window, opening style, and safety restrictors. In assessing the acoustic implications of relying upon opening of windows for relief of overheating, consideration will be given to such practicalities, where known, to estimate the order of sound reduction that may be offered from outside to inside.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
Plowman Craven 46730 October 2024
Acoustics, Ventilation and Overheating: Residential Design Guide (2020) 6.2.56 The ‘Acoustics Ventilation and Overheating: Residential Design Guide’ Ref 6.27 (AVOG) was published in January 2020 by the ANC and IOA. It recommends an approach to acoustic assessments for residential development that takes due regard of the interdependence of provisions for acoustics, ventilation and overheating. 6.2.57 The document sets out a two-tiered approach to assess the risk of overheating for a proposed residential development site, based on a number of ‘risk categories’, ranging from negligible to high. The Level 1 assessment considers the external noise levels experienced by a proposed development, while the Level 2 assessment based on the resultant internal noise level. Unlike ADO, AVOG provides guidance for both day and night periods. Calculation of Road Traffic Noise (1998) 6.2.58 In the UK, the Calculation of Road Traffic Noise Ref 6.28 (CRTN) document provides the standard method for predicting noise from road traffic. Predictions are made using input parameters, such as traffic flow, composition, speed and type of road, and distance of the receptor from the road. This method enables the calculation of average noise levels over a period of either 18 hours or 1 hour, presented in terms of the parameter LA10. Design Manual for Roads & Bridges (1993) LA111 (2020) 6.2.59 The Design Manual for Roads and Bridges Ref 6.29 (DMRB) was originally published by the Department of Transport in 1993 and sets out procedures for undertaking the design of highways schemes. 6.2.60 LA111 Noise and Vibration sets out a methodology for assessing the impacts of noise and vibration. This volume was last updated in May 2020 (Rev 2). Table 3.54a within LA111 provides guidance on the magnitude of short-term road traffic noise impacts, which are reproduced in Table 6.4. Table 6.4: Classification of magnitude of short-term road traffic noise impacts Change in noise, dB LA10, 18hour or Lnight
Magnitude of Impact
Less than 1.0
Negligible
1.0 – 2.9
Minor
3.0 – 4.9
Moderate
Greater than or equal to 5.0
Major
Common Noise Assessment Methods in Europe (2012) 6.2.61 The Common Noise assessment methods in Europe Ref 6.30 (CNOSSOS-EU) document provides an empirically derived methodology to quantify the sound power levels of different vehicle categories (Category 1 is used for passenger cars. Heavy Goods Vehicles (HGVs) are referred to as Category 3). Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
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6.2.62 The methodology was initially derived to assist with strategic noise mapping in accordance with the Environmental Noise Directive 2002/49/ECRef 6.31 (END). It provides a means of quantifying sound levels for individual vehicle passes in instances where traffic flows are too low to be assessed in accordance with CRTN. IEMA Guidelines for Environmental Noise Impact Assessment (2014) 6.2.63 The Guidelines for Environmental Noise Impact Assessment Ref6.32 published by the Institute for Environmental Management and Assessment (IEMA) provide guidance on all aspects of environmental noise impact assessment. 6.2.64 The guidance advises that, for broadband sounds that are similar in all but magnitude, a change in noise level of 1 dB may be just perceptible under laboratory conditions, whilst a change of 3 dB is just perceptible under most normal conditions.
6.3
Consultation
6.3.1 As discussed in Chapter 2: Approach to Assessment, consideration has been given to the formal EIA Scoping Opinion provided by LBL and consultees and any additional consultation that may have occurred during the design period of the Proposed Development. Table 6.5: Consultation Feedback Consultee
Comment
Where is this addressed?
LBL EIA Scoping Opinion
“The applicant should ensure that an updated survey is undertaken for the application as the current ones were undertaken in 2021”
An updated survey has been undertaken and is described in paragraphs 6.4.6 - 6.4.10 and section 6.6.
LBL EIA Scoping Opinion
“The Scoping Report acknowledges that receptors away could also be affected. With regard to the closest receptors, the Scoping Report states that ‘control of noise at these receptors will therefore inherently protect sensitive receptors located at greater distances from the Site’ which is reasonable. The Scoping Report notes that receptors R6 and R7 may be occupied during construction Phase 1 and this will be considered within the ES. It is recommended that the ES also considers the construction noise and vibration impacts on early phase residential from later phase construction”.
The assessment has been undertaken in line with the Scoping Opinion (i.e. focussing on the nearest receptors, rather than an exhaustive list of all receptors nearby).
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
Due to changes in phasing, receptors R6 and R7 are now considered throughout the entirety of the construction assessment. A new receptor, R11, has been introduced to represent occupied early phase residential dwellings during later phase construction.
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6.4
Assessment Methodology and Significance Criteria
6.4.1 The following section outlines the methodologies applied to identify and assess the potential impacts and likely effects to result from the Proposed Development. Scope of the Assessment 6.4.2 An EIA Scoping Report was issued to LBL in January 2024 (Appendix 2.1). LBL’s formal Scoping Opinion was issued in June 2024 (Appendix 2.2). 6.4.3 The following potential effects were scoped into the assessment: • •
Noise and vibration effects during the demolition and construction phase Noise effects from the operation of the Proposed Development
Potential Significant Effects Demolition and Construction Phase • • •
Noise associated with demolition and construction activity Vibration associated with demolition and construction activity Noise from construction related traffic
Operational Phase • • •
Changes in noise attributable to road traffic from the Proposed Development Noise from building services plant associated Noise from operational activities within the Proposed Development.
Extent of The Study Area 6.4.4 The geographic extent of the Noise and Vibration assessment extends to include the nearest noise sensitive receptors, which are identified in section 6.8. These are generally located within 100 m of the boundary of the Proposed Development. 6.4.5 Whilst it is recognised that there may be additional noise sensitive receptors, those listed in section 6.8 are considered to be the most exposed to potential noise from the Proposed Development. Control of noise to these receptors will therefore inherently protect sensitive receptors located at greater distances from the Site. This has been acknowledged and accepted in LBL’s Scoping Response. Method of Baseline Collection 6.4.6 The baseline has been defined through environmental sound surveys undertaken in 2024 at various locations around the Site and representative of the acoustic environment experienced by nearby receptors which are considered sensitive to noise. 6.4.7 Long term monitoring was undertaken at four fixed, unmanned positions between 11th April 2024 and 8th May 2024. The purpose of these measurements was to establish the underlying background sound levels around the site, and to understand the diurnal sound variation.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
Plowman Craven 46730 October 2024
6.4.8 The measurements comprised contiguous fifteen-minute measurements of ambient sound level (LAeq,15min) and background sound levels (LA90,15min). Finer resolution data was also captured (100 ms duration) to define maximum noise events (Lmax) where relevant. 6.4.9 The long term measurement data has been supplemented with several short-term attended measurements at various positions around the Site. These measurements were intended to understand the variation in sound in finer detail around the Site and to obtain sound spectrum information. 6.4.10 Key measurement results relevant to the Noise and Vibration assessment are summarised in section 6.6. Full details of the baseline survey are provided in technical appendix 6.1. 6.4.11 Specifically in relation to the assessment of potential changes in road traffic noise, the baseline is informed by baseline traffic flow data provided by the project Transport Consultant (SLR) for the baseline year of 2023. Method of Assessment Demolition & Construction Phase Noise from demolition and construction activity 6.4.12 The analysis of likely construction noise has been undertaken in accordance with BS 5228-1 which provides methods for predicting construction noise levels based on reference data for noise emissions of typical construction plant and activities. 6.4.13 The standard also indicates a number of factors that are likely to affect the acceptability of construction noise including site location, the existing ambient sound levels, duration of site operations, hours of work, attitude of the site operator and noise characteristics of the work being undertaken. 6.4.14 Full details of the exact construction methods, plant and programme are not available at this stage of the development proposals. The construction noise impact assessment considers typical activities based upon previous experience of developments of similar type and scale. 6.4.15 Table 6.5 sets out the assumed construction stages that would take place on Site and the associated sound pressure levels for typical activities during these work stages. Assumptions have been made, based upon previous experience of similar types and scales of development in terms of what plant items will be in operation and the percentage of time the relevant plant will be in use across a typical 10-hour construction period. However, it should be noted that these are illustrative to enable outline assessments to be made and will need to be confirmed at the appropriate time once a Principal Contractor has been appointed. 6.4.16 Noise from each type of construction activity has been predicted at the nearby noise sensitive receptors. The predictions account for sound attenuation due to distance between the source and receiver, as well as any screening effects attributable to areas of solid construction hoarding around the perimeter of the Site where applicable. 6.4.17 Regarding distance attenuation, a reasonable ‘worst-case’ distance has been assumed during each work stage between the receptor and the closest part of an individual plot within the masterplan. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
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6.4.18 Regarding screening, BS 5228 advises that a barrier reduction of 5 dB can be considered when the top of the construction plant is ‘just visible’ to the receptor over the noise barrier, and a 10 dB reduction can be assumed when the barrier completely breaks the line of sight between the source and receptor. 6.4.19 The assessment assumes minimal embedded mitigation beyond standard construction noise control. However, for some particularly noisy activities such as concrete breaking or cutting paving slabs, it has been assumed that localised acoustic screening will be erected to fully break the line of sight between source and receptor. This is fairly conventional good practice and will be included within any future Construction Environmental Management Plan (CEMP). 6.4.20 No specific consideration has been given to construction noise associated with the internal fit-out of the building on the basis that, once the cladding has been installed, the building envelope itself will provide sufficient reduction of noise that significant effects would be avoided. Table 6.5: Assumed construction stage activity sound pressure levels (dB L Aeq,T at 10m)
Work stage
Demolition / Enabling works
Foundations & Substructure
Plant equipment assumed to be in operation
BS 5228-1 reference
Sound pressure level at 10 m, dB LAeq,T
Assumed ‘on-time’ %
Wheeled mobile crane
Table C4 Ref. 43
70
50%
Dozer
Table C2 Ref. 12
81
50%
Tracked excavator
Table C2 Ref. 14
79
75%
Articulated dump truck (tipping fill)
Table C2 Ref. 32
74
50%
Small / Medium dump truck
Table C4 Ref. 5
63
50%
Water bowsers (discharging)
Table C6 Ref. 37
81
50%
Concrete breakers
Table D7 Ref. 64
90
50%
Scaffolding
Table D7 Ref. 1
80
50%
Small tracked excavators
Table C4 Ref. 67
74
50%
Backhoe mounted hydraulic breaker
Table C5 Ref. 1
88
50%
CFA Piling
Table C3 Ref. 21
79
75%
Concrete mixing and pumping
Table C4 Ref. 32
78
75%
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Work stage
Superstructure, cladding and roofing
External hard landscaping
Plant equipment assumed to be in operation
BS 5228-1 reference
Sound pressure level at 10 m, dB LAeq,T
Assumed ‘on-time’ %
Concrete poker
Table C4 Ref. 33
78
50%
Concrete breakers
Table D7 Ref. 64
90
50%
Tracked excavator
Table C2 Ref. 14
79
50%
Small tracked excavators
Table C4 Ref. 67
74
50%
Wheeled mobile crane
Table C4 Ref. 43
70
50%
Water bowsers
Table C6 Ref. 37
81
50%
Backhoe mounted hydraulic breaker
Table C5 Ref. 1
88
50%
Scaffolding
Table D7 Ref. 1
80
50%
Wheeled mobile crane
Table C4 Ref. 43
70
50%
Concrete breakers
Table D7 Ref. 64
90
50%
Cutting and welding
Table C3 Ref. 31
73
50%
MEWPs
Table C4 Ref. 57
67
50%
Tower crane
Table C4 Ref. 48
76
50%
Concrete mixing and pumping
Table C4 Ref. 32
78
50%
Water bowsers
Table C6 Ref. 37
81
50%
Backhoe mounted hydraulic breaker
Table C5 Ref. 1
88
50%
Concrete breakers
Table D7 Ref. 64
90
50%
Road roller
Table D3 Ref. 114
80
75%
Cutting paving slabs
Table C4 Ref. 73
84
75%
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Work stage
Miscellaneous / All stages
Plant equipment assumed to be in operation
BS 5228-1 reference
Sound pressure level at 10 m, dB LAeq,T
Assumed ‘on-time’ %
Tracked excavator
Table C2 Ref. 14
79
50%
Wheeled mobile crane
Table C4 Ref. 43
70
50%
Concrete mixing and pumping
Table C4 Ref. 32
78
50%
Vibratory roller
Table C5 Ref. 20
75
75%
Asphalt Paver + Tipper lorry
Table C5 Ref 31
77
75%
Water bowsers
Table C6 Ref. 37
81
50%
Diesel generator
Table C4 Ref. 84
74
100%
Club hammer
Table D7 Ref. 80
79
50%
Angle grinder
Table C4 Ref. 93
80
50%
Hand-held circular saw cutting timber
Table D7 Ref. 77
82
50%
Impact wrench
Table D6 Ref. 52
78
50%
Site forklift trucks idling
Table D7 Ref. 96
77
50%
Diesel hoist
Table D7 Ref. 98
76
75%
Road sweeper
Table C4 Ref. 90
76
50%
6.4.21 The predicted noise levels are then compared against fixed limiting levels to determine the impact magnitude. BS 5228-1 informative Annex E provides example criteria of absolute noise limits for construction activities, and these have been used to determine the significance of any construction noise impacts within this assessment. 6.4.22 The criteria do not represent mandatory limits but rather a set of example approaches intended to reflect the type of methods commonly applied to construction noise. In broad terms, the example criteria are based on a set of fixed limit values which, if exceeded, may result in a significant effect unless ambient noise levels are sufficiently high to provide a degree of masking of construction noise.
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6.4.23 The range of guidance values detailed in BS 5228 Annex E have been used to numerically define the magnitude levels, as per Table 6.6. The values are based upon construction occurring during daytime hours from 08:00 to 18:00 on weekdays, and 08:00 to 13:00 on Saturdays. Reference is made to Category A, this is the most onerous category in the example thresholds shown in BS 5228, considered appropriate for tranquil sound climates. 6.4.24 As construction noise will always be an introduction of a new noise source (albeit temporary) and typically causes annoyance, impacts are considered to be negative. Therefore, the goal of mitigation measures is to minimise the severity and durations of negative impacts. Table 6.6: Impact magnitude – Noise from demolition and construction activities Impact magnitude
Noise level, dB LAeq,10hr
Description
High
> 85
Trigger level for temporary rehousing, or reasonable cost thereof, as set out in E.4 of BS 5228.
Medium
≤ 85 > 75
Above the trigger level for noise insulation works, or cost thereof, as set out in Table E.2 of BS 5228
Low
≤ 75 > 65
Above the threshold of ‘Category A’ of the ABC method set out within BS 5228, but lower than the trigger level for noise insulation works.
Negligible
≤ 65
Below the threshold of Category A of the ABC method set out within BS 5228.
Vibration from demolition and construction activity 6.4.25 Piling operations during the early phases of construction usually present the main risk of vibration effects to surrounding buildings. Other construction activities are unlikely to generate significant levels of vibration over prolonged periods. 6.4.26 CFA piling has been identified as the preferred means of piling. This technique is recognised within BS 5228-2 as generating very low levels of vibration. However, there is no ratified method to predict vibration levels from this type of piling. Therefore, to enable assessment, reference is made to historic vibration data within BS 5228-2 for auger piling at varying distances for different types of soil. This is considered a suitably robust approach for the purposes of identifying potentially significant effects. 6.4.27 Table 6.7 provides examples of historic data from BS 5228-2 at distances between 5 m and 15 m from piling activity. This aligns with the minimum distance between existing vibration sensitive receptors and areas of the Proposed Development likely to utilise piling. These are considered to be a reasonable worst case. In practice, the majority of piling will take place further at greater distances, which will result in reduced vibration levels at the receptors.
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Table 6.7: Historic data on vibration from auger piling BS 5228-2 reference
Table D6 Ref 107
Table D6 Ref 100
Table D6 Ref 102
Table D6 Ref 103
Table D6 Ref 104
Year and location
1985 Portland (Dorset)
1974 London W6
1982 Cheltenham
Type of soil
6m of soft ground over rock
Distance, m
PPV, mm/s
Activity
5
0.54
Augering
5
0.36
Surging casing
5
0.22
Twisting in casing
5
0.42
Spinning off
5
0.43
Boring with rock auger
7
3.20
Auger Driving casing using 3 t dolly (Horizontal vibration)
7
1.00
Auger Driving casing (Vertical vibration)
9
0.20
Augering
9
0.80
Hammering casing with Kelly bar
10
0.38
Augering
10
1.10
Dollying casing (2 t dolly)
10
0.96
Auger hitting base of hole
10
0.57
Spinning off
10
0.40
Augering
10
0.30
Mudding in
10
0.30
Spinning off
10
1.00
Dollying casing (2 t dolly)
14
0.20
Mudding in
14
0.80
Dollying casing (2 t dolly)
Fill/gravel/London clay
Fill / wet sand/ lias clay
1983 Romford Fill clay
1985 London W1 Fill/sand/clay
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14
0.30
Auger hitting base of hole
15
0.10
Augering
6.4.28 The assessment of construction vibration compares the historic data in Table 6.7 against vibration thresholds set out within BS 5228-2, which are commonly regarded as providing an acceptable level of protection from the short-term vibration levels associated with construction activities. 6.4.29 According to BS 5228-2, the thresholds at which cosmetic damage could occur in buildings (15 mm/s for light framed structures, or 50 mm/s for reinforced of heavy framed buildings) are significantly higher than the values for adverse human response to vibration. Consequently, the latter has been used to define impact magnitudes for construction vibration; as summarised in Table 6.8. Table 6.8: Impact magnitude – Vibration from demolition and construction activities Impact magnitude
PPV, mm/s
Description
High
≥ 10.0 mm/s
Vibration is likely to be intolerable for any more than a very brief exposure to this level in most building environments.
Medium
< 10.0 mm/s ≥ 1.0 mm/s
It is likely that vibration above 1.00 mm/s in residential environments will cause complaint but can be tolerated over short periods if prior warning and explanation has been given to residents.
Low
< 1.0 mm/s ≤ 0.3 mm/s
The threshold at which vibration might be just perceptible in residential environments. The upper value may cause complaint if prior warning is not given to residents.
Negligible
< 0.3mm/s
Vibration may be just perceptible in the most sensitive situations for most vibration frequencies associated with construction.
Noise from demolition and construction traffic 6.4.30 In addition to noise from construction activity, Heavy Goods Vehicles (HGVs) and other delivery vehicles will be visiting the site throughout the construction programme. 6.4.31 Changes in road traffic noise during construction have been assessed based upon traffic flow data provided by the project Transport Consultant (SLR) and following the methodology described within CRTN. The assessment is based on two construction timeslices; • •
2028: Phase 1A and 1B overlap. This timeslice represents a busy period for construction and demolition, with Phase1A nearing completion and demolition of Phase 1B commencing. This also represents a high peak in construction vehicles (72 HGV movements per day). 2030: Occupation of Phae 1A with new residents and construction and demolition across the entire site with 1B, 2A, 2B and 3A. This also represents the highest peak in construction vehicles (168 HGV movements per day), and includes partial operational road traffic from the completed Phase 1A buildings.
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6.4.32 Traffic data has been provided as 18-hour Annual Average Weekday Traffic (AAWT) and consequently assessment is based upon changes in L10,18hr. This is standard practice for the assessment of road traffic noise. 6.4.33 The impact magnitude is assessed by comparing the change in road traffic noise with and without the Proposed Development against criteria listed in DMRB for short term road traffic noise impacts. The impact magnitude for construction traffic noise is shown in Table 6.9. Table 6.9: Impact magnitude – Noise from demolition and construction traffic Impact magnitude
Noise change, dB LA10,18hr
Description
High
≥ 5.0
Change in short term noise would be clearly perceptible. Considered in DMRB to be a major magnitude.
Medium
3.0 – 4.9
Change in short term level may be perceptible under normal conditions. Considered in DMRB to be a moderate magnitude.
Low
1.0 – 2.9
Change in short term level may be perceived at the upper end of the range under certain conditions. Described in DMRB to be a minor magnitude.
Negligible
<1.0
Change in short term level may be just perceptible in critical listening conditions. Described in DMRB to be negligible magnitude.
6.4.34 As set out in the Scoping Report, an assessment has been undertaken for road links where road traffic associated with the Proposed Development could result in change in basic noise level of more than 1 dB. This is in line with scoping guidance provided within the most recent version of DMRB. Historic versions of DMRB advised that a 1 dB change is likely to occur should there be a 25% change in the overall traffic flow (AAWT). Road links subject to changes of less than a 1 dB change inherently result in a negligible impact. 6.4.35 Where assessments have been undertaken, these are based upon assessing to a fixed distance of 10 m from the centre of the relevant road links; rather than to a specific receptor. As the assessment considers the relative change in noise, rather than the absolute noise level, the distance itself does not affect the resultant impact (as the existing roads themselves will not be relocated). This applies to assessments during both the construction and operational phase. Operational Phase Changes in noise associated with operational road traffic 6.4.36 The introduction of new road traffic associated with the Proposed Development has the potential to change the level of noise on the surrounding existing road networks. 6.4.37 As with the construction traffic assessment, changes in road traffic noise during the operational phase of the Proposed Development have been assessed in line with CRTN based upon traffic flow data provided by SLR. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
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6.4.38 The impact magnitude is assessed by considering the difference in road traffic noise between the future baseline year (2036 – the opening year of the fully completed and operational Proposed Development) with and without the Proposed Development. Additional consideration has been given to the year 2036 in a scenario whereby only Phase 1A is completed. 6.4.39 Assessment for the operational phase has been undertaken for road links where road traffic associated with the Proposed Development could result in change in basic noise level of more than 1 dB. For road links included within the assessment, the magnitude of impact of operational traffic noise is determined based upon the DMRB criteria for assessment of shortterm noise impacts as set out in Table 6.9. Noise from building services plant 6.4.40 Noise emissions from fixed building services plant will need to be controlled to limiting levels to avoid disturbance of neighbouring noise sensitive receptors. 6.4.41 At this stage, information on the type and quantity of building services plant is not sufficiently developed to enable a detailed assessment to be undertaken. Therefore, the assessment has been based on setting appropriate plant noise emission limits designed to avoid significant effects. These limits will be secured by planning condition upon granting of planning permission and is a standard approach at this stage. 6.4.42 The magnitude of noise impacts associated with the operation of fixed building services plant have been defined based upon guidance within BS 4142. The impact of sound of a commercial nature, such as plant noise, depends upon both the margin by which the rating level of the specific sound source exceeds the background sound level and the context in which the sound occurs. The impact can be estimated by subtracting the measured background sound level from the rating level. Impact magnitudes for the assessment of noise from building services plant is provided in Table 6.10. Table 6.10: Impact magnitude – Noise from building services plant and commercial noise Impact magnitude
Difference between rating level and background sound, dB
Description
High
≥ 10
A difference of +10 dB or more is likely to be an indication of a significant adverse impact, depending on context.
Medium
≤ 10 >0
The lower the rating level is relative to the measured background level, the less likely it is that the specific sound source will have an adverse impact or a significant adverse impact.
Low
≤0 > -10
Where the rating level does not exceed the background sound level, this is an indication of the specific sound source having a low impact, depending on the context.
Negligible
≤ -10
The rating level of noise from the specific sound is not expected to result in a measurable increase in the background sound level.
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6.4.43 LBL typically require that noise from building services plant is controlled to a level no greater than 5 dB below the existing background sound levelRef6.32, and it is expected that this requirement will be secured by planning condition. This will inherently result in a low impact. 6.4.44 For receptor R11, which is used to represent future residential dwellings within the Proposed Development, it is proposed that building services noise is controlled to a level not exceeding the typical background sound levels. Whilst this is a slight relaxation upon LBL’s standard policy, it is recognised that new residents will not be familiar with the baseline background sound levels within the local area and would therefore not experience an increase in sound in the same way as an existing receptor. The proposed limits are still indicative of a ‘low’ impact according to the BS 4142 methodology. Noise from commercial activities within the Proposed Development 6.4.45 Commercial and business units within the Proposed Development have the potential to introduce new noise from several sources. Noise from road traffic associated with the commercial units, and fixed building services plant, are included within the respective assessments detailed above. 6.4.46 Where a specific use is known, and the types of likely activities can be reasonably estimated (e.g. loading and unloading of delivery vehicles), the predicted level of noise is assessed in line with BS 4142. Impact magnitudes are based upon those defined in Table 6.10. 6.4.47 Where other operational activities cannot be accurately quantified at this stage (i.e., where specific tenants or processes are unknown), the approach has been to assess based upon the setting of operational sound limits designed to avoid significant effects. There will be a need for operational management plans to be developed for such activities, mindful of the need to incorporate noise control measures to minimise disturbance to nearby noise sensitive receptors. These can be secured by planning condition upon granting of planning permission. Suitability of the Site for residential development 6.4.48 The Proposed Development will need to be designed to provide appropriate sound levels both internally within apartments and externally within amenity areas to protect future occupants against adverse health effects. 6.4.49 The site suitability assessment is informed by the results of the baseline environmental sound survey, which has been used to calibrate a 3D computer noise model of the Proposed Development. 6.4.50 The site suitability assessment has been primarily undertaken based upon the Maximum Parameters massing for the purposes of identifying the highest external noise levels incident upon the Proposed Development in order to identify appropriate noise control measures. 6.4.51 However, it is noted that the Maximum Parameters will offer significant acoustic screening between the primary noise sources (i.e. roads around the perimeter of the Site) and areas towards the centre of the Site. Whilst this will not affect the outcome of the internal sound level assessment, as the worst-case will be facing the road, there is potential that it will underestimate noise levels within the external amenity spaces. Therefore, a secondary assessment has been provided based upon the Illustrative Scheme to test the effects of reducing the building massing, as this is likely to result in increased noise levels towards the middle of the site. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
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Internal sound levels within dwellings 6.4.52 The building envelope will be designed to achieve the internal sound levels set out in Table 6.3. These criteria are commonly adopted as the ‘industry standard’ and are normally required by most local authorities. They include for normally occurring noise such as road traffic, trains and general street activity; but exclude sporadic activities such as emergency sirens or alarms. 6.4.53 BS 8233 states that regular individual noise events (such as a passing train) can cause sleep disturbance. WHO guidance suggests an internal sound level of 45 dB LAmax should not be exceeded more than 10-15 times per night. 6.4.54 In addition to providing guidance on suitable internal sound levels, BS 8233 also provides a method for calculating the level of noise intrusion through a facade. A simplified assessment is to subtract the internal sound level standard from the external noise level incident upon the façade and apply a correction of 5 dB to account for the effect of amplification of noise entering the room (due to factors such as the shape and size of the space, plus any sound absorbing finishes). This simplified method has been adopted to give an indication of the likely level of façade sound reduction required at this stage. 6.4.55 Consideration has also been given to the acoustic implications of opening windows, to relieve risk of overheating, on the internal acoustic environment for future occupants. Assessment is based upon compliance with the acoustic requirements of ADO, with additional guidance drawn from AVOG where appropriate. External amenity spaces 6.4.56 In addition to the indoor acoustic conditions, it is desirable that residents have access to external amenity space for resting and enjoyment. BS 8233 provides guidance on suitable external sound levels which are derived from WHO guidance. 6.4.57 BS 8233 advises that, for traditional external amenity areas such as gardens or patios, it is desirable that sound levels do not exceed 50 dB LAeq,16hr between 07:00 and 23:00, with an upper guideline value of 55 dB LAeq,16hr. 6.4.58 However, as explained in paragraph 6.2.37, BS 8233 advises that these desirable sound levels are not always achievable in areas close to strategic transport infrastructure or within town centres, and also setting noise limits for small private balconies (which may be used for drying washing, growing plants etc) is not necessarily appropriate. This is the case for a large number of external facing balconies within the Proposed Development. 6.4.59 The site suitability assessment is therefore focused on identifying areas where residents could have access to quieter external amenity areas (in line with the BS 8233 criteria) within the Proposed Development should they wish to utilise them.
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6.5
Significance Criteria
6.5.1 The assessment of the potential impacts and likely effects as a result of the Proposed Development has taken into account both the Demolition and Construction Phases and Operational phases. The significance level attributed to each effect has been assessed based on the magnitude of change due to the Proposed Development and the sensitivity of the affected receptor/receiving environmental to change, as well as a number of other factors that are outlined in more detail in Chapter 2: Approach to Assessment. 6.5.2 Magnitude of change and the sensitivity of the affected receptor/receiving environmental are both assessed on a scale of high, medium, low and negligible (as shown in Chapter 2: Approach to Assessment). Effect Significance 6.5.3 The following terms have been used to define the significance of effects identified: • • • •
Major positive or negative effect – where the Proposed Development would cause a large improvement (or deterioration) to the existing environment; Moderate positive or negative effect – where the Proposed Development would cause a noticeable improvement (or deterioration) to the existing environment; Minor positive or negative effect – where the Proposed Development would cause a small improvement (or deterioration) to the existing environment; and Negligible – no discernible improvement or deterioration to the existing environment as a result of the development will occur.
6.5.4 Major or moderate effects will be considered as significant in the context of this assessment. Minor or negligible effects will be considered as not significant. Receptor sensitivity 6.5.5 Sensitive receptors in the assessment have been classified into the following categories of sensitivity. These categories have been determined based on the guidance contained in BS 8233, World Health Organisation Guidelines, and other guidance documents as described in section 6.2. Table 6.11 summarises the sensitivities for the different receptor types. Table 6.11: Receptor sensitivity Sensitivity
Typical descriptors
High
Residential (dwellings plus residential healthcare and educational establishments) Educational facilities (schools and colleges)
Medium
Non-residential healthcare and hospitals Noise-sensitive leisure (e.g. hotels, museums and libraries) Places of worship
Low
Commercial facilities (e.g. retail and office uses)
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Defining the effect 6.5.6 The scale of effects has been determined using the matrix presented in Table 6.12, through a standard method of assessment based upon professional judgement, considering the sensitivity of the receptor and the magnitude of impacts described in the previous section. 6.5.7 Consideration is also given to other factors that may affect the scale of effect. For example, a ‘high’ impact may be considered to have a lower effect if it is highly localised, or over very short durations. Conversely, a ‘medium’ impact may have a greater effect if the resultant change in noise is experienced over a prolonged period. Effects will be considered positive if they result in a reduction in noise experienced at the receptor, and negative if they result in an increase in noise when compared to the baseline. 6.5.8 The assessment is centred upon controlling noise to the nearest sensitive receptors in the vicinity of the site. All effects are therefore considered to be of local significance. 6.5.9 Effects identified throughout the demolition and construction period are considered to be temporary, short to medium-term effects (depending on the extent of the construction works). Noise effects identified during the operational phase of the Proposed Development are considered to be permanent. 6.5.10 All identified effects are as a direct result of the Proposed Development Table 6.12: Effect significance matrix for Noise and Vibration assessment
Receptor sensitivity
Impact magnitude High
Medium
Low
Negligible
High
Major
Moderate
Minor
Negligible
Medium
Moderate
Moderate
Minor
Negligible
Low
Moderate
Minor
Minor
Negligible
6.6
Baseline Conditions
6.6.1 The environmental sound climate is characterised primarily by road traffic along Molesworth Street, Rennell Street and Lewisham High Street. Sound from intermittent trains is audible during periods of quieter road traffic to the west of the Site. 6.6.2 External sound levels are lower towards the east of the Site overlooking the pedestrianised high street and market. The soundscape here is characterised by people movement and talking, as well as market activity. 6.6.3 An overview of the measurement locations and summary of measured results is presented in Figure 6.1 and key measurement results relevant to the noise impact assessment are summarised in Table 6.13.
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Figure 6.1 Summary of measurement positions and key baseline environmental sound survey results
6.6.4 Ambient sound levels (LAeq,T) are provided as a logarithmic average over the relevant periods. Typical background sound levels (LA90) have been defined, following a statistical analysis as per the methodology of BS 4142, as the cumulative tenth percentile of measured levels during the period. 6.6.5 Measurement positions 1-4 all comprised long-term monitoring over a period of at least 5 days including a weekend at each position (at least 7 days for positions 1, 3 and 4. Position 2 was shorter due to a battery failure on site after 5 days). Refer to Appendix 6.1 for further details. 6.6.6 The remaining measurement positions have been used primarily to develop the 3D computer model of the site for the purposes of the site suitability assessment and are not directly referenced throughout this noise impact assessment. As such, results are not included in Table 6.13, but are provided in Appendix 6.1 for reference. Table 6.13: Summary of key measurement results from baseline environmental sound survey
Measurement position
Ambient sound pressure level, dB LAeq,T
Typical background sound pressure level, dB LA90,T
Day (07:00–23:00)
Day (07:00–23:00)
Night (23:00-07:00)
Night (23:00-07:00)
1
62
59
56
52
2
64
60
55
45
3
63
57
53
41
4
63
60
55
45
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6.7
Future Baseline
6.7.1 Consideration has been given to the evolution of the baseline condition in the absence of the Proposed Development. 6.7.2 The dominant source of environmental sound is road traffic. Traffic flow data provided by the project Transport Consultant (SLR) includes the future baseline data for 2036 (the opening year of the fully completed Proposed Development) and this has been referenced in the assessment of future operational road traffic noise. 6.7.3 A review of the data indicates that, for all the assessed road links, an increase in road traffic flows of less than 14% is expected in the future year in the absence of the Proposed Development. According to DMRB this will result in less than a 1 dB change in baseline noise levels. Changes in sound level of less than 1 dB are considered to be only just perceptible under laboratory conditions and imperceptible in normal real-world conditions. Therefore, it is considered that there will be negligible increase in the future baseline sound levels from road traffic.
6.8
Sensitive Receptors
6.8.1 The sensitive receptors considered within the assessment were set out within the EIA Scoping Report and were acknowledged as acceptable by LBL. The receptors are summarised in Table 6.14. 6.8.2 Two additional receptors (R10 and R11) not included within the EIA Scoping Report have also been assessed. R10 is the St Saviour’s Church located on Lewisham High Street to the southeast of the Site. R11 has been identified to represent future residents within occupied parts of the scheme. 6.8.3 For the purposes of the demolition and construction phase assessments, R11 is defined as being at a fixed distance of 10 m from construction activity. This is the closest distance between the earliest completed and occupied dwellings (Phase 1A) and later construction phases and is considered a reasonable worst case. 6.8.4 For assessments of the completed development, R11 is used as a holistic term when describing criteria that may apply to future residents of the Proposed Development, but is not defined as a fixed location for any given building (e.g. fixed building services plant noise limits will apply equally at all dwellings within the Proposed Development) 6.8.5 Whilst it is recognised that there may be additional noise sensitive receptors, those listed above are considered to be the most exposed to potential noise from the Proposed Development. Control of noise to these receptors will therefore inherently protect sensitive receptors located at greater distances from the Site.
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Table 6.14: Noise sensitive receptor descriptions Receptor ID
Description
R1
Residential dwellings at Mill Apartments and Riverdale House
R2
Residential apartments at 193 Lewisham High Street (above shops)
R3
Residential apartments at 161-171 Lewisham High Street (above shops)
R4
Residences between Lewisham High Street and Lewis Grove (above shops)
R5
Residences at Tower House and 77-83 Lewisham High Street (above shops)
R6
Residences at 110-118 Lewisham High Street (above shops)
R7
Residences at Metro Apartments (86-92 Lewisham High Street) and 90-94A Lewisham High Street (above shops)
R8
Residences at 50-70 Lewisham High Street (above shops)
R9
Lewisham Gateway Phase 2 (under construction)
R10
St Saviour’s Church, Lewisham High Street
R11
New dwellings within occupied phases of the Masterplan
6.8.6 All receptors are residential in nature and considered to be ‘high’ sensitivity to noise, except for receptor R10. This is a place of worship and considered of ‘medium’ sensitivity to noise.
6.9
Assessment of Effects, Mitigation and Residual Effects Demolition & Construction Phase
6.9.1 This section identifies and assesses the scale and nature of the main effects arising from the Proposed Development during the construction phase. Noise from demolition and construction activity 6.9.2 The potential effects of noise from demolition and construction activities have been assessed based upon the schedule of potential noise generating activities set out in Table 6.5. The resulting demolition and construction noise levels are presented in Table 6.15 during Phase 1A (Timeslice 1), and Table 6.16 for the remaining phases (Timeslice 2). Figures identifying the construction distances for each timeslice are provided in Appendix 6.1. 6.9.3 The resultant noise levels are colour coded according to the impact magnitude. A negligible impact magnitude is denoted in green, with low, medium and high impact magnitudes colour coded in yellow, orange and red respectively. Noise levels that would result in a significant effect are identified in underlined text. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
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6.9.4 With regard to receptor R8, it should be noted that these are located very close to the Phase 1A buildings. This is similarly the case at receptor R6 during the construction of plot C1 (Phase 3A). For the purposes of assessment, it has been assumed that construction will be taking place at least 5 m from these receptors. It is recognised that some demolition and construction activities could be taken place at even smaller distances. However, it becomes difficult to predict these with any accuracy. Specialist care and attention will be needed when these demolition and construction activities are taking place in proximity of receptor R8 and R6. Appropriate construction techniques and management measures will be needed to mitigate, and minimise as best as practicable, the impact upon the receptor. The draft CMP submitted alongside the ES identifies the need to isolate any connected structures early in the demolition phase to minimise noise and vibration transfer throughout works. Table 6.15: Demolition and construction noise assessment – Phase 1A (Timeslice 1) Receptor
Range of potential construction noise levels per stage, dB LAeq,T Demolition / Enabling works
Foundations & Substructure
Superstructure, Cladding & Roofing
R1
29 - 51
36 - 51
33 - 51
36 - 51
42 - 48
R2
27 - 49
34 - 49
31 - 49
34 - 49
40 - 46
R3
30 - 52
37 - 52
34 - 52
37 - 52
43 - 49
R4
42 - 60
49 - 60
46 - 60
49 - 61
55 - 61
R5
44 - 66
51 - 66
48 - 66
51 - 66
57 - 63
R6
52 - 70
59 - 70
56 - 70
59 - 71
65 - 71
R7
60 - 78
67 - 78
64 - 78
73 - 85
73 - 79
R8
66 - 84
73 - 84
70 - 84
73 - 85
79 - 85
R9
47 - 65
54 - 65
51 - 65
54 - 66
60 - 66
R10
28 - 50
34 - 50
32 - 50
35 - 50
41 - 47
R11
External hard landscaping
Miscellaneous
N/A for Phase 1A
6.9.5 The assessment for Phase 1A (Timeslice 1) concluded that the majority of demolition and construction activities will result in a negligible to low impact magnitude. However, some specific activities will result in a medium impact magnitude at some receptors as discussed below.
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6.9.6 Minor negative effects are predicted at receptors R6 throughout all demolition and construction stages, which are not significant in the context of this noise impact assessment. Minor negative effects are also predicted at R5 for all phases excepting the use of miscellaneous equipment (e.g. generators, hand tools etc), and R9 during external hard landscaping works and the use of miscellaneous tools. 6.9.7 Moderate negative effects are predicted at receptors R7 and R8 during all demolition and construction stages, which are significant. 6.9.8 Effects at all other receptors are negligible. Table 6.16: Demolition and construction noise assessment – Remaining phases (Timeslice 2) Receptor
Range of potential construction noise levels per stage, dB LAeq,T Demolition / Enabling works
Foundations & Substructure
Superstructure, Cladding & Roofing
External hard landscaping
Miscellaneous
R1
49 - 67
56 - 67
53 - 67
56 - 68
62 - 68
R2
52 - 70
59 - 70
56 - 70
59 - 71
65 - 71
R3
46 - 64
53 - 64
50 - 64
53 - 65
59 - 65
R4
49 - 67
56 - 67
53 - 67
56 - 68
62 - 68
R5
40 - 58
47 - 58
44 - 58
47 - 59
53 - 59
R6
66 - 84
73 - 84
70 - 84
73 - 85
79 - 85
R7
43 - 65
50 - 65
47 - 65
50 - 65
56 - 62
R8
44 - 66
51 - 66
48 - 66
51 - 66
57 - 63
R9
49 - 67
56 - 67
53 - 67
56 - 68
62 - 68
R10
52 - 70
59 - 70
56 - 70
59 - 71
65 - 71
R11
60 - 78
67 - 78
64 - 78
67 - 79
73 - 79
6.9.9 The assessment for the remaining construction phases (Timeslice 2) concluded that the majority of demolition and construction activities will result in a negligible to low impact magnitude. However, some specific activities will result in a medium impact magnitude at some receptors as discussed below. 6.9.10 Minor negative effects are predicted at receptors R1, R2, R4, R9 and R10 throughout all demolition and construction stages, which are not significant in the context of this noise impact assessment. Minor negative effects are also predicted at R8 for all phases excepting the use of miscellaneous equipment (e.g. generators, hand tools etc). Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
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6.9.11 Moderate negative effects are predicted at receptor R6 and R11 during all stages of demolition and construction, which are significant. It should be noted that this is based upon the minimum distance of 5 m for R6 and 10 m for R11. Minor negative effects are predicted at both receptors for construction activities taking place at distances of 15 m or more from the occupied residential phases. Therefore, for receptor R6, moderate negative effects are only considered likely during the construction of plot C1. 6.9.12 Effects at all other receptors are negligible. Mitigation 6.9.13 The demolition and construction noise assessment highlighted the potential for significant effects at receptors R7 and R8 during phase 1A, and at receptors R6 and R11 during the remaining phases, for some activities occurring at relatively small distances from the receptor. 6.9.14 Best practicable means should therefore be employed to mitigate the effects, based upon the measures indicated within BS 5228 and discussed below. The implementation of best practicable means will also serve to reduce noise from other construction related activity that was found to be of lower impact. 6.9.15 The draft CMP submitted alongside the ES confirms that the Contractor will be expected to develop a full and final CMP which would set out details of noise control measures. The need to include noise control measures within the CMP can be secured by means of a suitably worded planning condition attached to any decision notice for the Proposed Development. 6.9.16 The CMP would be expected to include (but not be limited to) the following: • • • • • • • •
• •
Confirmation of site working hours (as identified within paragraph 6.4.23 of this chapter); Substitution of noisy plant and techniques with quieter alternatives; Provision of enclosures and or acoustic barriers around noisy plant or processes; Careful use and siting of noisy plant; Regular maintenance of plant to minimise noise with age and use; When particularly noisy activities are expected to take place close to the affected receptors, clear communication lines between the Contractor and residents to inform of the type of activities and likely timescales; The use of just-in-time deliveries to reduce the duration which receptors are exposed to noise from construction traffic; Loading and unloading of vehicles, dismantling of site equipment such as scaffolding or moving equipment or materials around the site are to be conducted in a manner as to minimise noise generation. Vehicles should be switched off when not in use (anti-idling policy). The use of reverse beepers shall be avoided as far as is practicable with safe operating practices; and All machines in intermittent use shall be shut down in the intervening periods between works if possible or throttled down to a minimum. Construction noise monitoring to be employed to determine compliance with any construction noise limit agreed with LBL post planning, with an agreed reporting and action protocol.
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Residual Effect 6.9.17 It is not possible to accurately quantify the level of noise reduction that would be achieved through the implementation of best practicable means. However, recognising that significant effects were typically only occurring when construction activity took place at short distances, it is anticipated that these effects can be managed by communication with residents at the appropriate time to inform them of the likely duration of works or, if necessary, agree a more suitable time to undertake the noisiest works closest to the site boundary. 6.9.18 Whilst this will not reduce the level of noise generated, it is commonly recognised that this can positively affect the receptor’s perception of the construction activity. This will be of particular importance when construction works are taking place at small distances less than 15 m to the receptors. Beyond this distance, construction noise would be reduced to a Minor Negative effect through distance attenuation in combination with localised screening around particular noisy activities such as concrete breaking. 6.9.19 On the basis that the adverse effects of noise from demolition and construction can be appropriately managed, the residual effect is considered to be Negligible to Minor Negative at all receptors, which is not significant. Vibration from demolition and construction activity 6.9.20 CFA Piling has been identified as the preferred means of piling. This technique is recognised within BS 5228-2 as generating very low levels of vibration. 6.9.21 The historic data presented in Table 6.7 has been assessed against the vibration thresholds set out in Table 6.8 to determine impact magnitude. 6.9.22 At distances above 10 m, there are numerous examples of historic PPV data less than 1.0 mm/s. This corresponds to a negligible to low impact and would apply to receptors R1-R6, R9 and R10 during Phase 1A (Timeslice 1), and all receptors excepting R6 and R11 during the later construction phase assessment (Timeslice 2). Therefore, at these receptors, the effect of vibration during construction will be negligible to minor negative, and not significant in the context of this ES chapter 6.9.23 Receptors R7 and R8 are located at distances less than 10 m from the Proposed Development during Phase 1A (Timeslice 1), as are receptors R6 and R11 during the remaining phases (Timeslice 2). The historic data does show a number of examples where PPV is reduced to less than 1.0 mm/s at these distances. However, there are two outliers in the data which highlight the potential for occasional higher levels of vibration (up to 3.2 mm/s). The resultant impact magnitude at these receptors is therefore considered to range from negligible to medium. This will result in negligible to moderate negative effects, which would be significant. Further mitigation should be implemented to reduce these effects. Mitigation 6.9.24 The construction vibration assessment identified that there is a potential for significant effects when piling is ongoing at distances of less than 10 m from a sensitive receptor.
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6.9.25 Similar vibration mitigation measures would be expected to set out within a CMP as described for noise in paragraph 6.9.16; in particular the selection of lower-vibration, maintaining clear communication lines with local residents, maintaining the equipment, and vibration monitoring to check ongoing compliance against any agreed vibration limit with LBL post planning. Residual Effect 6.9.26 Similarly to demolition and construction noise, whilst it is not possible to accurately quantify the reduction in vibration that would be achieved through the implementation of best practicable means, it is considered that vibration can be adequately managed during times when piling is taking place at close quarters (less than 10 m from the receptors). CFA piling is often recognised as being the least vibration generating, and there are several examples in Table 6.7 which demonstrate that low impact magnitudes (minor negative effects) can be realised. 6.9.27 Further to this, communication with residents will be necessary at an appropriate time will to inform them of the likely duration of piling works or, if necessary, agree a more suitable time to undertake the works closest to the site boundary. It is commonly recognised that this can positively affect the receptor’s perception of the construction activity and therefore would reduce the impact. 6.9.28 On the basis that the adverse effects of vibration from demolition and construction can be appropriately managed, the residual effect is considered to be Negligible to Minor negative at all receptors, which is not significant. Noise from demolition and construction phase road traffic 6.9.29 The traffic flow data provided by the Transport Consultant (SLR) has been reviewed to determine the changes in noise due to construction road traffic. The review concluded that none of the assessed road links exceed the threshold to trigger assessment described in paragraph 6.4.34 for either of the assessed construction years. 6.9.30 Consequently, noise from demolition and construction traffic is considered to result in a negligible impact magnitude. This results in a Negligible effect, which is not significant in the context of this assessment. Mitigation 6.9.31 No significant effects were identified and as such no specific mitigation is required. However, it is commonly found that the CEMP will contain best practicable means, such as ‘no idling’ policies, which would be expected to further reduce noise associated with demolition and construction traffic. Residual Effect 6.9.32 The residual effect of noise from demolition and construction road traffic remains negligible and not significant.
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Operational Phase 6.9.33 This section identifies and assesses the scale and nature of the main effects arising from the Proposed Development during the operational phase. Changes in noise associated with operational road traffic 6.9.34 The traffic flow data provided by the Transport Consultant (SLR) has been reviewed to determine the changes in noise due to operational phase road traffic. 6.9.35 The review concluded that none of the assessed road links exceed the threshold to trigger assessment described in paragraph 6.4.32 in either assessment scenario (Phase 1A only, nor the fully completed and operational development). 6.9.36 In a scenario where only phase 1A is completed, the most affected road link will experience an increase in AAWT of less than 2%. This will result in less than a 1 dB change in road traffic noise, and therefore a negligible impact magnitude. 6.9.37 In the ‘fully completed’ development scenario, there is an overall reduction in traffic movements for all assessed road links. The road link most benefiting from this will experience a 7% reduction in traffic. However, the magnitude of this beneficial impact remains negligible. 6.9.38 As such, a negligible effect is concluded for both the ‘Phase 1A only’ and ‘Fully Completed’ development scenarios, which is not significant in the context of this impact assessment. Mitigation 6.9.39 No significant effects were identified and as such no specific mitigation is proposed. Residual Effect 6.9.40 The residual effect of noise from operational road traffic remains negligible and not significant. Noise from building services plant 6.9.41 Noise produced by building services equipment must be controlled to achieve acceptable levels of environmental noise, both within the site itself and the surrounding areas. 6.9.42 At this stage, the types of plant and equipment selections have not been finalised. The main plant is likely to take the form of: • • • •
Air handling plant: Localised mechanical ventilation with heat recovery (MVHR) units within the apartments, and commercial unit air handling units (AHUs, fans and MVHRs). Residential heating and cooling: Air source heat pumps (ASHPs) located at roof level of each building Commercial heating and cooling: May be provided by ASHPs or Variable Refrigerant Flow (VRF) condensing units by the incoming Tenants at a later date. Emergency plant: Smoke extract fans and life safety generators.
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6.9.43 As a consequence of the current state of design, the assessment is based upon setting limiting rating noise levels that future plant selections will need to adhere to. The limits are derived in line with the guidance set out within BS 4142, LBL planning policy, and with reference to the EIA Scoping Report. The need to achieve these limits can be enforced through the use of a suitably worded planning condition attached to any decision notice for the Proposed Development. 6.9.44 Proposed limits for the rating noise levels of new building services plant are proposed in Table 6.17. The limits are derived from measurements taken during the 2024 baseline environmental sound survey (the most relevant measurement position is provided in brackets beneath the receptor ID). Table 6.17: Limiting Rating Noise limits (dB LAr,Tr) for new building services plant Receptor
Description
Daytime (07:0023:00)
Night (23:0007:00)
R1, R2,R3, R10
Representative background sound level at receptor, dB LA90
55
45
Proposed maximum rating noise level, dB LAr,Tr
50
40
Representative background sound level at receptor, dB LA90
55
45
Proposed maximum rating noise level, dB LAr,Tr
50
40
(Position 2)
R4,R5,R6,R7,R8,R9 (Position 4)
6.9.45 On the basis that these limits are secured through planning condition, noise from building services plant will result in a Minor Negative effect at all noise sensitive receptors, which is not significant in the context of this noise impact assessment. Furthermore, the result noise limits will be fully compliant with LB Lewisham policy. 6.9.46 Noise from emergency plant would not normally be expected to meet the rating level requirements as set out within Table 6.12. It is common practice to apply a ‘relaxed’ requirement whereby noise from emergency plant (life safety generators, smoke extract fans) are controlled to a level no more than 10 dB above the prevailing background sounds during periods when the equipment is periodically tested. 6.9.47 Whilst this would result in a ‘high’ impact magnitude, BS 4142 methodology states the importance of considering the context of the new noise source that is being introduced. The emergency equipment provides a vital life safety function, and the impact of noise is therefore considered to be of secondary importance. Outside of emergency use, the equipment is typically only operated for short periods for testing. It is commonly accepted that testing should only take place for limited periods (normally up to one hour) during working hours Monday to Friday, and excluding bank holidays and weekends. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
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6.9.48 Based upon previous experience, and professional judgment, it is considered that the limited duration, and testing during the noisier part of the day, reduces the impact magnitude substantially. Noise from emergency plant is therefore considered to be of low impact. This will result in a Minor Negative effect at all receptors, which is not significant Mitigation 6.9.49 Whilst the impact assessment concluded that noise from building services plant would be controlled to limiting noise criteria, noise control measures will be needed to ensure that the limits are adhered to. 6.9.50 As the design is progressed, detailed plant noise assessments will be required to identify specific mitigation required to achieve the rating noise level limits. In addition to selecting low noise equipment as far as possible, it is likely that physical noise control measures will be required. These would include the use of sound attenuators to the intakes and exhausts of fans, and attenuation packs to heat rejection plant. Appropriate space planning has been made within the detailed design for phase 1A. In addition, all equipment will need to be fitted with anti-vibration mounts as standard. 6.9.51 The need to control noise to limiting levels can be controlled through the use of a suitably worded planning condition attached to any decision notice for the Proposed Development. Any such condition should enable assessment on a ‘building by building’, or ‘unit by unit’, basis to allow for staggered tenancies and the phased nature of the Proposed Development. Residual Effect 6.9.52 On the basis that noise will be controlled to appropriate limits secured by planning condition, noise from building services plant will result in a Minor Negative effect at all noise sensitive receptors, which is not significant. Noise from commercial activities within the Proposed Development 6.9.53 There will be a number of commercial and business units within the Proposed Development. At this stage, whilst the types of use are broadly defined, specific tenants have not been brought in and so the precise activities cannot be accurately defined. 6.9.54 Any incoming tenant would be expected to undertake a noise impact assessment and use this to inform an operational management plan to limit noise impacting upon neighbouring receptors, including those introduced as part of the Proposed Development. 6.9.55 The operational management plan would be expected to include a mixture of physical noise control measures (e.g. acoustic enclosure of particularly noisy processes within service yards), and management controls (no idling, switching off reversing alarms at night, keeping doors closed at night etc). The noise limits that would need to be achieved will be dependent upon the operating hours of the commercial unit in question.
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6.9.56 According to BS 4142, a rating noise level that does not exceed the background sound level is indicative of a low impact, depending upon the context. In terms of specific context, the site already houses Lewisham Shopping Centre, and so the Proposed Development will not be introducing dissimilar uses, or sound sources, into the area. Therefore, a rating noise limit for operational activity that does not exceed the background sound is considered to be appropriate. However, it is understood that LBL would seek to impose a limit 5 dB below the background sound level, similar to building services plant noise Ref 6.32. 6.9.57 Based upon the measured background sound levels, this would result in the same rating noise limits as set out in Table 6.12 for building services noise. Limits are provided for day and night time periods. Although it is likely that most activity would take place during daytime hours, night time limits may be appropriate for certain activities. 6.9.58 To determine whether the limits are feasible, consideration has been given to the types of activity that could reasonably be expected to occur within the Proposed Development. Aside from the residential units, the Proposed Development primarily comprises commercial retail units, as well as a music venue as part of a refurbishment of the existing CoL building. 6.9.59 The main types of noise that are anticipated are therefore primarily those of vehicles arriving at, and leaving, the Proposed Development as well as noise from building services plant noise. These have both been assessed and reported on as part of the operational road traffic assessment and building services plant noise assessments respectively. 6.9.60 Additional consideration has been given to the impact of individual HGV movements driving within the service deck. This is located at first floor level beneath the landscaped podium in broadly the same location as the existing service deck and is at least 65 m from the nearest receptor (R1). Assessment is focused on this receptor as the most noise-affected from the service deck. 6.9.61 The assessment of noise from individual HGVs has been undertaken based upon the following conservation assumptions: •
• • •
Up to eight HGV movements in a single hour within the Service Deck (approximately 1 every 7.5 mins). This is considered conservative given that the maximum daily HGV flows provided by the project transport consultant are less than 30 HGVs per 18 hour day). Assessment has been based upon the distance from the top of the ramp (i.e. service yard entrance) to the nearest receptor. When vehicles are on the ramp itself, they are assumed to be part of the road traffic along Molesworth Street. It is assumed that individual vehicle movements will be located at the closest point at the service yard entrance for 30 seconds. In practice, as this is the main ingress and egress point, the time spent at this location is likely to be shorter. No BS 4142 character corrections have been applied on the basis that the existing sound environment contains vehicle noises, which will regularly include HGVs and other commercial delivery vehicles within the existing shopping centre service deck. The sound character is therefore considered to be in keeping with the existing baseline sound environment.
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6.9.62 In the absence of specific data, the vehicle sound power levels have been calculated based upon the CNOSSOS-EU methodology. This method empirically derives a vehicle sound power level based upon its category (HGVs are referred to as Category 3). Specific noise levels (as defined in BS 4142) have then been calculated at the receptors using the vehicle sound power level, number of vehicles per hour, and distance to the top of the service ramp. This follows the methodology set out within Annex F of BS 5228-1 for calculating noise from vehicles using a regular haul road. 6.9.63 The predicted rating noise level for individual HGV movements is presented In Table 6.18. In accordance with BS 4142, daytime assessment is based upon a reference time period of 1 hour. At night, the reference time period is fifteen minutes. Table 6.18 Assessment of individual HGV movements to receptor R1 Time of day Description Day (07:00–23:00)
Night (23:00-07:00)
Predicted rating noise level, dB LAr,Tr
34
28
Background sound level, dB LA90,T
55
50
Difference between background sound level and rating noise level, dB
-21
-28
6.9.64 The assessment of individual HGV movements demonstrates that noise from this source will be reduced to a negligible impact magnitude at R1. The resulting effect is therefore negligible, which is not significant. As R1 is the most noise-affected by this potential source of noise, the effect at other receptors will also be negligible. 6.9.65 Consideration has also been given to the music venue as part of the CoL building refurbishment. At this stage, the music venue forms part of the outline element of the scheme and therefore minimal details are available. To assess impact, the following assumptions have been made: • • • •
Internal reverberant sound levels are assumed to be 105 dB(A). This is in line with the typical ‘full concert’ level for a dedicated live music venue (i.e. concert venue). The building envelope is assumed to be a cavity brick wall with a sound reduction value of Rw 45 dB. The nearest, and therefore most affected, receptor will be R3; approximately 25 m away from the existing CoL building. By controlling sound to this receptor, all other receptors will experience lower impacts. BS 4142 character corrections have been applied on the basis of ‘clearly perceptible’ tonality (+4 dB) and a +3 dB correction for ‘other’ acoustic character.
6.9.66 The predicted rating noise level for music venue noise breakout is presented In Table 6.19. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
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Table 6.19 Assessment of music venue noise breakout to receptor R3 Time of day Description Day (07:00–23:00)
Night (23:00-07:00)
Predicted rating noise level, dB LAr,Tr
60
60
Background sound level, dB LA90,T
55
50
Difference between background sound level and rating noise level, dB
+6
+10
6.9.67 The assessment of music venue noise breakout indicates that noise from this source will result in a medium noise impact at receptor R3. The resulting effect is therefore moderate negative, which is significant. 6.9.68 On the basis of the above, it is expected that, for most commercial activity, suitable noise management plans can be developed to achieve the rating levels set out in Table 6.17. Consequently the magnitude of noise impact from most commercial activities will be low. This will result in a minor negative effect at all receptors, which is not significant. Without mitigation, noise from the music venue could result in moderate negative effects which are significant. Further mitigation will be required as part of the detailed planning application for this element outlining measures taken to reduce noise. Mitigation 6.9.69 Noise associated with commercial activity was assessed on the basis of achieving limiting noise levels at the neighbouring receptors. 6.9.70 There will be a need for noise management plans to be developed by the incoming tenants at a later date. The noise management plan may include a mixture of physical noise control measures as part of the fit-out (incorporating acoustically rated walls, doors, introducing acoustic buffer spaces etc), and management measures (e.g. silent reversing alarms if deliveries occur during the night period).
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6.9.71 Specifically with regard to the music venue, it will be necessary to develop the façade specifications to limit noise break-out to suitably low levels. Based upon the assessments undertaken, it is anticipated that a sound reduction performance in the order of Rw 60 dB will be required but this will need to confirmed through detailed assessment. To achieve this will likely require the blocking up of existing windows (or provision of high performance secondary glazing) and developing acoustic rated wall linings to the existing façade. Consideration should be given to buffer spaces (circulation, toilets etc) against the external walls, and incorporation of lobbied access doors, to minimise noise egress from the venue. It will be necessary to detail ventilation systems to control both plant noise from the fans, but also to account for any music noise break-in to the ductwork system. This will require sound attenuators to be installed within the ductwork. All measures will need to be developed as part of the detailed planning application for this element as the music venue plans are progressed. 6.9.72 The need to prepare noise management plans and implement the necessary physical mitigation can be controlled through the use of a suitably worded planning condition attached to any decision notice for the Proposed Development. Any such condition should enable assessment on a ‘unit by unit’ basis to allow for staggered tenancies. Residual Effect 6.9.73 On the basis that noise management plans are developed, and that the mitigation identified therein is implemented to control noise to limiting levels secured by planning condition, the residual effect is considered to be minor negative at all receptors which is not significant. Site suitability Internal sound levels within apartments 6.9.74 The level of external noise incident upon the Proposed Development has been predicted using Datakustik’s CadnaA software, calibrated against the baseline noise survey. These predictions have been used to determine the level of sound reduction that needs to be achieved by the building façade. 6.9.75 Outline elements of the Proposed Development are included within the model based upon the Maximum Parameters as a worst-case assessment. Detailed elements of the Proposed Development (Phase 1A) are based upon the detailed included within this planning application. 6.9.76 Figures 6.2 and 6.3 shows example output from the acoustic model, showing the level of noise that is experienced across different elevations of the Site. Additional images are provided in Appendix 6.1.
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Figure 6.2 Example noise model output: Daytime LAeq (Max parameters + Detailed plots)
Figure 6.3 Example noise model output: Night time LAFmax (Max parameters + Detailed plots)
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6.9.77 The highest average day and nighttime ambient sound levels (LAeq,T) and maximum sound levels (LAfmax), and the calculated level of façade sound reduction required to control external noise to appropriate internal sound levels, are provided in Table 6.20. Table 6.20: Notional façade sound insulation performance requirements in noisiest parts of the Site Period
Parameter
Predicted external noise level, dB
Proposed internal sound level dB
Composite sound reduction index of façade, dB Rw
Day time (07:00 – 23:00)
LAeq,16hr
68
35
38
Night (23:00 – 07:00)
LAeq,8hr
65
30
40
LAfmax
83
45
43
6.9.78 The requirements for façade sound insulation are driven by the need to control maximum sound levels during the night period. 6.9.79 Although the requirements are onerous in the most noise exposed parts of the site, they can be achieved with high performance commercially available acoustic double glazing systems, in combination with a suitably specified external wall construction (whether ‘lightweight’ or masonry). The detailed acoustic specification of facades will be subject to further optimisation post planning The above noted ratings are illustrative of likely order of performance to control noise to suitable standards for rest and sleep. 6.9.80 In parts of the Proposed Development exposed to lower noise levels, there will be opportunity to specify lower acoustic performance requirements. 6.9.81 Based upon the predicted external noise levels, alternative means of ventilation will be required to provide background ventilation rates in line with Part F of the Building Regulations. Current provision is for MVHR units throughout the Proposed Development. 6.9.82 On the basis that the façade and ventilation system can be designed to achieve suitable internal sound levels during the day and night even on the noisiest parts of the site, the site is considered suitable for residential development. Other uses, such as retail or music venue spaces, will have less stringent requirements than the residential dwellings, and suitable internal conditions will be achievable with façade systems having lower acoustic performance (notwithstanding the need to control noise breakout from the music venue).
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6.9.83 It should be noted that further consideration will need to be given post-planning to controlling noise ingress from the Alpha Lounge to residential dwellings. Noise from this source was not captured during the baseline sound survey, however it is understood that there have been noise complaints from loud music late at night. In developing the façade specifications for the detailed plots (building N1 and N2) post-planning, additional survey measurements will be required during times when the Alpha Lounge is known to be operating so that façade specifications can be suitably developed to control noise to suitable levels. It is anticipated that this can be achieved through the use of enhanced specification acoustic glazing locally within the affected apartments. The need to undertake further detailed assessments can be secured by planning condition. Noise and overheating 6.9.84 Consideration has been given to the implications of external noise should an open window be relied upon to assist with control of heat build-up. 6.9.85 Based upon the results of the 3D modelling exercise, there will be parts of the Site which would require very small window openings to comply with the acoustic requirements of Approved Document O if relying on opening windows. Where larger openings are required, alternative means to provide relief from overheating will need to be considered when developing the detailed design. 6.9.86 The introduction of passive measures, such as external blinds and glazing designed to reduce solar gains, will help to reduce overheating at source, minimising the amount of time that occupants would be exposed to higher heat or noise levels. 6.9.87 Allowance has been made within the Illustrative Scheme to introduce mechanical cooling to affected apartments in the noisiest parts of the site to enable the combined overheating and acoustic requirements of Approved Document O to be achieved. The precise means through which this cooling solution will be delivered will be finalised as part of the detailed design, and will seek to minimise energy demand. For the outline elements of the Proposed Development, this will require further assessment at the detailed design stage. 6.9.88 There will be some areas away from the main roads, where a natural cooling strategy by means of simple opening windows, may be appropriate. This will be subject to further development post planning to determine areas where alternative means can be avoided. External amenity noise levels 6.9.89 It was recognised in paragraph 6.4.58 that the proximity of the Proposed Development to the wider transport network will mean that achieving external noise levels in line with BS 8233 will not be possible on private balconies. This is commonly the case in built up urban areas. Therefore, the assessment was focused on the identification of alternative quiet external amenity areas that residents can access within the site. 6.9.90 There are two large public realm spaces; one at ground level between Lewisham House and plots N1 and N2 (the Northern Square), and the roof of the Service Deck at Level 02. Within the Maximum Parameters noise model, it is demonstrated that noise levels throughout large parts of these amenity spaces will be less than 50 dB LAeq,16hr and will therefore be in line with, or quieter than, the BS 8233 desirable noise levels. It has, however, been explained that the maximum parameter model potential offers more acoustic screening due to increased building massing. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
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6.9.91 To provide a more conservative assessment, with less acoustic screening, an assessment of the Illustrative Scheme has also been undertaken. The predicted noise levels within the external amenity spaces are presented in Figure 6.4 and it can be seen that the majority of publicly accessible external amenity space at podium and ground level will be quieter than the BS 8233 guidance sound levels. There will be some areas close to the main access points in and out of the Site that will be slightly higher. However, these are relatively small in comparison to the areas falling within the BS 8233 guidelines.
Figure 6.4 Environmental sound levels in external amenity areas (Illustrative scheme model)
6.9.92 On the basis of this assessment, it is considered that it will be possible to provide suitable alternative external amenity space within the Proposed Development in terms of noise. The space will be accessible to all future residents of the Proposed Development. Therefore, the site is suitable for it’s intended use in terms of external amenity noise. 6.9.93 Furthermore, the landscaping design proposes extensive green space with meadow planting. This can be expected to offer a positive soundscape within the amenity areas for people’s enjoyment and wellbeing.
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6.10 Limitation and Assumptions Demolition and Construction phase 6.10.1 Specific details of construction activities and plant used is not available at this stage. The construction noise assessment assumes that plant and equipment are used for a proportion of the 10 hour working day and are located at the same distance from the noise sensitive receptor for the duration of works. These are illustrative to enable outline assessments to be made and will need to be confirmed at the appropriate time once a Principal Contractor has been appointed. This will identify particular construction activities, and the operating duration throughout the construction programme. 6.10.2 The calculations assume that plant is located at the shortest possible distance to the receiver. This is considered unlikely to occur in practice for long durations and is therefore considered to be a reasonable worst-case scenario. 6.10.3 Assumptions have been made regarding acoustic screening of certain construction activities. Where an activity is likely to be fully screened from the receptor, a 10 dB reduction has been assumed. For a partial line of sight screening, a 5 dB reduction has been assumed in line with BS 5228 guidance. 6.10.4 Some receptors, specifically R6 and R8, are located at very small distances from the Proposed Development, less than 5 m. Accurately predicting noise at such small distances is difficult. Specialist care and attention will be needed when these demolition and construction activities are taking place in proximity of receptor R6 and R8. Appropriate construction techniques and management measures will be needed to mitigate, and minimise as best as practicable, the impact upon the receptor. 6.10.5 The construction road traffic noise assessment is dependent upon the traffic data provided by the Transport Consultant (SLR), and any assumptions or limitations of that work will be carried forward into the noise assessment. Operational phase 6.10.6 As with the construction assessment, the operational road traffic noise assessment is dependent upon the traffic data provided by the Transport Consultant, and any assumptions or limitations of that work will be carried forward into the noise assessment. 6.10.7 Details of building services plant are not sufficiently defined to enable a plant noise assessment at this time. There will be a need for further detailed development of the building services noise control strategy post planning. Noise limits are defined, and commentary is provided on the types of mitigation that are likely to be required in order to control noise to these limits. 6.10.8 A similar limitation exists with regard to noise from commercial units. Noise limits have been defined which will need to be adhered to by future incoming tenants. Commentary is provided on the types of activity that might reasonably be expected. However, there will be a need for further detailed noise assessments by future tenants on a unit-by-unit basis, relative to their intended use.
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Site suitability 6.10.9 The baseline surveys, whilst extensive, do not appear to have captured specific noise from the Alpha Lounge. However, it is understood that there have been historic noise complaints with regard to this source and so it is acknowledged that this risk ought to be explored further. Additional surveys will be required in developing the façade designs at the detailed design stage to ensure that this source is properly quantified and accounted for within the design. It is, however, expected that noise can be suitably reduced through appropriate acoustic specification of the building envelope. The need for such a detailed assessment can be secured by planning condition.
6.11 Cumulative Effects 6.11.1 This section considers the likely cumulative effects that could arise from the Proposed Development when considered alongside other committed development schemes proximate to the Site. It identifies whether effects from several developments which individually may be insignificant could, when considered together, cause significant cumulative effects requiring mitigation. 6.11.2 A number of committed developments have been identified as being relevant to this assessment. These were identified through a review of LBL’s planning portal and have been agreed with LBL (Figure 2.1). 6.11.3 The assessment is based on the best available information and draws on the assessments included in the ES and Application Reports that accompany the development applications, where available. 6.11.4 Of the listed schemes, the Lewisham Market (DC/24/136236) development is relevant to the Proposed Development in terms of noise. All other cumulative schemes are located more than 300 m away or now part of the baseline. As such, each scheme will have local sensitive receptors to which noise will need to be controlled; limiting cumulative effects. Demolition and Construction Phase Assessment 6.11.5 Although specific programme details are unknown, this application has already been approved. As a lightweight structure, it is also considered that construction techniques will vary significantly such that there will not be a simple additive cumulative effect in terms of noise or vibration. Again, it is therefore considered unlikely that cumulative effects are likely to occur. 6.11.6 Cumulative noise and vibration effects during the demolition and construction stage therefore remain as described in paragraph 6.9.19 and 6.9.28. Mitigation, Monitoring and Residual Effects 6.11.7 Significant cumulative effects are not anticipated to occur. Therefore, mitigation will be as described for the demolition and construction noise and vibration assessments.
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Operational Phase Assessment Operational road traffic noise 6.11.8 The assessment of changes in noise due to operational road traffic considers the relative change between the future baseline scenario with, and without, the Proposed Development in place. The future baseline flows provided by the Transport Consultant takes into account the road traffic due to cumulative schemes in both scenarios. Cumulative effects are therefore inherently considered within the noise assessment and the effects are as previously described. Noise from building services plant 6.11.9 Noise from building services plant will need to be controlled to the nearest receptors by both the Proposed Development and the cumulative schemes. 6.11.10 The Proposed Development and the Lewisham Market scheme share common receptors (R4-R8). Rating noise limits are likely to be set to a level 5 dB lower than the prevailing sound levels for both developments. 6.11.11 If the two developments are both designed to this degree, the combined rating level would be 2 dB lower than the prevailing background sound at the nearest common receptor. Theoretically, this would result in a low impact magnitude, and consequently a Minor Negative effect at receptors R4-R8, which is not significant. Noise from commercial units 6.11.12 The main source of commercial unit noise common to both the Proposed Development and the cumulative scheme is likely to be building services plant which has been discussed above. 6.11.13 For other sources of commercial noise, it is difficult to quantify a cumulative effect. In qualitative terms, commercial units associated with both sites will have different uses and therefore different types of sound associated with them which do not simply ‘add up’ to provide a combined effect. In practice, noise from Lewisham Market already forms part of the baseline conditions around the Site, and is therefore already considered within the assessment. 6.11.14 Regardless, commercial units from both sites will need to implement control measures to reduce the effects of commercial unit noise on sensitive receptors. This will reduce the likelihood of significant cumulative effects occurring. Mitigation, Monitoring and Residual Effects 6.11.15 Significant cumulative effects are not anticipated to occur. Therefore, mitigation will be as described for the various operational phase noise assessments.
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6.12 Climate change 6.12.1 Consideration has been given to the implications of climate change upon the Proposed Development with respect to noise and vibration. 6.12.2 A practical implication of climate change is that the potential for warmer weather may result in an increased reliance upon openable windows to provide relief of heat build-up in future. As discussed earlier within the chapter, the most noise affected parts of the site will be provided with alternative means of providing heat relief; avoiding the need to rely upon opening the windows. 6.12.3 Any future design of alternative means of controlling overheating will need to be informed by an overheating assessment based upon an appropriate future design year.
6.13 Summary 6.13.1 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. 6.13.2 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. 6.13.3 Following the implementation of appropriate mitigation measures, no significant residual effects have been identified. 6.13.4 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 presented in Table 6.21.
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Table 6.21: Summary of Effects DESCRIPTION RECEPTO SIGNIFICANCE OF EFFECTS OF R SIGNIFICANT MAJOR / POSITIVE / P / D / I ST / EFFECTS MODERATE NEGATIVE T MT / / MINOR / LT NEGLIGIBLE Demolition & Construction Timeslice 1 (R11 not applicable during Timeslice 1) Noise from R1-R4, R10 Negligible Negligible demolition and construction R5, R6, R9 Minor Negative activity R7, R8 Moderate Negative Vibration from demolition and construction activity Construction traffic Timeslice 2 Noise from demolition and construction activity
Vibration from demolition and construction activity Construction traffic
SUMMARY OF MITIGATION / ENHANCEMENT MEASURES
SIGNIFICANCE OF RESIDUAL RELEVANT RELEVANT EFFECTS POLICY LEGISLATIO N MAJOR / POSITIV P / D / I ST / MODERATE E / T MT / / MINOR / NEGATIV LT NEGLIGIBLE E
T
D
ST/MT
Negligible
Negligible T
D
T
D
ST/MT
Minor
Negative T
D
T
D
Minor
Negative T
D
Minor
Negative T
D
Minor
Negative T
D
R1-R6, R9, Minor R10 R7, R8 Moderate
Negative
T
D
Negative
T
D
ST/MT Implementation of BPM set out within a CEMP ST/MT and secured by planning condition ST/MT
All receptors
Negligible
Negligible
T
D
ST/MT
Negligible
Negligible T
D
R3, R5, R7 Negligible
Negligible
T
D
ST/MT
Negligible
Negligible T
D
R1,R2,R4, Minor R8,R9,R10 R6, R11 Moderate
Negative
T
D
ST/MT
Minor
Negative T
D
Negative
T
D
Minor
Negative T
D
R1-R5, R7-R10 R6, R11
Minor
Negative
T
D
Minor
Negative T
D
Moderate
Negative
T
D
ST/MT Implementation of BPM set out within a CEMP ST/MT and secured by planning condition ST/MT
Minor
Negative T
D
All receptors
Negligible
Negligible
T
D
ST/MT
Negligible
Negligible T
D
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ST/ MT ST/ MT ST/ MT ST/ MT ST/ MT ST/ MT
CoPA
ST/ MT ST/ MT ST/ MT ST/ MT ST/ MT ST/ MT
CoPA
CoPA CoPA CoPA CoPA CoPA
CoPA CoPA CoPA CoPA CoPA
Operation Changes in All noise receptors associated with operational road traffic
Negligible
Negligible
P
D
LT
None
Noise from All building services receptors plant
Minor
Negative
P
D
LT
Enforcing condition Minor requiring plant noise limits to be achieved. Condition should enable discharge on a plot by plot basis as appropriate.
Noise from operational activity
All receptors
Minor (generally)
Negative
P
D
LT
Moderate (noise breakout from music venue)
Site suitability – R11 achieving suitable internal sound levels within apartments
Site suitable for residential development (subject to detailed design)
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Negligible
Design post planning to incorporate suitable noise control measures to achieve the agreed limits. Enforcing condition Minor requiring further detailed assessments on a plot by plot basis as necessary.
Negligible P
D
LT
Negative P
D
LT
Negative P
D
LT
London Plan D13, Lewisham policy DM26 / Draft policy QD8
-
-
London Plan D13, Lewisham policy DM26 / Draft policy QD8
Design post planning to incorporate suitable noise control measures to achieve the agreed limits.
-
-
-
Noise management plans to be developed by operator(s). Enforcing condition Site suitable requiring appropriate for internal sound levels to residential be achieved. development (subject to Detailed design post detailed planning to incorporate design) Plowman Craven 46730 October 2024
-
London Plan D13, Lewisham policy DM26 / Draft policy QD8 London Plan D13, Lewisham policy DM26 / Draft policy QD8
Site suitability – R11 noise and overheating
Site suitable for residential development (subject to detailed design)
-
-
-
Site suitability – R11 external amenity
Site suitable for residential development (subject to detailed design)
-
-
-
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suitable noise control measures into the building envelope design to achieve the agreed limits. Alternative means of cooling to be provided in parts of the Proposed Development where opening windows will result in noise levels exceeding ADO. External sound levels in line with BS 8233 guidance can be achieved through large parts of the publicly accessible amenity space.
Site suitable for residential development (subject to detailed design) Site suitable for residential development (subject to detailed design)
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-
-
-
-
-
-
Building Regulations Part O
London Plan D13, Lewisham policy DM26 / Draft policy QD8
6.0 References Ref 6.1 Environmental Protection Act 1990. Available at:www.legislation.gov.uk/ukpga/1990/43, Accessed 24th September 2024 Ref 6.2 Control of Pollution Act 1974. Available at: www.legislation.gov.uk/ukpga/1974/40, Accessed 24th September 2024 Ref 6.3 Noise at Work Regulations 2005. Available at: www.legislation.gov.uk/uksi/2005/1643, Accessed 24th September 2024 Ref 6.4 Ministry of Housing, Communities and Local Government (2023) National Planning Policy Framework. Available at: https://www.gov.uk/government/publications/national-planning-policyframework--2, Accessed: 24th September 2024 Ref 6.5 Department for Environment, Food & Rural Affairs (2010) Noise Policy Statement for England. Available at: https://www.gov.uk/government/publications/noise-policy-statement-forengland, Accessed 24th September 2024 Ref 6.6 Ministry of Housing, Communities and Local Government (2019) Planning Practice Guidance – Noise. Available at: https://www.gov.uk/guidance/noise–2, Accessed 24th September 2024 Ref 6.7 Greater London Authority (2021) The London Plan 2021. Ref 6.8 Greater London Authority (2014) Sustainable Design and Construction Supplementary Planning Guidance. Ref 6.9 London Borough of Lewisham (2011) Core Strategy. Ref 6.10 London Borough of Lewisham (2013) Site Allocations. Ref 6.11 London Borough of Lewisham (2014) Development Management Local Plan. Ref 6.12 London Borough of Lewisham (2014) Town Centre Local Plan. Ref 6.13 London Borough of Lewisham (2021) Draft Lewisham Local Plan Regulation 18 Stage. Available at: https://consultation.lewisham.gov.uk/planning/lewisham-local-plan-regulation-18public-consultat/supporting_documents/LEWISHAM%20LOCAL%20PLAN_accessible.pdf Accessed: 24th September 2024 Ref 6.14 British Standards Institution (BSI) (2009) BS 5228-1:2009+A1:2014 Code of practice for noise and vibration control on construction and open sites – Part 1: Noise. London: BSI Ref 6.15 British Standards Institution (BSI) (2009). BS 5228-2:2009 Code of practice for noise and vibration control on construction and open sites – Part 2: Vibration. London: BSI. Ref 6.16 London Borough of Lewisham (2022) Good practice guide control of pollution and noise from demolition and construction sites. Ref 6.17 British Standards Institution (BSI) (2008) BS 6472-1:2008 Guide to evaluation of human exposure to vibration in buildings – Part 1: Vibration sources other than blasting. London: BSI. Ref 6.18 British Standards Institution (BSI) (2014) BS 8233:2014 Guidance on sound insulation and noise reduction for buildings. London: BSI. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 6: Noise and Vibration
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Ref 6.19 World Health Organization (WHO) (1999) Guidelines for Community Noise. Geneva: WHO. Ref 6.20 British Standards Institution (BSI) (2019) BS 4142:2014+A1:2019 Methods for rating and assessing industrial and commercial sound. London: BSI. Ref 6.21 Association of Noise Consultants (2020) BS 4142:2014+A1:2019 Technical Note Available at: https://www.association-of-noise-consultants.co.uk/bs-4142-guidance/ Accessed: 24 September 2024 Ref 6.22 World Health Organization (WHO) (2009) Night Noise Guidelines for Europe. Geneva: WHO Ref 6.23 World Health Organization (WHO) (2018). Environmental Noise Guidelines for the European Region. Geneva: WHO Ref 6.24 Institute of Acoustics (IOA) (2017) ProPG: Professional Practice Guidance on Planning & Noise Ref 6.25 HM Government (2022) Approved Document O: Overheating Ref 6.26 Acoustics and Noise Consultants (ANC) (2022) Guide to Demonstrating Compliance with the Noise Requirements of Approved Document O Ref 6.27 Institute of Acoustics and Association of Noise Consultants (IoA/ANC) (2020) Acoustics, Ventilation and Overheating: Residential Design Guide Ref 6.28 Department for Transport (1988) Calculation of Road Traffic Noise (CRTN). Ref 6.29 Highways England (2019) Design Manual for Roads and Bridges (DMRB) LA111 Noise and Vibration Ref 6.30 Joint Research Centre, Institute for Health and Consumer Protection (2012) Common noise assessment methods in Europe (CNOSSOS-EU) Publications Office Available at https://data.europa.eu/doi/10.2788/32029 Accessed: 24th September 2024 Ref 6.31 European Parliament and Council (2002) Directive 2002/49/EC relating to the assessment and management of environmental noise. Available at: https://eur-lex.europa.eu/legalcontent/EN/TXT/?uri=CELEX%3A32002L0049 Accessed 24th September 2024 Ref 6.32 Institute of Environmental Management and Assessment (IEMA). (2016). Guidelines for Environmental Impact Assessment. Lincoln: IEMA Ref 6.33 London Borough of Lewisham (2022), Preparing a noise assessment for a planning application. Available at https://lewisham.gov.uk/myservices/environment/pollution-information-fordevelopers-and-businesses/pollution-information-planning-applications/preparing-a-noiseassessment-for-a-planning-application Accessed 24th September 2024
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7.0 Air Quality 7.1
Introduction
7.1.1 This Chapter reports the likely significant effects of the Proposed Development on the Site and the surrounding area in terms of air quality matters. Where appropriate, it also identifies proposed mitigation measures to prevent, minimise or control likely negative effects arising from the Proposed Development and the subsequent anticipated residual effects. 7.1.2 The effects of the Proposed Development are considered over the demolition & construction and operational phases. 7.1.3 The main air quality issues covered in this Chapter include the following: • • • • •
Fugitive dust emissions from construction activities affecting amenity. Emissions of nitrogen oxide (NOx) and particulate matter (PM10 and PM2.5) from construction phase non-road mobile machinery (NRMM) affecting local air quality at existing receptors. Emissions of NOx, PM10 and PM2.5 from construction traffic affecting local air quality at existing receptors. Emissions of NOx, PM10 and PM2.5 from traffic using nearby roads and subsequent exposure of future site users to poor air quality. An air quality neutral assessment of the Proposed Development has been undertaken in accordance with the London Plan Policy Air Quality Neutral GuidanceRef 7.1.
7.1.4 This Chapter (and its associated figures and appendices) should be read together with the Introductory Chapters of this ES (Chapters 1 – 5), as well as Chapter 17: Effect Interactions. 7.1.5 This Chapter is accompanied by the following appendices: • • • • • • • • •
Appendix 7.1 – Glossary of terms; Appendix 7.2 – Figures; Appendix 7.3 – IAQM Assessment Methodology; Appendix 7.4 – Traffic Data; Appendix 7.5 – Model Inputs and Verification; Appendix 7.6 – Local Authority Monitoring Data; Appendix 7.7 – Modelled Receptor Locations; Appendix 7.8 – Model Results; and Appendix 7.9 – Air Quality Positive Statement.
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Competence 7.1.6 This assessment has been undertaken by the WSP UK Ltd air quality specialists Natalie Espelid and Dr Saba Manzoor. Natalie Espelid is a Principal Air Quality Consultant with six years of experience in air quality consultancy and is a full member of the Institute of Air Quality Management (IAQM) and the Institution of Environmental Sciences (IES). Natalie has a wider range of experience in environmental consultancy and has undertaken air quality impact assessments for large scale infrastructure projects as well as for commercial, residential and mixed-use developments in support of planning applications and as part of Environmental Impact Assessments (EIAs). 7.1.7 Dr Saba Manzoor is an Associate Consultant with eleven years of experience in air quality consultancy. Saba is also a full member of the IAQM and IES and a Chartered Environmental Scientist. She is skilled in conducting air quality assessments as part of EIAs for large-scale industrial, and infrastructure projects, plus other major schemes in the UK, Europe, and the Middle East. For a number of these projects, Saba also supported the environmental permits and approvals process.
7.2
Legislation, Planning Policy and Guidance
7.2.1 The following national, regional and local planning policy and guidance is of relevance to the assessment of the effects of the Proposed Development in relation to air quality.
Legislative Context 7.2.2 The following national legislation is of relevance to the Proposed Development: Environmental Protection Act (1990) 7.2.3 Section 79 of the Environmental Protection ActRef 7.2Ref 7.2 gives the following definitions of statutory nuisance relevant to dust and particles: “Any dust, steam, smell or other effluvia arising from industrial, trade or business premises or smoke, fumes or gases emitted from premises so as to be prejudicial to health or a nuisance”; and “Any accumulation or deposit which is prejudicial to health or a nuisance.” 7.2.4 Following this, Section 80 states that where a statutory nuisance is shown to exist, the local authority, in this case the London Borough of Lewisham (LBL), must serve an abatement notice. Failure to comply with an abatement notice is an offence and if necessary, the local authority may abate the nuisance and recover the expenses. 7.2.5 Statutory nuisance provisions are relevant to (amongst other things) the control of dust from demolition and construction. There are no statutory limit values for dust above which ‘nuisance’ is deemed to exist. Nuisance is a subjective concept, and its perception is highly dependent upon the existing conditions and the change which has occurred. The party responsible for the premises giving rise to the emissions is responsible for ensuring use of the Best Practicable Means to avoid a statutory nuisance. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 7: Air Quality
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Environment Act (1995) 7.2.6 Part IV of the Environment Act 1995Ref 7.3 required the Secretary of State to publish a national Air Quality Strategy (AQS) and set up a system of Local Air Quality Management (LAQM). The Environment Act 2021 was subsequently enshrined into law in November 2021Ref 7.4. Schedule 11 of this Act makes it clear that it remains a requirement for local authorities to periodically review and document local air quality within their area with the aim of meeting the air quality objectives defined in the Air Quality Regulations. Where the AQS objectives are not likely to be achieved, a local authority is required to designate an Air Quality Management Area (AQMA) and draw up an Air Quality Action Plan (AQAP) to secure improvements in air quality. Environment Act (2021) 7.2.7 The Environment ActRef 7.5 passed into law in November 2021. This Act sets a legally binding duty on the Secretary of State to bring forward air quality targets into secondary legislation; with specific regard to the annual mean level of PM2.5 in ambient air. 7.2.8 In March 2022 and in response to this duty, the UK government proposed a legally binding target to reduce PM2.5 concentrations across England to 10µg/m3 and achieve a 35% reduction of population exposure by 2040. In addition to these targets, the government has published, as part of the Environmental Improvement Plan 2023, two new interim targets aimed at reducing population exposure to PM2.5 by 22% (compared to 2018 levels) and reducing annual mean concentrations to 12µg/m3 by the end of January 2028. 7.2.9 Schedule 11 of the Environment Act 2021 also provides amendments to the Environment Act 1995 regarding the duty of the Secretary of State to report on air quality in England as well as the functions and duties of relevant public authorities including, but not limited to, the duty of a local authority to prepare an action plan for an AQMA “…for the purpose of securing that air quality standards and objectives are achieved…” 7.2.10 Under the Environment Act 2021, the Office for Environmental Protection was formed in order to perform the role of an objective and impartial environmental watchdog in the UK. Previously this role was held by the European Commission. Air Quality Regulations 7.2.11 The Air Quality (England) Regulations 2000Ref 7.5 and the Air Quality (England) (Amendment) Regulations 2002Ref 7.6 set objectives for ambient pollutant concentrations. The objective for human health applies where there is relevant exposure: “…at locations which are situated outside of buildings or other natural or man-made structures, above or below ground, and where members of the public are regularly present…”. 7.2.12 The Air Quality Standards Regulations 2010Ref 7.7, the Air Quality (Amendment of Domestic Regulations) (EU Exit) Regulations 2019Ref 7.8 and the Environment (Miscellaneous Amendments) (EU Exit) Regulations 2020Ref 7.9 set legally binding limit values for concentrations in outdoor air of major air pollutants that impact public health such as PM 10, PM2.5 and NO2. The limit values are numerically the same as the objectives.
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7.2.13 The Environmental Targets (Fine Particulate Matter) (England) Regulations 2023Ref 7.10 enact new long-term targets for PM2.5, aiming to combat air pollution and safeguard public health. These regulations outline the following objectives: •
•
Annual Mean Concentration Target: By 2040, achieve of a maximum annual mean concentration of 10µg/m3 of PM2.5 across England. This target sets a clear benchmark for air quality improvement, ensuring that the air we breathe meets stringent standards for particulate matter. Population Exposure Reduction Target: Aim for a substantial 35% reduction in population exposure to PM2.5 by 2040, compared to a base year of 2018. This reduction target emphasises the importance of minimising the health risks associated with prolonged exposure to fine particulate matter, thereby enhancing the well-being of communities nationwide.
7.2.14 By implementing these targets, policymakers are taking proactive measures to address the adverse effects of air pollution on public health and the environment. It’s akin to setting waypoints on a journey towards cleaner air, ensuring that we stay on course to achieve tangible improvements in air quality for generations to come. 7.2.15 The Air Quality Standards in terms of objectives, limit values and targets that are relevant to this assessment are given in Table 7.1. Table 7.1: Relevant air quality standards
Pollutant
Concentration in micrograms per cubic metre (µg/m3)
Measured as
Objective
Nitrogen dioxide (NO2)
40
Annual mean
Limit value not to be exceeded.
200
1-hour (hourly) mean
Not to be exceeded more than 18 times a year.
40
Annual mean
Limit value not to be exceeded.
50
24-hour (daily) mean
Not to be exceeded more than 35 times a year.
20
Annual mean
Limit value not to be exceeded.
12
Annual mean
Interim target concentration not to be exceeded by the end of January 2028.
Particulate matter less than 10 micrometres in diameter (PM10)
Particulate matter less than 2.5 micrometres in diameter (PM2.5)
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Pollutant
Concentration in micrograms per cubic metre (µg/m3)
Measured as
Objective
10
Annual mean
Target concentration not to be exceeded by the end of 2040.
Planning Policy Context National 7.2.16 The following national level policy and guidance documents are of relevance to the Proposed Development: Clean Air Strategy (2019) 7.2.17 The Department for Environment, Food and Rural Affairs (Defra) published the Government’s Clean Air Strategy in 2019Ref 7.12. This sets out measures which aim to reduce emissions from all sources of air pollution, making air healthier to breathe, protecting nature and boosting the economy. The Strategy also provides goals to cut public exposure to airborne particulate matter, as per the recommendation made by the World Health Organisation. 7.2.18 Furthermore, the Strategy confirms that the Government will set new legislation to “create a stronger and more coherent framework for action to tackle air pollution, in line with the risk they pose to public health and the environment, plus new local powers to take action in areas with an air pollution problem. These will support the creation of Clean Air Zones to lower emissions from all sources of air pollution, backed up with clear enforcement mechanism.” New enforcement powers will also be given at a national and local level, across all sectors of society. UK Air Quality Strategy Framework for local authority delivery 7.2.19 The Government’s policy on air quality within England is set out in the AQS for Framework for local authority delivery. The AQS provides a framework for reducing air pollution in the England with the aim of meeting the AQS objectives. Environmental Improvement Plan (2023) 7.2.20 On the 31st January 2023, the UK government published its Environment Improvement PlanRef 7.13 , which constitutes the first review of the 25 Year Environment Plan as required under the Environment Act 2021. Of relevance to air quality within this document is the 25 Year Environmental Plan goal to achieve clean air in the UK by cutting air pollution overall through tackling key sources of emissions and specific hotspots and reducing ammonia emissions. 7.2.21 In addition, the document sets out the following commitments: •
“A legal target to reduce population exposure to PM2.5 by 35% in 2040 compared to 2018 levels, with a new interim target to reduce by 22% by the end of January 2028.
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• • •
Legal concentration limits for a number of other key pollutants. We already meet the majority of these limits including for sulphur dioxide and coarse particulate matter. We are working towards meeting compliance with a 40µg/m3 limit for nitrogen dioxide. A legal target to require a maximum annual mean concentration of 10 micrograms of PM2.5 per cubic metre (µg/m3) by 2040, with a new interim target of 12µg/m3 by the end of January 2028. Legal emission reduction targets for five damaging pollutants by 2030 relative to 2005 levels: o Reduce emissions of nitrogen oxides by 73%. o Reduce emissions of sulphur dioxide by 88%. o Reduce emission of PM2.5 by 46%. o Reduce emissions of ammonia by 16%. o Reduce emissions of non-methane volatile organic compounds by 39%.”
National Planning Policy Framework (2023) 7.2.22 The Government’s overall planning policies for England are described in the National Planning Policy Framework (NPPF)Ref 7.17. The core underpinning principle of the NPPF is the presumption in favour of sustainable development, defined as “…meeting the needs of the present without compromising the ability of future generations to meet their own needs.” 7.2.23 One of the three overarching objectives of the NPPF is that the planning system should “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.” 7.2.24 In relation to air quality, the following paragraphs in the document are relevant to the Proposed Development: •
•
•
•
Paragraph 55, which states “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.” Paragraph 108, which relates to the need to consider transport related issues at the earliest stages of plan making and development proposals, so that “…c) opportunities to promote walking, cycling and public transport use are identified and pursued; d) the environmental impacts of traffic and transport infrastructure can be identified, assessed and taken into account – including appropriate opportunities for avoiding and mitigating any adverse effects, and for net environmental gains...”. Paragraph 109, which states “Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions and improve air quality and public health.”; Paragraph 180, which states “Planning policies and decisions should contribute to and enhance the natural and local environment by: …e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans.”;
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•
•
Paragraph 191, which states “Planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development.”; and, Paragraph 192, which states “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. So far as possible these opportunities should be considered at the planmaking stage, to ensure a strategic approach and limit the need for issues to be reconsidered when determining individual applications. Planning decisions should ensure that any new development in Air Quality Management Areas and Clean Air Zones is consistent with the local air quality action plan.”
Regional London Plan 2021 7.2.25 Policy SI 1 of the London PlanRef 7.14 is the key policy specific to the improvement of air quality within Greater London and it states that: “A Development Plans, through relevant strategic, site-specific and area-based policies, should seek opportunities to identify and deliver further improvements to air quality and should not reduce air quality benefits that result from the Mayor’s or boroughs’ activities to improve air quality. B To tackle poor air quality, protect health and meet legal obligations the following criteria should be addressed: 1) Development proposals should not: a) lead to further deterioration of existing poor air quality b) create any new areas that exceed air quality limits, or delay the date at which compliance will be achieved in areas that are currently in exceedance of legal limits c) create unacceptable risk of high levels of exposure to poor air quality.
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2) In order to meet the requirements in Part 1, as a minimum: a) development proposals must be at least Air Quality Neutral b) development proposals should use design solutions to prevent or minimise increased exposure to existing air pollution and make provision to address local problems of air quality in preference to post-design or retro-fitted mitigation measures c) major development proposals must be submitted with an Air Quality Assessment. Air quality assessments should show how the development will meet the requirements of B1 d) development proposals in Air Quality Focus Areas or that are likely to be used by large numbers of people particularly vulnerable to poor air quality, such as children or older people should demonstrate that design measures have been used to minimise exposure. C Masterplans and development briefs for large-scale development proposals subject to an Environmental Impact Assessment should consider how local air quality can be improved across the area of the proposal as part of an air quality positive approach. To achieve this a statement should be submitted demonstrating: 1) how proposals have considered ways to maximise benefits to local air quality, and 2) what measures or design features will be put in place to reduce exposure to pollution, and how they will achieve this. D In order to reduce the impact on air quality during the construction and demolition phase development proposals must demonstrate how they plan to comply with the Non-Road Mobile Machinery Low Emission Zone and reduce emissions from the demolition and construction of buildings following best practice guidance. E Development proposals should ensure that where emissions need to be reduced to meet the requirements of Air Quality Neutral or to make the impact of development on local air quality acceptable, this is done on-site. Where it can be demonstrated that emissions cannot be further reduced by on-site measures, off-site measures to improve local air quality may be acceptable, provided that equivalent air quality benefits can be demonstrated within the area affected by the development.” 7.2.26 Policy D3 ‘Optimising site capacity through the design-led approach’ is also relevant and says that new development should be designed such that it helps “prevent or mitigate the impacts of noise and poor air quality”. Policy GG3 ‘Creating a healthy city’ is also relevant to air quality and the Proposed Development. This policy requires developers to “seek to improve London’s air quality, reduce public exposure to poor air quality and minimise inequalities in levels of exposure to air pollution.”
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London Environment Strategy (2018) 7.2.27 The London Environment StrategyRef 7.15 was published by the Mayor of London in May 2018 with the aim of ensuring that “London will have the best air quality of any major world city by 2050, going beyond the legal requirements to protect human health and minimise inequalities.” Chapter 4 of this document states that particulate matter (both PM10 and PM2.5) and NO2 remain the two pollutants of specific concern in London and to improve air quality the following actions are required: • • •
“reducing exposure of Londoners to harmful pollution across London – especially in priority locations like schools – and tackling health inequality. achieving legal compliance with UK and EU limits as soon as possible, including by mobilising action from the London boroughs, government and other partners. establishing and achieving new, tighter air quality targets for a cleaner London, meeting the World Health Organization (WHO) health-based guidelines by 2030 by transitioning to a zero emission London.”
7.2.28 Of relevance to the Proposed Development and this assessment are the following policies set out to achieve the Mayor of London’s objectives: • • • • • • •
Policy 4.1.1 “Make sure that London and its communities, particularly the most disadvantaged and those in priority locations, are empowered to reduce their exposure to poor air quality.” Policy 4.1.2 “Improve the understanding of air quality health impacts to better target policies and action.” Policy 4.2.1 “Reduce emissions from London’s road network by phasing out fossil fuelled vehicles, prioritising action on diesel, and enabling Londoners to switch to more sustainable forms for transport.” Policy 4.2.2 “Reduce emissions from non-road transport sources, including phase out fossil fuels.” Policy 4.2.3 “Reduce emissions from non-transport sources, including by phasing out fossil fuels.” Policy 4.3.2 “The Mayor will encourage the take up of ultra low and zero emission technologies to make sure London’s entire transport system is zero emission by 2050 to further reduce levels of pollution and achieve WHO air quality guidelines.” Policy 4.3.3 “Phase out the use of fossil fuels to heat, cool and maintain London’s buildings, homes and urban spaces, and reduce the impact of building emissions on air quality.”
Local London Borough of Lewisham: Core Strategy (2011) 7.2.29 Adopted in June 2011, the Core StrategyRef 7.16 covers the 15-year period from 2011 to 2026 and includes policies that help LBL to assess all future planning applications. Of relevance to the Proposed Development and air quality is Policy 9 ‘Improving local air quality’ through which the LBL council seeks to improve local air quality and minimise any negative air quality impacts.
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Lewisham Development Management Local Plan (2014) 7.2.30 The Lewisham Development Management Local PlanRef 7.17 sets out the planning policies for managing development in the LBL. These policies are used to guide, assess and determine planning applications. Of relevance to air quality is DM Policy 23 ‘Air Quality’ which states: “The Council will require all major developments that have the potential to impact on air quality to submit an Air Quality Impact Assessment (AQIA) considering the potential impacts of pollution from individual and cumulative development on the site and on neighbouring areas and detailing any appropriate mitigation measures that would reduce exposure to acceptable levels. Applications for planning permission for all new developments that have the potential to impact on air quality in an Air Quality Management Area (AQMA) will not be permitted to include a biomass boiler.” Lewisham Town Centre Local Plan (2014) 7.2.31 The Lewisham town centre local plan development plan documentRef 7.18 was adopted in 2014 and sets out the vision and objectives for regeneration of the town centre. To address the high levels of pollution in the town centre, Objective 7 – Environment 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.” Draft Lewisham Local Plan (Regulation 19 stage) (2023) 7.2.32 In January 2023, the LBL submitted their draft Local PlanRef 7.19 to the Secretary of State for examination. Once adopted the new Local Plan will establish the planning and investment framework from 2020 to 2040 within the administrative area of the LBL. Under the new local plan, of relevance to the Proposed Development and air quality is policy SD6 ‘Improving air quality’. Under this policy “all new development must use the design-led approach and integrate on-site measures to improve air quality and prevent or minimise the population’s exposure to poor air quality, having regard to Lewisham’s Air Quality Management Plan.” In addition, all proposals must: • • • •
“a) Seek to improve air quality and be at least air quality neutral; b) Not lead to a further deterioration of existing poor air quality; c) Not create any new areas that exceed air quality limits, or delay the date at which compliance will be achieved in areas that are currently in exceedance of legal limits; and d) Not create unacceptable risk of high levels of exposure to poor air quality.”
7.2.33 Furthermore, all development proposals must demonstrate how they comply with the NRMM Low Emission Zone requirements and reduce emissions from the demolition and construction of buildings following the Mayor’s ‘The Control of Dust and Emissions during Construction and Demolition’ SPG, 2014Ref 7.28 or subsequent guidance. 7.2.34 Lastly, development proposals will be considered having regard to their individual and cumulative impacts on air quality. Proposals that do not meet the requirements above will be Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 7: Air Quality
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refused “unless it can be suitably demonstrated that adverse impacts can be mitigated to an acceptable level. Mitigation should be provided on-site. In exceptional circumstances where it is demonstrated that on-site mitigation is not feasible, off-site provision may be acceptable where equivalent air quality benefits will be delivered in the area affected by the development.” Guidance 7.2.35 The following guidance documents are of relevance to the Proposed Development: National Planning Practice Guidance (NPPG) (2019) 7.2.36 This guidanceRef 7.17 provides a number of guiding principles on how the planning process can take into account the impact of new development on air quality. It also explains how much detail air quality assessments need to include for proposed developments, and how impacts on air quality can be mitigated. This guidance provides information on how air quality is taken into account by Local Authorities in both the wider planning context of Local Plans and neighbourhood planning, and in individual cases where air quality is a consideration in a planning decision. London Local Air Quality Management Technical Guidance 2019 (LLAQM.TG(19)) 7.2.37 The Mayor of London has issued technical guidanceRef 7.25 for use by the London Boroughs and the LBL in managing local air quality. The guidance, referred to in this document as LLAQM.TG(19), includes procedures that are also relevant to air quality assessments undertaken for new development in London. This guidance has been used where appropriate in the assessment presented herein. Local Air Quality Management Technical Guidance 2022 (LLAQM.TG(22)) 7.2.38 Defra has published technical guidanceRef 7.26 for use by local authorities outside of the London Boroughs in their review and assessment work. This guidance, referred to in this document as LAQM.TG(22), has been used with respect to the methodology used in the assessment of operational phase effects where LLAQM.TG(19) does not include suitable guidance on the approach that should be taken. London Council’s Guidance for Air Quality Assessment (2007) 7.2.39 The London Councils have published guidanceRef 7.27 for undertaking air quality assessments in the London Boroughs, the majority of which have declared AQMAs. The guidance sets out suggested methods for undertaking such an assessment within the London area and provides a methodology to assist in determining the impacts of a development proposal on air quality. The main message of the document is that the factors of greatest importance will generally be the difference in air quality as a result of the proposed development and the potential exposure of occupants of future development to air pollution.
Mayor of London’s Supplementary Planning Guidance for the Control of Dust and Emissions During Construction and Demolition (2014)
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7.2.40 This Supplementary Planning Guidance (SPG)Ref 7.28 builds on the voluntary guidance published in 2006 by the London Councils to establish best practice in mitigating impacts on air quality during demolition and construction works. The SPG incorporates more detailed guidance and best practice and seeks to address emissions from NRMM through the use of a Low Emission Zone, which was introduced in September 2015. 7.2.41 The SPG provides a methodology for assessing the potential impact of demolition and construction activities on air quality following the same procedure as set out in the IAQM Guidance on the assessment of dust from demolition and construction. It then identifies the relevant controls and mitigation measures that should be put in place to minimise any adverse impacts, which need to be set out, in draft, in an air quality assessment report submitted with the planning application, and then formalised post submission as an Air Quality and Dust Management Plan. Details of site air quality monitoring protocols are also provided with varying requirements depending on the size of the site and the potential risk of adverse impacts. IAQM Guidance on the assessment of dust from demolition and construction (2024) 7.2.42 This document published by the IAQMRef 7.29 was produced to provide guidance to developers, consultants and environmental health officers on how to assess the impacts arising from construction activities. The emphasis of the methodology is on classifying sites according to the risk of impacts (in terms of dust nuisance, PM10 impacts on public exposure and impact upon sensitive receptors) and to identify mitigation measures appropriate to the level of risk identified. Environmental Protection UK (EPUK) Land-Use Planning & Development Control: Planning for Air Quality (2017) 7.2.43 The EPUK and the IAQM have published guidanceRef 7.30 that offers comprehensive advice on several aspects: • • • •
when an air quality assessment may be required; what should be included in an assessment; how to determine the significance of any air quality impacts associated with a development; and the possible mitigation measures that may be implemented to minimise these impacts.
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London Plan Guidance: Air Quality Neutral (2023) 7.2.44 In February 2023 the Greater London Authority (GLA) published the London Plan Guidance (LPG) on Air Quality NeutralRef 7.1 which sets new benchmarks for all development to ensure that transport and building emissions do not worsen air quality in London.
7.3
Consultation
7.3.1 As discussed in Chapter 2: Approach to Assessment, the formal EIA Scoping Opinion provided by LBL, as well as any additional consultations that may have occurred during the design period of the Proposed Development, have been considered. Table 7.2: Consultation Feedback
Consultee
Comment
Where is this addressed?
Between the 28 October and 11 November 2021, a request for consultation on the air quality assessment scope and methodology was emailed to the Environmental Protection Manager (EPM) at the LBL.
No response was received from the EPM at the LBL.
N/A
Virtual meeting attended by the WSP air quality specialist at representatives from the LBL and the GLA.
The GLA made the following comments: • •
•
•
A car free development and an all-electric energy strategy is welcome. Consideration would need to be given to the number of emergency generators and the flue locations to determine the level of assessment required. If the Proposed Development, in conjunction with the existing buildings, has the potential to create street canyons, a detailed assessment would potentially be required regardless of the change in traffic flow. A construction dust assessment would be required to inform the mitigation strategy and that it would also be necessary to screen, in line with EPUK guidance, the need for a detailed assessment of
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•
•
•
A total of 3 emergency generators are proposed as part of the overall development. These will only operate in case of an emergency and during routine testing. Routine testing will be 30min part load one per month and full load test for 1 hour per year. Therefore, detailed assessment of generators is not considered required. A detailed dispersion modelling assessment, including canyons, has been undertaken for the peak construction year and once the development is operational. This can be found in Section 7.9 Assessment of Effects, Mitigation and Residual Effects. Construction dust assessment and detailed assessment of construction road impacts have been undertaken in Section 7.9 Plowman Craven 46730 October 2024
Consultee
Comment
•
•
•
In February 2024 an updated request for consultation on the air quality assessment scope and methodology was emailed to the Environmental Protection Manager at the LBL.
construction road traffic impacts. The draft Air Quality London Plan guidance for an Air Quality Neutral Assessment would need to be followed and that if the development is not air quality neutral, additional mitigation would be required. It is expected that verification of dispersion models should use existing monitoring data, as well as results of the sitespecific survey, so long as they are robust enough. The air quality assessment should be carried out in line with LLAQM.TG guidance, which requires the annual mean objective to be applied to exposure within amenity areas and that the GLA will expect an assessment of PM2.5 against the 10µg/m3 standard to be included.
The updated request for consultation stated that the draft Air Quality London Plan guidance for an Air Quality Neutral Assessment would no longer be used, but instead the finalised guidance published in February 2023 would be followed.
Where is this addressed?
•
•
•
Assessment of Effects, Mitigation and Residual Effects. Air Quality Neutral assessment outlined in Section 7.9 Assessment of Effects, Mitigation and Residual Effects. Verification undertaken using existing monitoring data and site-specific survey as outlined in Appendix 7.5. Predicted PM2.5 concentrations has been assessed against the 10µg/m3 standard where relevant.
N/A
The correspondence requested the EPM’s view on the adoption for use of the IAQM Guidance on the assessment of dust from demolition and construction (version 2.2). Lastly, the correspondence stated that an Air Quality Positive Statement would be prepared in line with the London Plan guidance. No response was received from the EPM at the LBL.
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Consultee
Comment
Where is this addressed?
EIA Scoping Opinion
The approach outlined in the Scoping Report is generally accepted, although some comments have been made as follows:
The assessment includes data from the 2023 Annual Status Report in 7.6 Baseline Conditions and 2022 data has been used for model verification (Appendix 7.5).
The Scoping Report states that ‘data collected in 2020 and 2021 is not considered representative of typical pollution concentrations due to the COVID-19 pandemic and associated travel restrictions imposed in the UK’ and this is agreed with. However, as LBL have since published the 2023 Annual Status Report with data obtained in 2022, the applicant should ensure that this data is used as opposed to the 2019 data.
No odour sources are proposed as part of the Detailed Application. For the outline application, details of any potential restaurants and hot food sites are not available at the time of writing. It is proposed that this will be reviewed during detailed planning stage.
The Applicant is expected to consider the effects of any existing or proposed sources of odour in their design as required. Where the Development is phased, the Applicant should consider the years in which worst-case exposure and worstcase impacts on air quality may arise. Regarding the operational effects assessment, where the potential exists for the emergency generator(s) to operate for more than 18 hours per annum, these should be included in the detailed dispersion modelling assessment unless they can be screened out using the EPUK/IAQM guidance.
The Development is phased, and two time slices have been considered as worst case during the construction phase. These have been assessed in Section 7.9 Assessment of Effects, Mitigation and Residual Effects. Detailed assessment of emergency generators not considered required as will only be operational during service, maintenance and during an emergency. An Air Quality Positive Statement has been prepared and is provided in Appendix 7.9. Full details of all modelling undertaken, assumptions and inputs are outlined in Appendix 7.4 and Appendix 7.5.
It is expected an Air Quality Positive assessment to be submitted n accordance with the ‘London Plan Guidance: Air Quality Positive’ document. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 7: Air Quality
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Consultee
Comment
Where is this addressed?
The ES is to provide a transparent account of the modelling undertaken, all assumptions made and all input data used including datasets used, methodologies (monitoring, modelling and scenarios), meteorological data, background concentrations, traffic data (flows, speed, etc), dispersion model type.
7.4
Assessment Methodology and Significance Criteria
7.4.1 The following section outlines the methodologies applied to identify and assess the potential air quality impacts and likely effects to result from the Proposed Development on sensitive receptors. Scope of the Assessment 7.4.2 An EIA Scoping Report was issued to LBL in January 2024 (Appendix 2.1). LBL’s formal Scoping Opinion was issued in June 2024 (Appendix 2.2). 7.4.3 The following potential effects were scoped into the assessment: • • • •
Fugitive dust emissions from construction activities affecting amenity. Emissions of NOx, PM10 and PM2.5 from construction phase NRMM affecting local air quality at existing receptors. Emissions of NOx, PM10 and PM2.5 from construction traffic affecting local air quality at existing receptors. Emissions of NOx, PM10 and PM2.5 from traffic affecting local air quality at existing and future human receptors.
7.4.4 An air quality neutral assessment the Proposed Development will be undertaken in accordance with the London Plan Policy Air Quality Neutral Guidance.
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Extent of The Study Area Demolition and Construction Phase 7.4.5 The study area for fugitive dust emissions associated with the demolition and construction stages has been defined, based on the methodology provided within the IAQM Construction Dust Guidance 2024 and the Mayor of London’s SPG 2014, as 250m from the Site and within 50m of the route(s) used by construction vehicles on the public highway up to 250m from the Site entrance(s). The study area is illustrated in Figure 1 and Figure 2 in Appendix 7.2. 7.4.6 The extent of the study area for traffic impacts during demolition and construction stages has been defined as 200m from the roads that would be affected by changes in traffic, according to IAQM/EPUK Land-Use Planning Guidance indicative traffic screening criteria for air quality assessment, during construction. The study area is illustrated in Figure 3 in Appendix 7.2. Operational Phase 7.4.7 The extent of the study area for traffic impacts during the operational stage has been defined as 200m from the modelled road network. The study area is illustrated in Figure 3 in Appendix 7.2. Baseline Collection 7.4.8 A desk-based review of information and data in the public domain has been undertaken to determine the baseline (existing) air quality conditions in the vicinity of the Site. The following information has been used to define baseline conditions within 2km of the Proposed Development: • • • • • • • •
Environment Agency’s Public Registers: Installation Permits Ref 7.28; The LBL’s Environmental Permit Register; The LBL’s 2023 Air Quality Annual Status Report Ref 7.29; The LBL’s 2023 Nitrogen Dioxide Diffusion Tube Survey ReportRef 7.30; Spatial data for the LBL’s AQMAs as published by DefraRef 7.31; The London Atmospheric Emissions Inventory (LAEI)Ref 7.32; National forecasts for background pollutant concentrations based on Pollution Climate Mapping (PCM) model data published by DefraRef 7.33; and Multi-Agency Geographic Information for the Countryside (MAGIC) websiteRef 7.34 for locations of statutory designated sites including Sites of Special Scientific Interest (SSSIs), Special Protection Areas (SPAs), Special Areas of Conservation (SACs), Ramsar sites, National and Local Nature Reserves (NNRs and LNRs) and Ancient Woodlands (AWs).
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7.4.9 In addition, over the period from September 2021 to June 2023, WSP undertook a NO2 diffusion tube survey to establish baseline conditions in the vicinity of the Site and help identify any potential constraints to its development. The locations of the site-specific diffusion tube monitoring site are illustrated in Figure 4 in Appendix 7.2. Demolition & Construction Dust Assessment 7.4.10 Dust comprises particles typically in the size range 1 - 75 micrometres (µm) in aerodynamic diameter and is created through the action of crushing and abrasive forces on materials. The larger dust particles fall out of the atmosphere quickly after initial release and therefore tend to be deposited in close proximity to the source of the emission. Dust is therefore unlikely to cause long-term or widespread changes to local air quality. However, its deposition on property and cars can cause ‘soiling’ and discolouration. This may result in complaints of annoyance through amenity loss or perceived damage caused, which is usually temporary. 7.4.11 PM10 (and finer particulate matter) make up relatively small proportions of total dust released and, because of their small size, can be transported by the wind over a wider area. This includes a finer fraction known as PM2.5 (with an aerodynamic diameter of less than 2.5µm). As these particles are at the smaller end of the size range of dust particles, they can be transported by wind over a wider area. PM10 and PM2.5 are small enough to be drawn into the lungs during breathing, which could have a potential impact on health in sensitive individuals. 7.4.12 However, it is worth noting that, according to the IAQM guidance, the majority of fugitive particulate emissions arising from construction sites are expected to relate to the coarser fractions (i.e. PM2.5-10) with just 10-15% expected to comprise PM2.5. The IAQM guidance therefore focusses on PM10 for the purposes of assessment. 7.4.13 An assessment of the likely significant effects on local air quality due to the generation and dispersion of dust and PM10 during the construction stage has been undertaken with reference to: • • •
The Mayor of London’s SPG for the control of dust and emissions during construction and demolition; The available information for this stage of the Proposed Development provided by the Design Team; and Professional judgement and experience.
7.4.14 The Mayor of London’s SPG request a Dust Risk Assessment to be undertaken following the methodology published by the IAQM, which assesses the risk of potential dust and PM 10 impacts from the following forces sources: demolition; earthworks; general construction activities and trackout. It considers the nature and scale of the activities undertaken for each source and the sensitivity of the area to an increase in dust and PM10 levels in order to assign a level of risk. Risks are described in terms of there being a low, medium or high risk of dust impacts. Once the level of risk has been ascertained, then site specific mitigation proportionate to the level of risk is identified, and the significance of residual effects determined. A summary of the IAQM Construction Dust Guidance assessment methodology is provided in Appendix 7.3.
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Construction NRMM assessment 7.4.15 In addition to impacts on local air quality due to on-site construction activities, exhaust emissions from construction NRMM may have an impact on local air quality in the vicinity of the Site. As information on the number and type of NRMM associated with the demolition and construction stage was not available at the time of writing, a qualitative assessment of their impact on local air quality has been undertaken using professional judgement and by considering the following: • • •
The number and type of construction NRMM likely to be generated during the demolition and construction stages of the Proposed Development; The number and proximity of sensitive receptors to the Site; and The likely duration of the demolition and construction stage and the nature of activities undertaken.
Construction Traffic Assessment 7.4.16 In addition to impacts on local air quality due to on-site construction activities, exhaust emissions from construction vehicles and plant may have an impact on local air quality adjacent to the routes used by these vehicles to access the Site and in the vicinity of the Site itself. 7.4.17 A quantitative assessment of the changes in pollutant concentrations due to emissions to air from construction traffic has been undertaken using the (Atmospheric Dispersion Modelling System) ADMS-Roads dispersion model (version 5.0.1.3). This model uses detailed information regarding traffic flows on the local road network, surface roughness, and local meteorological conditions to predict pollutant concentrations at specific receptor locations, as determined by the user. The assessment has focused on impacts arising in the peak construction year which is expected to be 2030. 7.4.18 NO2, PM10 and PM2.5 have been considered in this assessment as road traffic is a major source of these pollutants and their concentrations tend to be close to, or in exceedance of the AQS objectives in urban locations such as the Site. 7.4.19 Meteorological data, such as wind speed and direction, is used by the model to determine pollutant transportation and level of dilution by the wind. Meteroligcal data used in the model was from the London City Airport for 2022. This station is considered to provide representative data for the assessment. 7.4.20 Traffic data for use in the assessment were provided by SLR Consulting, the project Transport Planners. A summary of the traffic data and pollutant emission factors used is the assessment can be found in Appendix 7.4. It includes details of the annual average daily traffic (AADT) flows, vehicle speeds (kph) and the percentage of heavy duty vehicles (HDV) for the local road network in all assessment years considered. 7.4.21 For the construction phase assessment, three scenarios have been modelled, as follows: • 2022 base year (used for model verification and in describing existing baseline conditions); • 2030 without the Proposed Development; and • 2030 with the Proposed Development at the peak of construction.
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7.4.22 Appendix 7.5 provides detailed information on how road traffic emissions have been derived, how the dispersion modelling has been undertaken, and how model outputs have then been processed to determine annual mean concentrations of NO2, PM10 and PM2.5. Appendix 7.5 also provides details on the model verification process. 7.4.23 The number of days with PM10 concentrations exceeding 50µg/m3 was estimated using the relationship with the annual mean concentration described in LLAQM.TG(22). 7.4.24 LAQM.TG(22) advises that exceedances of the 1-hour mean NO2 objective are unlikely to occur where annual mean concentrations are below 60µg/m3. It also provides guidance if either measured or predicted annual mean NO2 concentrations reach or exceed 60µg/m3. 7.4.25 Once processed, the predicted concentrations were compared against the relevant AQS objectives for NO2, PM10 and PM2.5 set out in Table 7.1. Operational Phase (Human Exposure Assessment) 7.4.26 NO2 and PM10 concentrations have been considered in this assessment to determine the potential exposure of future users to poor air quality in the opening year (2036) of the Proposed Development due to (non-development) traffic using the local road network. 7.4.27 A quantitative assessment using the ADMS-Roads dispersion model was carried out to predict annual mean NO2, PM10 and PM2.5 concentrations in the opening year 2036. Modelling details are largely the same as outlined above for construction phase assessment, with further details provided in Appendix 7.5. Air Quality Neutral 7.4.28 The air quality neutral assessment was undertaken in accordance with the London Plan Guidance using the details on the proposed energy and transport strategies supplied by the project Electrical Engineers and Transport Planners respectively. 7.4.29 The Mayor of London’s London Plan Guidance sets new benchmarks for all development to ensure that transport and building emissions do not worsen air quality in London. There are two benchmarks that cover the two main emission sources of air pollution from new developments, and these are: • •
“Building Emissions Benchmark (BEB) – emissions from equipment used to supply heat and energy to the buildings; and Transport Emissions Benchmarks (TEB) – emissions from private vehicles travelling to and from the development.”
7.4.30 Developments that do not exceed these benchmarks (considered separately) would be considered to be ‘air quality neutral’. Developments that exceed the benchmarks would be required to amend the details of the development in the first instance before seeking agreement with the local planning authority to off-set any excess in emissions with on or offsite mitigation measures.
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7.5
Significance Criteria
7.5.1 The assessment of the potential impacts and likely effects as a result of the Proposed Development has taken into account both the Demolition and Construction and Operational phases. The significance level attributed to each effect has been assessed based on the magnitude of change due to the Proposed Development and the sensitivity of the affected receptor/receiving environmental to change, as well as a number of other factors that are outlined in more detail in Chapter 2: Approach to Assessment. 7.5.2 Magnitude of change and the sensitivity of the affected receptor/receiving environmental are both assessed on a scale of high, medium, low and negligible (as shown in Chapter 2: Approach to Assessment). Construction Phase 7.5.3 The IAQM Construction Dust Guidance assessment methodology recommends that significance criteria are only assigned to the identified risk of dust impacts occurring from a construction activity with appropriate mitigation measures in place. With the application of appropriate mitigation measures (proportionate to the identified level of risk, which are typically those considered best practice), significant air quality effects due to construction dust are unlikely. Typical best practice mitigation measures include, but are not limited to, regular site inspections, planning site layout to locate dust causing activities away from receptors where possible, erecting solid screens or barriers, soft strip buildings before demolition and implementing a travel plan. 7.5.4 For the assessment of the impact of exhaust emissions from on-site NRMM on local concentrations of NO2 and particulate matter, the significance of residual effects has been determined qualitatively using professional judgement and the principles outlined in the EPUK/IAQM Land-Use Planning Guidance, which are described below. 7.5.5 The approach provided in the EPUK/IAQM Land-Use Planning Guidance has been used within this assessment to assist in describing the air quality effects of additional emissions from traffic generated by the Proposed Development during peak construction phase. 7.5.6 This guidance recommends that the degree of an impact is described by expressing the magnitude of incremental change in pollution concentration as a proportion of the relevant assessment level and examining this change in the context of the new total concentration and its relationship with the assessment criterion. This is summarised in Table 7.3. Table 7.3: Impact descriptors for individual receptors
Long term average concentration at receptors in assessment year
% change in concentration relative to Air Quality Assessment Level (AQS objective) 1
2.5
6-10
>10
75% or less of AQS
Negligible
Negligible
Slight (minor)
Moderate
76-94% AQS
Negligible
Slight (minor)
Moderate
Moderate
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Long term average concentration at receptors in assessment year
% change in concentration relative to Air Quality Assessment Level (AQS objective) 1
2.5
6-10
>10
95-102% of AQS
Slight (minor)
Moderate
Moderate
Substantial (major)
103-109% of AQS
Moderate
Moderate
Substantial (major)
Substantial (major)
110% or more of AQS
Moderate
Substantial (major)
Substantial (major)
Substantial (major)
Notes: Where the %change in concentrations is <0.5%, the change is described as ‘negligible’ regardless of the concentration. When defining the concentration as a percentage of the AQS objective, ‘without development’ concentration should be used where there is a decrease in pollutant concentration and the ‘with development;’ concentration where there is an increase. Where concentrations increase, the impact is described as adverse, and where it decreases as beneficial.
7.5.7 The EPUK/IAQM Land-Use Planning Guidance notes that the criteria in Table 7.3 should be used to describe impacts at individual receptors. The criteria should be considered as a starting point for assessing the significance of effects, as other factors may also need to be taken into account. The EPUK/IAQM Land-Use Planning Guidance states that the overall significance assessment should be based on professional judgement, considering several factors, including: • • •
The existing and future air quality in the absence of the development; The extent of current and future population exposure to the impacts; and The influence and validity of any assumptions adopted when undertaking the prediction of impacts.
7.5.8 The EPUK/IAQM Land-Use Planning Guidance states that for most road transport related emissions, long-term average concentrations are the most useful for evaluating the impacts. 7.5.9 The guidance does not include criteria for determining the significance of the effect on hourly mean NO2 concentrations or daily mean PM10 concentrations. Therefore, the significance of these will be assessed using professional judgement and considering the principles described above.
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Operational Phase 7.5.10 In considering new exposure to air pollution and the levels of mitigation required within the design of the Proposed Development, reference was made to the Air Pollution Exposure Criteria (APEC) published in the London Councils’ guidance for air quality assessments and shown in Table 7.4. Table 7.4: London Council Air Pollution Exposure Criteria
APEC Level
Applicable Range Annual Mean NO2
A
>5% below national objective
Applicable Range PM10 • •
B
Between 5% below or above national objective
•
•
C
>5% above national objective
• •
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Annual mean: >5% below national objective. 24 hour: >1-day less than national objective. Annual mean: Between 5% above or below national objective. 24 hr: Between 1-day above or below national objective.
Annual mean: >5% above national objective. 24 hr: >1-day more than national objective.
Recommendation
No air quality grounds for refusal; however, mitigation of any emissions should be considered.
May not be sufficient air quality grounds for refusal, however appropriate mitigation must be considered e.g. maximise distance from pollution source, proven ventilation systems, parking considerations, winter gardens, internal layout considered, and internal pollutant emissions minimised. Refusal on air quality grounds should be anticipated, unless the Local Authority has a specific policy enabling such land use and ensure best endeavours to reduce exposure are incorporated. Worker exposure in commercial/industrial land uses should be considered further. Mitigation measures must be presented with air quality assessment, detailing anticipated outcomes of mitigation.
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7.6
Baseline Conditions
7.6.1 This section outlines the existing baseline conditions of the Site. LBL’s review and assessment of air quality 7.6.2 In 2001 and 2013, the LBL declared the Lewisham AQMA and the Crofton Park and Honor Oak Park AQMA, respectively. The Lewisham AQMA encompasses the Site and was declared due to exceedances of the annual mean NO2 and daily mean PM10 AQS objectives. The Crofton Park and Honor Oak Park AQMA, located approximately 1.1km east of the Site, was declared due to exceedances of the annual mean NO2 AQS objective. 7.6.3 As part of its Local Air Quality Management (LAQM) duties, LBL adopted its Air Quality Action Plan (AQAP)Ref 7.40 in 2022. This document details the actions that the council will deliver during the period 2022 to 2027 to “reduce concentrations of pollution, and exposure to pollution” thereby positively impacting the health and quality of life of residents and visitors to the borough. Measures implemented to improve air quality within the borough include, but are not limited to, the following. • • • • • •
Ensuring enforcement of the NRMM air quality policies; Enforcing air quality neutral policies; Ensuring emissions from construction are minimised; Recommendation of ultra-low to zero emission combustion plant for all developments; Ensuring the master planning and redevelopment areas align with Air Quality Positive and Healthy Streets approaches; and Enforcing installation of residential electric charge points on new developments.
Local Emissions Sources 7.6.4 The Site is located in an area where air quality is mainly influenced by emissions from road transport using the local road network, and in particular the A21 Molesworth Street, Lewisham High Road, the A20 Rennel Street, Lewis Gove Street and the A20 Lewisham High Street. 7.6.5 According to the Environment Agency’s public register there are no large installations within 2km of the Site boundary. There are however 21 small installations regulated by the LBL and five small installations regulated by the Royal Borough of Greenwich (RBG) that are within 2km of the Site boundary. These small installations include six petrol stations, one concrete batching plant and 19 dry cleaners. The closest permitted installation is the Lewisham Dry Cleaners located approximately 133m east of the Site boundary on Lee High Road. 7.6.6 Other local sources include combustion plant used to generate heat and power for buildings. The railway line that runs between Ladywell and Lewisham Stations is more than 30m west of the Site. Consequently, if diesel trains use this stretch of track, the associated emissions are not likely to impact upon locations of relevant exposure within the Site. 7.6.7 It is assumed that as part of their operating permits, these facilities will be required to implement appropriate mitigation to prevent and/or minimise releases to air, especially beyond the boundaries of the facilities. Given the distance from the Site and the presence of other buildings between these industrial facilities and the Application Site, it is considered unlikely that they would have a measurable influence on air quality at the Proposed Development. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 7: Air Quality
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Local Authority Monitoring Data 7.6.8 Figure 5 in Appendix 7.2 illustrates that the LBL currently operate 61 diffusion tube monitoring sites within 2km of the Site boundary and two continuous monitoring sites (CMS). Within 2km of the Site there are also five diffusion tube sites and one CMS operated by the RBG. Table A7-6-1 in Appendix 7.6 provides details of all diffusion tube monitoring sites within 2km of the Site, including those operated by the neighbouring RBG. 7.6.9 Table A7-6-1 in Appendix 7.6 shows that in 2022 there were no exceedances of the annual mean NO2 AQS objective of 40µg/m3 recorded at any diffusion tube monitoring location within 2km of the Site. The maximum annual mean NO2 concentration of 33.9µg/m3 was recorded approximately 1.7km northwest of the Site at the roadside site L55. Over the six-year period from 2016 to 2022 inclusive, all diffusion tube monitoring sites have recorded a general decrease in annual mean NO2 concentrations. 7.6.10 With reference to LLAQM.TG(19) as well as LAQM.TG22, where an annual mean NO2 concentration is below 60µg/m3 it is unlikely that there would be an exceedance of the hourly mean AQS objective. Consequently, the hourly mean NO2 concentrations are not likely to have exceeded the hourly mean AQS objective at any of the diffusion tube monitoring locations in 2022. 7.6.11 Table A7-6-1 in Appendix 7.6, shows that in 2022 the maximum annual mean NO2 concentration recorded at CMSs within 2km of the Site was 38.4µg/m3. This was recorded at the roadside site LW4 which is located approximately 300m to the northwest. In 2022 none of the CMSs within 2km of the Site recorded an exceedance of the annual mean AQS objective and annual mean concentrations showed a general improvement (i.e. decrease) since 2016. The hourly mean NO2 concentrations in 2022 were compliant with the AQS objective at all CMSs. 7.6.12 In addition, the LBL and the RBG both operate one CMS within 2km of the Site boundary for the purpose of monitoring PM10 concentrations. Both CMS are representative of roadside sites. Table A7-6-2 in Appendix 7.6 shows that monitored PM10 concentrations at both CMSs were compliant with the relevant AQS objectives in 2022 and have been since 2016. WSP Air Quality Monitoring 7.6.13 On the 6th September 2021 WSP commenced a 22-month site-specific NO2 diffusion tube survey to establish baseline concentrations at the Site and identify any potential constraints to the Proposed Development. The results of the survey have also been used to inform the dispersion model verification strategy; the details of which are provided in Appendix 7.5. 7.6.14 The duration of the diffusion tube survey and location of monitoring sites were discussed and agreed with the Applicant prior to commencement of the survey. Monitoring was carried out at twelve locations, details of which are summarised in Table 7.5. 7.6.15 Table 7.5 shows that over the three-year period from 2021 to 2023 inclusive no exceedances of the annual mean NO2 AQS objective were recorded across the Site.
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Table 7.5: Annual mean NO2 concentrations measured at site-specific monitoring locations
Site ID
X, Y
Site Location
Annual mean NO2 concentration (µg/m3) 2021
2022
2023
LSC01.GF
538234, 175700
Ground floor signpost off the A20, along the north edge of the Site
N/A
32.2
26.3
LSC01.2F
538219, 175680
On the roof of the shopping centre, above LSC.01.GF
24.5
24.2
22.4
LSC02.GF
538144, 175568
Ground floor west stairwell of the shopping centre car park
27.6
28.4
28.8
LSC02.2F
538144, 175568
Second floor west stairwell of the shopping centre park
27.1
27.7
27.9
LSC03.GF
538153, 175391
Ground floor below car park exit ramp
29.9
28.8
28.1
LSC03.1F
538152, 175404
First floor car park ramp, closer to main road, southern end
36.1
29.5
27.5
LSC04.1F
538262, 175454
First floor, roof above TKMaxx store
N/A
N/A
N/A
LSC05.GF
538136, 175475
Ground floor below the car park exit ramp, northern end
30.0
31.9
29.0
LSC05.2F
538138, 175479
Second floor car park exit ramp, closer to the car park exit
37.0
34.7
34.3
LSC06.GF
538208, 175285
Ground floor south of the Probation service office, facing the roundabout
27.4
28.6
29.9
LSC06.2F
538179, 175365
Furthest south of roof past the loading areas
26.1
22.5
21.0
LW4
537912, 175838
Collocated with LW4 continuous monitor
31.5
37.9
39.6
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London Atmospheric Emissions Inventory 7.6.16 The London Atmospheric Emissions Inventory (LAEI) provides predicted annual mean NO2, PM10 and PM2.5 concentrations for 2019 across Greater London up to the M25, at a grid resolution of 20 x 20m. 7.6.17 A review of the most recent data from the LAEI encompassing the Site shows that in 2019 annual mean NO2 concentrations ranged from 27.9µg/m3 to 55.2µg/m3 across the Site. Exceedances of the relevant AQS objectives were predicted to have occurred on the Site boundaries adjacent to the A21 Molesworth Street and the A20 Lewisham High Street. The maximum concentration of 55.2µg/m3 was predicted to have occurred at the north east corner of the Site adjacent to the A20 Lewisham High Street. 7.6.18 According to the LAEI, annual mean concentrations of PM10 predicted across the Site in 2019 ranged from 16.6µg/m3 to 36.0µg/m3 and, therefore, were predicted to meet the annual mean PM10 AQS objective. The maximum concentration of 36.0µg/m3 was predicted to have occurred at the north east corner of the Site adjacent to the A20 Lewisham High Street. 7.6.19 According to the LAEI, annual mean PM2.5 concentrations predicted across the Site in 2019 ranged from 10.7µg/m3 to 15.4µg/m3. The highest concentration occurred at the north east corner of the Site adjacent to the A20 Lewisham High Street. The LAEI data therefore shows that in 2019 there were no exceedances of the annual mean PM2.5 AQS objective (20µg/m3). It is noted that the PM2.5 concentrations across the Site exceed the 2030 target of 10µg/m3. 7.6.20 A review of the LAEI also identified that the Site is located within the Lewisham Loampit Vale and Lewisham High Street Air Quality Focus Area (AQFA). AQFAs are locations that “not only exceed the EU annual mean limit value for NO2 but are also locations with high human exposure.” There are ten AQFAs within 2km of the Site, illustrated in Figure 5 in Appendix 7.2, namely: • • • • • • • • • •
Lewisham Loampit Vale and Lewisham High Street; Deptford Town Centre; New Cross Gate and New Cross; Catford Road and Catford Gyratory; Greenwich Centre; Sun-in-the-Sands junction A102/A2 Shooters Hill and Charlton Road roundabout; Greenwich South Street/Lewisham High Street Junction and Blackheath Hill; Brockley Road (B218) between Adelaide Avenue and Wickham Road; St Mildreds Road (A205) from Hither Green Lane to Burnt Ash Hill (A2212); and Brockley Cross.
Modelled Baseline 7.6.21 As part of the modelling undertaken for the peak construction year, a 2022 current baseline was modelled (i.e. without the Proposed Development). All model results are provided in Appendix 7.8. 7.6.22 The results of the assessment show that in the 2022 baseline case, concentrations exceeded the AQS objective of 40µg/m3 at 6 of the 83 modelled receptor locations. The highest predicted concentration is 44.9µg/m3 at receptor 19_0 (a residential receptor on A20). Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 7: Air Quality
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7.6.23 The results of the assessment show that in the 2022 baseline case, concentrations at all of the receptors considered are predicted to easily meet the annual mean objective for PM10 of 40µg/m3. The highest predicted concentration is 21.9µg/m3 at receptor 11 (Residential apartment on Lewisham Hight Street). 7.6.24 The current annual mean PM2.5 AQS objective is 20µg/m3. The results of the assessment show that in the 2022 baseline case, concentrations at all of the receptors considered are predicted to easily meet the objective. The highest predicted concentration is 13.9µg/m3 at receptor 11 (Residential apartment on Lewisham Hight Street).
7.7
Future Baseline
7.7.1 As part of the modelling undertaken for the peak construction year, a 2030 future baseline was modelled (i.e. without the Proposed Development). For details on modelling methodology and receptors where air quality predictions were made, see 7.9 Assessment Methodology and Significance Criteria. All model results are provided in Appendix 7.8. 7.7.2 For 2030, all concentrations are predicted to be lower than for 2022. Air quality is predicted to improve with time as a consequence of ultra-low/zero emissions technologies replacing older, more polluting technologies in line with observed trends and forecasts by Defra and other London authorities. 7.7.3 Predicted future baseline annual mean NO2 concentrations range from 16.3µg/m3 at receptor 5 (Prendergast Vale School) to 25.9µg/m3 at receptor 19_0 (Residential apartment on A20). These concentrations meet the annual mean NO2 air quality objective. Furthermore, the relatively low predicted annual mean concentrations also indicate that the 1-hour mean NO2 air quality objective is also likely to be met. 7.7.4 Predicted future baseline annual and 24-hour mean PM10 concentrations meet the air quality objectives, respectively, at all receptors. 7.7.5 Predicted future baseline annual mean PM2.5 concentrations exceed the Mayor of London’s target for 2030 of 10µg/m3 at all the receptors due to high background PM2.5 concentrations (ranging between 11.2µg/m3 and11.6µg/m3).
7.8
Sensitive Receptors
7.8.1 Sensitive locations are places where the public or sensitive ecological habitats may be exposed to pollutants resulting from activities associated with the Proposed Development. These would include locations sensitive to an increase in dust deposition and airborne particulate matter exposure as a result of on-site construction activities, locations sensitive to exposure to gaseous pollutants emitted from the exhausts of construction traffic associated with the Proposed Development, and new receptors introduced into the area as a result of the Proposed Development.
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Demolition & Construction Phase 7.8.2 According to the IAQM Construction Dust Guidance, a dust assessment is undertaken where there are: • • • •
Human receptors within 250m of the Site; and/or Human receptors within 50m of the route(s) used by construction vehicles on the public highway, up to 250m from the Site entrance(s); and/or Ecological receptors within 50m of the Site; and/or Ecological receptors within 50m of the route(s) used by construction vehicles on the public highway, up to 250m from the Site entrance(s).
7.8.3 It is within these distances that the impacts of dust soiling and increased particulate matter in the ambient air would have the greatest impact on local air quality at sensitive receptors (Figure 1 and Figure 2 in Appendix 7.2). 7.8.4 In terms of locations that are sensitive to pollutants emitted from engine exhausts, these would include places where members of the public are likely to be regularly present over the period of time of the AQS objective. For instance, on a footpath where exposure to pollutants would be transient (for the duration of passage along that path) comparison with a short-term standard (i.e. 15-minute mean or 1 hour mean) may be relevant. At a school or adjacent to a private dwelling, where exposure to pollutants may be for longer periods, comparison with a long-term standard (such as 24-hour mean or annual mean) may be more appropriate. Box 1.1 of LLAQM.TG(19) and LAQM.TG(22) Table 7.6 provides examples of the locations where the AQS objectives should and should not apply. Table 7.6: Examples of where national AQS objectives should apply
Averaging Period Annual mean
AQS objectives should apply at:
AQS objectives should generally not apply at:
•
•
All locations where members of the public might be regularly exposed. Building facades of residential properties, schools, hospitals, care homes, etc.
• • •
24-hour mean
• •
1-hour mean
• •
All locations where the annual mean AQS objective would apply, together with hotels. Gardens of residential properties. All locations where the annual mean and: 24 and 8-hour mean AQS objective apply. Kerbside sites (for example, pavements of busy shopping streets).
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•
•
Building facades of offices or other places of work where members of the public do not have regular access. Hotels, unless people live there as their permanent residence. Gardens of residential properties. Kerbside sites (as opposed to locations at the building façade), or any other location where public exposure is expected to be short term. Kerbside sites (as opposed to locations at the building façade), or any other location where public exposure is expected to be short term. Kerbside sites where the public would not be expected to have regular access.
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Averaging Period
AQS objectives should apply at: •
•
AQS objectives should generally not apply at:
Those parts of car parks, bus stations and railway stations etc. which are not fully enclosed, where members of the public might reasonably be expected to spend one hour or more. Any outdoor locations where members of the public might reasonably be expected to spend one hour or longer.
7.8.5 In order to complete the assessment of construction stage impacts, a number of ‘receptors’ representative of locations of relevant public exposure have been identified at which pollution concentrations have been predicted. Receptors have been located adjacent to the roads that are likely to experience the greatest change in traffic flows or composition, and therefore NO2 and particulate matter concentrations, as a result of the Proposed Development. 7.8.6 There are no statutory designated ecological receptors within the construction traffic study areas and therefore, they are not considered further within this assessment. 7.8.7 The locations of the construction stage dispersion modelling assessment receptors are summarised in Table 7.7 and illustrated in Figure 6 (shown in Appendix 7.2). Full details of all modelled existing receptor locations are also given in Table A7-7-1 in Appendix 7.7. Receptors have been modelled at 1.5m above ground to represent standard breathing height. To represent receptors at higher floors, receptor points have been included at different heights, but still modelled at 1.5m above the respective floor level. Table 7.7: Construction phase modelled receptor locations
Receptor ID
X
Y
Height above ground level (m)
1
537970.9
174759.3
1.5
2
537906.7
174593.3
1.5
3
537968.9
174910.6
1.5
4
538113.6
174986.1
1.5
5
537927.3
175684.8
1.5
6
538014.3
174887.6
1.5
7
538016.4
174938.9
1.5
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Receptor ID
X
Y
Height above ground level (m)
8
538183.1
175247.4
1.5
9
538207.4
175221.4
4.5
10
538393.5
175601.6
4.5
11
538269.7
175722.8
4.5
12_1
538181.9
175724.6
4.5
13
538477.2
175661.3
1.5
14
538421.8
175591.8
4.5
15
538403.7
175582.9
1.5
16_0
538249.1
175783.3
1.5
17_1
538011.3
175810.0
4.5
18_1
537797.6
175871.5
4.5
19_1
538059.3
175842.0
4.5
20
538065.1
175806.4
1.5
21_1
538151.3
175850.8
4.5
22_1
538161.6
175793.8
4.5
23_1
537903.3
175816.7
4.5
24
537715.4
175945.0
4.5
25
538239.0
175280.0
4.5
26
538270.6
175331.8
1.5
27
538321.9
175453.6
4.5
28
538377.8
175549.6
4.5
29
538119.7
175374.9
1.5
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Receptor ID
X
Y
Height above ground level (m)
30
538084.3
174995.6
1.5
31
537991.8
174928.2
1.5
32
538306.1
175626.9
4.5
12_0
538181.9
175724.6
1.5
17_0
538011.3
175810.0
1.5
18_0
537797.6
175871.5
1.5
19_0
538059.3
175842.0
1.5
21_0
538151.3
175850.8
1.5
22_0
538161.6
175793.8
1.5
23_0
537903.3
175816.7
1.5
12_2
538181.9
175724.6
7.5
17_2
538011.3
175810.0
7.5
18_2
537797.6
175871.5
7.5
19_2
538059.3
175842.0
7.5
21_2
538151.3
175850.8
7.5
22_2
538161.6
175793.8
7.5
23_2
537903.3
175816.7
7.5
12_3
538181.9
175724.6
10.5
17_3
538011.3
175810.0
10.5
18_3
537797.6
175871.5
10.5
19_3
538059.3
175842.0
10.5
21_3
538151.3
175850.8
10.5
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Receptor ID
X
Y
Height above ground level (m)
22_3
538161.6
175793.8
10.5
23_3
537903.3
175816.7
10.5
33
538112.3
175063.8
4.5
34
538132.9
175029.7
1.5
35
538052.1
174954.6
4.5
16_2
538249.1
175783.3
7.5
16_1
538249.1
175783.3
4.5
16_3
538249.1
175783.3
10.5
1_0_Phase 1_B
538198.2
175692.0
1.5
6_0_Phase 1
538210.3
175282.3
1.5
11_0_Phase 1
538298.5
175653.3
1.5
15_0_Phase 1
538257.9
175630.9
1.5
16_0_Phase 1
538256.0
175569.5
1.5
1_1_Phase 1_B
538198.2
175692.0
4.5
6_1_Phase 1
538210.3
175282.3
4.5
11_1_Phase 1
538298.5
175653.3
4.5
15_1_Phase 1
538257.9
175630.9
4.5
16_1_Phase 1
538256.0
175569.5
4.5
1_2_Phase 1_B
538198.2
175692.0
7.5
6_2_Phase 1
538210.3
175282.3
7.5
11_2_Phase 1
538298.5
175653.3
7.5
15_2_Phase 1
538257.9
175630.9
7.5
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Receptor ID
X
Y
Height above ground level (m)
16_2_Phase 1
538256.0
175569.5
7.5
1_3_Phase 1_B
538198.2
175692.0
10.5
6_3_Phase 1
538210.3
175282.3
10.5
11_3_Phase 1
538298.5
175653.3
10.5
15_3_Phase 1
538257.9
175630.9
10.5
16_3_Phase 1
538256.0
175569.5
10.5
Operational Phase 7.8.8 To complete the operational stage exposure assessment, pollution concentrations have also been predicted at a number of locations within the Site. Receptors have been positioned at 1.5m above the respective level of the Proposed Development to represent standard breathing height. 7.8.9 The locations of the assessment receptors are summarised in Table 7.8 and illustrated in Figure 7 (shown in Appendix 7.2). Full details of all modelled future receptor locations are also given in Table A-7-7-2 in Appendix 7.7. Table 7.8: Operational phase modelled receptor locations
Receptor ID
X
Y
Height above ground level (m)
1_0_Phase 2
538198.2
175692.0
1.5
2_0_Phase 2
538155.3
175594.4
1.5
3_0_Phase 2
538137.4
175540.6
1.5
4_0_Phase 2
538137.2
175486.2
1.5
5_0_Phase 2
538142.6
175430.6
1.5
6_0_Phase 2
538210.3
175282.3
1.5
7_0_Phase 2
538177.4
175312.6
1.5
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Receptor ID
X
Y
Height above ground level (m)
8_0_Phase 2
538222.1
175389.8
1.5
9_0_Phase 2
538264.4
175452.8
1.5
10_0_Phase 2
538295.8
175518.6
1.5
11_0_Phase 1
538298.5
175653.3
1.5
17_0_Phase 2
538177.3
175358.3
1.5
14_0_Phase 2
538157.5
175408.7
1.5
15_0_Phase 1
538257.9
175630.9
1.5
16_0_Phase 1
538256.0
175569.5
1.5
1_1_Phase 2
538198.2
175692.0
4.5
2_1_Phase 2
538155.3
175594.4
4.5
3_1_Phase 2
538137.4
175540.6
4.5
4_1_Phase 2
538137.2
175486.2
4.5
5_1_Phase 2
538142.6
175430.6
4.5
6_1_Phase 2
538210.3
175282.3
4.5
7_1_Phase 2
538177.4
175312.6
4.5
8_1_Phase 2
538222.1
175389.8
4.5
9_1_Phase 2
538264.4
175452.8
4.5
10_1_Phase 2
538295.8
175518.6
4.5
11_1_Phase 1
538298.5
175653.3
4.5
17_1_Phase 2
538177.3
175358.3
4.5
14_1_Phase 2
538157.5
175408.7
4.5
15_1_Phase 1
538257.9
175630.9
4.5
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Receptor ID
X
Y
Height above ground level (m)
16_1_Phase 1
538256.0
175569.5
4.5
1_2_Phase 2
538198.2
175692.0
7.5
2_2_Phase 2
538155.3
175594.4
7.5
3_2_Phase 2
538137.4
175540.6
7.5
4_2_Phase 2
538137.2
175486.2
7.5
5_2_Phase 2
538142.6
175430.6
7.5
6_2_Phase 2
538210.3
175282.3
7.5
7_2_Phase 2
538177.4
175312.6
7.5
8_2_Phase 2
538222.1
175389.8
7.5
9_2_Phase 2
538264.4
175452.8
7.5
10_2_Phase 2
538295.8
175518.6
7.5
11_2_Phase 1
538298.5
175653.3
7.5
17_2_Phase 2
538177.3
175358.3
7.5
14_2_Phase 2
538157.5
175408.7
7.5
15_2_Phase 1
538257.9
175630.9
7.5
16_2_Phase 1
538256.0
175569.5
7.5
1_3_Phase 2
538198.2
175692.0
10.5
2_3_Phase 2
538155.3
175594.4
10.5
3_3_Phase 2
538137.4
175540.6
10.5
4_3_Phase 2
538137.2
175486.2
10.5
5_3_Phase 2
538142.6
175430.6
10.5
6_3_Phase 2
538210.3
175282.3
10.5
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Receptor ID
X
Y
Height above ground level (m)
7_3_Phase 2
538177.4
175312.6
10.5
8_3_Phase 2
538222.1
175389.8
10.5
9_3_Phase 2
538264.4
175452.8
10.5
10_3_Phase 2
538295.8
175518.6
10.5
11_3_Phase 1
538298.5
175653.3
10.5
17_3_Phase 2
538177.3
175358.3
10.5
14_3_Phase 2
538157.5
175408.7
10.5
15_3_Phase 1
538257.9
175630.9
10.5
16_3_Phase 1
538256.0
175569.5
10.5
7.9
Assessment of Effects, Mitigation and Residual Effects Demolition & Construction Phase First Effect (Construction Dust Assessment)
7.9.1 This section identifies and assesses the scale and nature of the main effects arising from construction dust emissions from the Proposed Development during its demolition and construction phases. 7.9.2 The demolition and construction period is phased over a 10-year period between 2026 and 2036. For the purpose of assessment of construction dust impacts, two ‘time slices’ have been assessed as follows: • •
2028; and 2030.
7.9.3 Most dust generation is likely to occur during the 'working week'. However, for some activities, like significant earthwork with exposed soil, can potentially generate dust 24/7 if no dust control measures are implemented during the construction period. Potential Dust Emissions Magnitude 7.9.4 The IAQM Construction Dust Guidance assessment methodology has been used to determine the potential dust emission magnitude for four key sources: demolition; earthworks; construction; and trackout.
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7.9.5 At this stage, specific details on the construction of the Proposed Development are not known. As such, the construction assessment has been completed using the information that is available and professional judgement where appropriate. The findings of the assessment are presented below. Demolition 7.9.6 Demolition activities will be required before construction activities can take place. The anticipated volume of buildings to be demolished is estimated to be greater than 75,000m3 and would likely consist of potentially dusty construction material such as concrete. Demolition activities may occur at heights greater than 12m above ground level. Therefore, the potential dust emission magnitude is judged to be ‘large’ for demolition activities during both time slices. Earthworks 7.9.7 The total area of the Site is between 18,000m2 to 110,000m2 and the soil type is loamy. Therefore, the potential dust emission magnitude is ‘medium’ for earthwork activities during both time slices. Construction 7.9.8 The total volume of buildings to be constructed on the Site will be greater than 75,000m3 with potentially dusty construction materials being used (e.g. concrete). Therefore, the potential dust emission magnitude is classed as ‘large’ for construction activities during both time slices. Trackout 7.9.9 Based on the traffic data (provided by the Project Team), there would be more than 50 HDV’s outward movements in any one day. Due to the size of the Site, it is also assumed that the length of unpaved roads within the Site would be greater than 100m. Therefore, the potential dust emission magnitude is classed as ‘large’ for trackout of both time slices. Table 7.9: Potential dust emission magnitude
Activity
Dust Emission Magnitude
Demolition
Large
Earthworks
Medium
Construction
Large
Trackout
Large
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Sensitivity of the Study Area 7.9.10 A windrose generated using 2022 meteorological data for London City airport (located approximately 6km to the northeast shows that the prevailing wind direction is from the southwest (Appendix 7.5). Therefore, receptors located to the northeast of the Site are more likely to be affected by dust and particulate matter emitted and re-suspended during the demolition and construction stage. 7.9.11 Under low wind speed conditions, it is likely that most dust would be deposited in the area immediately surrounding the source. The Site is primarily surrounded by residential apartments, offices and retail premises. 7.9.12 For the first time slice, 2028, the nearest human sensitive receptors are the series of residential apartments along A20 north of the Proposed Development. There are more than 100 of these receptors within 20m of the construction boundary for the first time slice. 7.9.13 For the second time slice, 2030, the nearest human receptors will be the residential homes constructed in phase 1 on plots N1 and N2. There will be more than 100 receptors within 20m of the construction boundary of the second time slice works area. 7.9.14 In accordance with the IAQM guidance, residential receptors have been classed as ‘high sensitivity’ receptors with respect to dust soiling. As there are more than 100 high sensitivity receptors within 20m of the construction boundary, the overall sensitivity of the surrounding to dust soiling is classed as ‘high’ for both time slices. 7.9.15 Similarly, in accordance with the IAQM guidance, as there are more than 100 high sensitivity receptors within 20m of the construction boundary, the overall sensitivity of the surrounding to human health impacts is classed as ‘medium’ for both time slices. 7.9.16 There are no ecological receptors within 250m of the Application Site, therefore the impacts of construction dust on ecological receptors can be scoped out and are not considered further in this assessment. 7.9.17 For trackout (for both dust soiling and human health), there are more than 100 residential receptors within 20m of the construction routes on Lewisham High Street, A20 and Molesworth Street that are anticipated to be used by construction traffic. As such the sensitivity to trackout is ‘high’ for dust soiling and ‘medium’ for human health for both the scenarios. 7.9.18 The sensitivity of the area to changes in dust and particulate matter for each of the construction activities considered is summarised in
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Table 7.10 - Sensitivity of the Study Area Potential Impact
Sensitivity of Surrounding Area Demolition
Earthworks
Construction
Trackout
High
High
High
High
Medium
Medium
Medium
Medium
Dust Soiling Human Health
Risk of Impacts 7.9.19 The predicted dust emission magnitude has been combined with the defined sensitivity of the area to determine the risk of impacts during the construction phase, prior to mitigation. Table 7.11 provides a summary of the risk of dust impacts for the Site. The risk category identified for each construction activity has been used to determine the level of mitigation required. Table 7.11 Summary Risk Table to Define Site Specific Mitigation
Potential Impact
Risk Demolition
Earthworks
Construction
Trackout
Dust Soiling
High Risk
Medium Risk
High Risk
High Risk
Human Health
High Risk
Medium Risk
Medium Risk
Medium Risk
Mitigation 7.9.20 Based on the assessment results, mitigation will be required. Recommended mitigation measures for a high-risk site are given below. General Communication • •
•
A stakeholder communications plan that includes community engagement before work commences on site should be developed and implemented. The name and contact details of person(s) accountable for air quality and dust issues should be displayed on the Site boundary. This may be the environment manager/engineer or the site manager. The head or regional office contact information should also be displayed. A Dust Management Plan (DMP), which may include measures to control other emissions, in addition to the dust and PM10 mitigation measures given in this report, should be developed and implemented, and approved by LBL.
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Site Management •
• •
•
All dust and air quality complaints should be recorded, and causes identified. Appropriate remedial action should be taken in a timely manner with a record kept of actions taken including of any additional measures put in place to avoid reoccurrence. The complaints log should be made available to LBL on request. Any exceptional incidents that cause dust and/or air emissions, either on or offsite should be recorded, and then the action taken to resolve the situation recorded in the logbook. Regular liaison meetings with other high risk construction sites within 500m of the Site should be held, to ensure plans are co-ordinated and dust and particulate matter emissions are minimised. It is important to understand the interactions of the off-site transport/deliveries which might be using the same strategic road network routes.
Monitoring •
•
•
•
Daily onsite and offsite inspections should be undertaken, where receptors (including roads) are nearby to monitor dust. The inspection results should be recorded and made available to LBL when asked. This should include regular dust soiling checks of surfaces such as street furniture, cars and windowsills within 100m of site boundary, with cleaning to be provided if necessary. Regular site inspections to monitor compliance with the Construction Environmental Management Plan / Demolition Management Plan (CEMP/DMP) should be carried out, inspection results recorded, and an inspection log made available to the Local Authority on request. The frequency of site inspections should be increased when activities with a high potential to produce dust are being carried out and during prolonged dry or windy conditions. Dust deposition, dust flux, and/or real-time PM10 continuous monitoring maybe required. Any requirement for monitoring (along with the number, type and location of monitoring sites) should be agreed with the Local Authority prior to the commencement of works and/or reviewed prior to the commencement of each phase of works (as monitoring may not be considered necessary for all activities/phases). Where possible baseline monitoring should start at least three months before work commences on-site or, if it is a large site, before work on a phase commences.
Preparing and maintaining the Site • • • • • • •
Plan the Site layout so that machinery and dust causing activities are located away from receptors, as far as is practicable. Where practicable, erect solid screens or barriers around dusty activities or the Site boundary that are at least as high as any stockpiles on Site. Where practicable, fully enclose the Site or specific operations where there is a high potential for dust production and the Site is active for an extensive period. Avoid site runoff of water or mud. Keep site fencing, barriers and scaffolding clean using wet methods. Remove materials that have a potential to produce dust from Site as soon as possible, unless being re-used on Site. If they are being re-used onsite, cover appropriately. Where practicable, cover, seed or fence stockpiles to prevent wind whipping.
Operating vehicle/machinery and sustainable travel •
Ensure all on-road vehicles comply with the requirements of the London Low Emission Zone and the London NRMM standards.
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• • • • •
Ensure all vehicle operators switch off engines when stationary - no idling vehicles. Avoid the use of diesel- or petrol-powered generators and use mains electricity or battery powered equipment where practicable. A maximum-speed-limit of 15mph on surfaced and 10mph on unsurfaced haul roads and work areas should be imposed. A Construction Logistics Plan should be produced to manage the sustainable delivery of goods and materials. A Travel Plan that supports and encourages sustainable travel (public transport, cycling, walking, and car-sharing) should be considered.
Operations •
• • •
•
Only use cutting, grinding or sawing equipment fitted or in conjunction with suitable dust suppression techniques such as water sprays or local extraction (e.g. suitable local exhaust ventilation systems). Ensure an adequate water supply on the Site for effective dust and particulate matter suppression or mitigation, using non-potable water where possible and appropriate. Use enclosed chutes and conveyors and covered skips. Minimise drop heights from conveyors, loading shovels, hoppers and other loading or handling equipment and use fine water sprays on such equipment wherever appropriate. Ensure equipment is readily available on Site to clean any dry spillages, and clean up spillages as soon as reasonably practicable after the event using wet cleaning methods.
Waste management •
Avoid bonfires and burning of waste materials.
Measures Specific to Demolition • •
• •
Soft strip inside buildings before demolition (retaining walls and windows in the rest of the building where possible, to provide a screen against dust). Ensure effective water suppression is used during demolition operations. Handheld sprays are more effective than hoses attached to equipment as the water can be directed to where it is needed. In addition, high volume water suppression systems, manually controlled, can produce fine water droplets that effectively bring the dust particles to the ground. Avoid explosive blasting, using appropriate manual or mechanical alternatives. Bag and remove any biological waste or damp down such material before demolition.
Measures Specific to Earthworks • • •
•
Re-vegetate earthworks and exposed areas and soil stockpiles to stabilise surfaces as soon as practicable. Use Hessian, mulches or tackifiers where it is not possible to re-vegetate or cover with topsoil, as soon as practicable. Stockpile surface areas should be minimised (subject to health and safety and visual constraints regarding slope gradients and visual intrusion) to reduce area of surfaces exposed to wind whipping. Where practicable, windbreak netting/screening should be positioned around material stockpiles and vehicle loading/unloading areas, as well as exposed excavation and material handling operations, to provide a physical barrier between the Application Site and the surroundings.
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• • •
Where practicable, stockpiles of soils and materials should be located as far as possible from sensitive properties, taking account of the prevailing wind direction. During dry or windy weather, material stockpiles and exposed surfaces should be dampened down using a water spray to minimise the potential for wind whipping. Only remove the cover in small areas during work and not all at once.
Measures Specific to Construction • •
•
• •
Avoid scabbling (roughening of concrete surfaces) if possible. Ensure sand and other aggregates are stored in bunded areas and are not allowed to dry out, unless this is required for a particular process, in which case ensure that appropriate additional control measures are in place. Ensure bulk cement and other fine powder materials are delivered in enclosed tankers and stored in silos with suitable emission control systems to prevent escape of material and overfilling during delivery. For smaller supplies of fine powder materials, ensure bags are sealed after use and stored appropriately to prevent dust. All construction plant and equipment should be maintained in good working order and not left running when not in use.
Measures Specific to Trackout •
• • • • •
• • •
Use water-assisted dust sweeper(s) on the access and local roads, to remove, as necessary, any material tracked out of the Site. This may require the sweeper being in frequent use. Avoid dry sweeping of large areas. Ensure vehicles entering and leaving sites are covered to prevent escape of materials during transport. Inspect onsite haul routes for integrity and instigate necessary repairs to the surface as soon as reasonably practicable. Record all inspections of haul routes and any subsequent action in a site log-book. Where practicable, hard surfaced haul routes should be installed, which are regularly damped down with fixed or mobile sprinkler systems, or mobile water bowsers and regularly cleaned. Implement a wheel washing system (with rumble grids to dislodge accumulated dust and mud prior to leaving the site where reasonably practicable). Ensure there is an adequate area of hard surfaced road between the wheel wash facility and the site exit, wherever site size and layout permits. Access gates to be located at least 10m from sensitive receptors where possible.
7.9.21 All appropriate measures will be set out in the CEMP/DMP and agreed with LBL prior to commencement of construction works. 7.9.22 Detailed mitigation measures to control construction traffic should be discussed with LBL to establish the most suitable access and haul routes for site traffic. The most effective mitigation will be achieved by ensuring that construction traffic does not pass along sensitive roads (i.e. residential roads, congested roads, via unsuitable junctions, etc.) where possible, and that vehicles are kept clean (through the use of wheel washers, etc.) and sheeted when on public highways. Timing of large-scale vehicle movements to avoid peak hours on the local road network will also be beneficial.
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Residual Effects 7.9.23 The residual effects of dust and PM generated by construction activities following the application of the mitigation measures described above and good site practice would be temporary, medium-term and negligible. Therefore, the residual effects would be not significant.
First Effects (NRMM Assessment) 7.9.24 The greatest impact on air quality due to emissions from NRMM associated with the construction stage will be in the areas immediately adjacent to the working areas. 7.9.25 Final details of the exact plant and equipment likely to be used on Site will be determined by the appointed contractor and alternatives to diesel plant should be considered. The number of plant and their location within the Site are likely to be variable over the construction period, depending on the activities taking place and the area of the Site under construction. NRMM will move around the Site and emissions will be transitory in nature. They will not therefore result in any long-term impacts on air quality at nearby receptors and impacts are considered to be temporary and negligible (not significant). Mitigation 7.9.26 Ensure all on-road vehicles comply with the requirements of the London Low Emission Zone and the London NRMM standards. Residual Effects 7.9.27 Based on the current local air quality in the area, and the likely numbers of NRMM that will be used, the impacts are considered to be temporary and negligible (not significant). First Effects (Construction Traffic Assessment) 7.9.28 Full results of the dispersion modelling are presented in Appendix 7.8 and a summary is provided below. NO2 7.9.29 By 2030, when construction traffic from the Proposed Development is expected to peak, the highest predicted concentration is at receptor 19_0. The concentration in the ‘with construction traffic’ scenario is 26.0µg/m3 at this receptor. The predicted changes in annual mean NO2 concentrations are all below 0.5% of the relevant AQS objective; therefore, in accordance with the EPUK/IAQM descriptors , the impact of the increased emissions on annual mean NO2 concentrations associated with the peak construction traffic is therefore negligible.
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7.9.30 In 2030, with the construction of the Proposed Development, annual mean NO2 concentrations predicted by the model are all below 60µg/m3, and therefore hourly mean NO2 concentrations are unlikely to cause a breach of the hourly mean AQS objective. The impact of the peak construction traffic on hourly mean NO2 concentrations at existing sensitive receptors is therefore negligible.
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PM10 7.9.31 By 2030, when construction traffic is expected to peak, predicted concentrations of PM10 are well below the annual mean objective at all receptors. The highest predicted concentrations are at receptor 11 (Residential apartment on Lewisham Hight Street). The predicted concentration in the with construction traffic scenario is 21.0µg/m3. The predicted changes in annual mean PM10 concentrations are 0.5% or less of the relevant AQS objective; based on the EPUK/IAQM descriptors, the impact of the increased emissions associated with the Proposed Development on annual mean PM10 concentrations is therefore negligible. 7.9.32 The AQS objective for daily mean PM10 concentrations is 50µg/m3 to be exceeded no more than 35 times a year. The total number of days predicted to exceed the daily mean PM10 concentration is 5 days. The increased emissions associated with the peak construction traffic result in no changes to the number of days experiencing concentrations greater than 50µg/m3; the impact on daily mean PM10 concentrations is thus also negligible. PM2.5 7.9.33 The highest predicted annual mean PM2.5 concentration in the 2030 with construction traffic scenario is at receptor 11 (Residential apartment on Lewisham Hight Street). The predicted concentration is 13.4µg/m3 and therefore well below the current AQS objective of 20µg/m3. 7.9.34 Mayor of London has a set an annual mean target for London to reach 10µg/m3 of PM2.5 by 2030. Predicted concentrations of PM2.5 are exceeding this objective at all receptors in each of the modelled scenarios during the peak construction phase year of 2030. It is worth noting that the background concentrations are between 11.2µg/m3 to 11.6µg/m3 at modelled receptors, and therefore already exceeding the objective. The predicted increase as a result of the peak construction traffic is a maximum of 0.1µg/m3, therefore the impact of the increased emissions associated with the Proposed Development on annual mean PM2.5 concentrations is considered to be negligible. Mitigation 7.9.35 The modelling assessment of peak construction phase traffic emissions suggest that impacts will be negligible, and therefore site-specific mitigation is not considered to be required. However, traffic related mitigation measures outlined under the demolition and construction phase will also be relevant here. These measures include ensuring all on-road vehicles comply with the requirements of the London Low Emission Zone, no vehicle idling, impose speed limits within work areas, produce a Construction Logistics Plan and Travel Plan to support and encourage sustainable travel. Residual Effects 7.9.36 The residual effects of the operation of the Proposed Development on local air quality would be temporary, medium-term and negligible and therefore are not significant for NO2, PM10 and PM2.5.
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Operational Phase First Effect (Human Exposure Assessment) 7.9.37 Full results of the dispersion modelling for opening year 2036 are presented in Table A7-8-5 in Appendix 7.8 and a summary is provided below. 7.9.38 The annual mean NO2 and PM10 concentrations are all below the relevant AQS objectives and the Proposed Development is not predicted to introduce new receptors into an area of known poor air quality. The highest annual mean NO2 and PM10 concentration predicted are 21.3 µg/m3 and 20.5 µg/m3 respectively. The applicable APEC band is A. In line with the APEC criteria outlined in Table 7.4, mitigation measures are not required. 7.9.39 The annual mean NO2 concentrations predicted by the model are all below 60µg/m3, therefore hourly mean NO2 concentrations are unlikely to cause a breach of the hourly mean AQS objective. Therefore, the Proposed Development is not anticipated to introduce new receptors into an area of known poor air quality. Mitigation 7.9.40 The Proposed Development is not anticipated to introduce new receptors into an area of known poor air quality and no site-specific mitigation measures will be required. Residual Effects 7.9.41 The Proposed Development will not introduce new receptors into an area of known poor air quality, and the any residual effects would be negligible, and therefore not significant. Air Quality Neutral 7.9.42 The Mayor of London’s Air Quality Neutral guidance states that most non-combustion heat sources, such as air source heat pumps, are assumed to have zero heat-related NOx emissions. The Site’s heat demand will be met through air source heat pumps. 7.9.43 Backup diesel generators would be installed for life safety purposes only and would not be used for any purpose other than for routine testing and maintenance, or in the event of an emergency. 7.9.44 Therefore, building emissions are not assessed further and the Proposed Development is considered air quality neutral in terms of building emissions. 7.9.45 The Proposed Development is car-free except for blue badge parking spaces. Therefore, in accordance with the Air Quality Neutral guidance, the Site can be considered air quality neutral in terms of transport emissions. 7.9.46 Taking into account both building and transport emissions, the development is ‘air quality neutral’.
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7.10 Limitation and Assumptions 7.10.1 To ensure transparency within the EIA process, the following limitations and assumptions have been identified: •
•
•
•
There are uncertainties associated with both measured and predicted concentrations. The model (ADMS-Roads) used in this assessment relies on input data (including predicted traffic flows), which also have uncertainties associated with them. The model itself simplifies complex physical systems into a range of algorithms. In addition, local micro-climatic conditions may affect the concentrations of pollutants that the ADMSRoads model would not consider. To reduce the uncertainty associated with the concentrations predicted by ADMSRoads, model verification has been carried out following guidance set out in LAQM.TG(22) to determine the performance of the model. As the model has been verified against local monitoring data and there can be reasonable confidence in the predicted concentrations. Defra’s forecasts for background pollutant concentrations have been used in the assessment. The forecast background concentrations account for measures to bring about improvements in air quality and do not extend beyond 2030. In assessing the operational year of 2036, it has been necessary to assume the same background levels as for 2030. This limiting assumption is likely to be conservative. At the time that this ES chapter was written, detailed information regarding the likely demolition and construction stage activities was not known. Therefore, the construction dust assessment has been completed using the available or indicative information from the project team on this stage of works and professional judgement.
7.11 Cumulative Effects 7.11.1 In relation to construction works, IAQM guidance and the Mayor of London SPG state that potential impacts are limited to a zone within 250m of the site boundary and/or within 50m of roads up to 250m from the site entrance points. Cumulative impacts from construction dust would be mitigated as the contractors for the Development and any committed developments would be required to manage construction phase emissions (as outlined in demolition and construction phase mitigation section which includes regular liaison meetings with other high risk construction sites to ensure plans are co-ordinated and dust and particulate matter emissions are minimised). Therefore, the conclusions of the air quality assessment in relation to amenity (dust impacts) and human health, hold for effects arising from the Development, both alone and cumulatively. With appropriate mitigation for construction dust impacts, all impacts are negligible and therefore effects are not significant. 7.11.2 In relation to emissions from construction traffic, the air quality assessment is inherently a cumulative assessment as the traffic data includes committed developments. 7.11.3 There are no operational phase cumulative effects from operational phase traffic as the Proposed Development is car free with only blue badge car parking spaces.
7.12 In-Combination Climate Impacts 7.12.1 Climate change could affect weather patterns which would in-turn affect the distribution and levels of air pollutants. Although it is not practicable to quantify how climate change may affect Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 7: Air Quality
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the findings presented in this chapter, it is considered that the influence of climate change is unlikely to substantially affect the findings of this assessment within the timeframe considered. 7.12.2 The Royal Society’s report on ‘Effects of net-zero policies and climate change on air quality’Ref 7.40 examines how climate change itself is expected to affect air quality in the UK by influencing emissions, atmospheric processing and transport of many pollutants. Some of these effects are likely to slow or temporarily reverse improvements in air quality. They are also likely to lead to changes in the seasonal and geographical variations in air quality. For example, pollution events associated with secondary pollutants such as ozone and particulate matter are likely to become more common in summer months with more frequent intense heatwaves. Conversely, pollution events in warmer winter months may reduce as stable atmospheric conditions under which pollution levels build up become less frequent. 7.12.3 The report also sets out how the changing climate, and the net zero measures adopted to limit further warming, can affect air quality. Net zero measures will generally compliment measures being implemented through legislation and policy to improve local air quality, with progressive reductions in vehicle exhaust emissions of NOx, PM10 and PM2.5 expected to continue for the foreseeable future. 7.12.4 The Royal Society’s report also discusses possible mitigation measures that could be considered alongside net zero measures to limit negative effects on air quality.
7.13 Summary 7.13.1 An air quality assessment has been undertaken to determine the potential effect of the Site on local air quality during both its construction and operational phases. 7.13.2 For the construction phase, a qualitative assessment of the potential impacts on local air quality from construction activities has been carried out using the IAQM guidance assessment methodology. 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 PM releases would be significantly reduced. The residual effects of dust and PM generated by construction activities on air quality are therefore negligible and not significant. 7.13.3 The NRMM 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. 7.13.4 In addition, a quantitative assessment of emissions to air from construction traffic was undertaken using ADMS-Roads. Changes in NO2, PM10 and PM2.5 concentrations were predicted for 2030, the assumed peak construction year. The results show that the Proposed Development would cause an imperceptible increase concentrations and no significant adverse effects are predicted. Therefore, no construction phase traffic mitigation measures are required. 7.13.5 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 and within an AQFA. ADMS-Roads was used to predict NO2, Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 7: Air Quality
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PM10 and PM2.5 concentrations across the Site at heights/locations representative of future relevant exposure. The modelling determined that future concentrations would be considerably below (more than 5%) the relevant air quality objectives and, therefore, classify as APEC A according to the London Councils’ exposure criteria. On this basis, there is no air quality grounds for refusal. 7.13.6 Taking into account the assessment results, it is considered that the Proposed Development complies with national and local policy for air quality.
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Table 7.12: Summary of Effects DESCRIPTION RECEPTOR SIGNIFICANCE OF EFFECTS OF SIGNIFICANT MAJOR / POSITI P / D / I ST / EFFECTS MODERATE VE / T MT / / MINOR / NEGATI LT NEGLIGIBLE VE Demolition & Construction
SUMMARY OF MITIGATION / ENHANCEMENT MEASURES
Existing N/A 1. Increased fugitive dust and human PM10 emissions health and ecological due to construction and receptors (within 250m demolition works resulting of the Site in a high risk of and/or 50m dust soiling and of a medium risk to construction routes) human health and ecology, prior to mitigation. The IAQM Construction Dust Guidance methodology recommends that significance is only assigned to the effect after considering the demolition and construction activity with
Good site practice and Negligible implementation of suitable mitigation measures identified within the Mayor of London guidance for a high risk site. These include those for general communication, monitoring, waste management, preparing and maintaining the site, general dust management, operating vehicles/machinery and measures specific to construction, earthworks and trackout. CEMP.DMP.
N/A
N/A N/A
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N/A
SIGNIFICANCE OF RESIDUAL RELEVANT RELEVANT EFFECTS POLICY LEGISLATIO N MAJOR / POSITIV P / D / I ST / MODERATE E / T MT / / MINOR / NEGATIV LT NEGLIGIBLE E
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Negative T
D
MT
N/A
N/A
mitigation applied Existing Negligible Increased human emissions and health and therefore ecological pollutant concentrations receptors associated with the use of NRMM during the demolition and construction stages. Prior to mitigation the effect of increased emissions to air from NRMM on local air quality would be direct, temporary, medium-term and negligible (not significant). Operation Future users Negligible Exposure of future users of of the Proposed the Proposed Development to Development poor air quality . would result in a negligible risk of disamenity prior to mitigation.
Negativ T e
D
MT
No mitigation proposed.
Negligible
Negative T
D
MT
N/A
N/A
Negativ P e
D
LT
No mitigation proposed.
Negligible
Negative P
D
LT
N/A
N/A
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Prior to mitigation, the residual effects of emissions to air on local air quality would be direct, permanent, long-term and negligible (not significant).
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8.0 References Ref 7.1 Mayor of London, (2023). London Plan Guidance – Air Quality Neutral [online]. Available at: https://www.london.gov.uk/sites/default/files/2023-02/Air%20Quality%20Neutral%20LPG.pdf [Accessed September 2024]. Ref 7.2 The National Archives, (1990). Environmental Protection Act 1990 [online]. Available at: https://www.legislation.gov.uk/ukpga/1990/43/contents [Accessed September 2024]. Ref 7.3 The National Archives, (1995). Environment Act 1995 [online]. Available at: https://www.legislation.gov.uk/ukpga/1995/25/contents [Accessed September 2024]. Ref 7.4 The National Archives, (2021). Environment Act 2021 [online]. Available at: https://www.legislation.gov.uk/ukpga/2021/30/contents/enacted [Accessed September 2024]. Ref 7.5 The National Archives, (2000). The Air Quality (England) Regulations 2000 – Statutory Instrument No. 928 [online]. Available at: https://www.legislation.gov.uk/uksi/2000/928/contents/made [Accessed September 2024]. Ref 7.6 The National Archives, (2002). The Air Quality (England) (Amendment) Regulations 2002 – Statutory Instrument No. 3043 [online]. Available at: https://www.legislation.gov.uk/uksi/2002/3043/contents/made [Accessed September 2024]. Ref 7.7 The National Archives, (2010). The Air Quality Standards Regulations 2010 – Statutory Instrument No. 1001 [online]. Available at: https://www.legislation.gov.uk/uksi/2010/1001/contents/made [Accessed September 2024]. Ref 7.8 The National Archives (2019) The Air Quality (Amendment of Domestic Regulations) (EU Exit) Regulations 2019 No.74 [online]. Available at: https://www.legislation.gov.uk/uksi/2019/74/contents/made [Accessed September 2024 Ref 7.9 The National Archives, (2020). The Environment (Micellaneous Amendments) (EU Exit) Regulations 2020 – Statutory Instrument [online]. Available at: https://www.legislation.gov.uk/uksi/2020/1313/introduction/made [Accessed September 2024]. Ref 7.10 The National Archives (2023). The Environmental Targets (Fine Particulate Matter) (England) Regulations 2023 – Statutory Instrument No. 96 [online]. Available at: https://www.legislation.gov.uk/uksi/2023/96/contents/made [Accessed August 2024]. Ref 7.11 The National Archives, (2021). Environment Act 2021 [online]. Available at: https://www.legislation.gov.uk/ukpga/2021/30/contents/enacted [Accessed September 2024]. Ref 7.12 Defra, (2019). Clean Air Strategy 2019 [online]. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/ 770715/clean-air-strategy-2019.pdf [Accessed September 2024]. Ref 7.13 Defra and the Devolved Administrations (2023) Environmental Improvement Plan 2023 [online]. Available at: https://www.gov.uk/government/publications/environmental-improvementplan [Accessed September 2024 Ref 7.14 Defra, (2007). The Air Quality Strategy for England, Scotland, Wales and Northern Ireland Volume 1 [online]. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/ 69336/pb12654-air-quality-strategy-vol1-070712.pdf [Accessed September 2024]. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 7: Air Quality
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Ref 7.15 Defra, (2007). The Air Quality Strategy for England, Scotland, Wales and Northern Ireland Volume 2 [online]. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/ 69337/pb12670-air-quality-strategy-vol2-070712.pdf [Accessed September 2024]. Ref 7.16 HM Government, (2023). Environmental Improvement Plan 2023 – First revision of the 25 Year Environment Plan [online]. Available at: https://assets.publishing.service.gov.uk/media/64a6d9c1c531eb000c64fffa/environmentalimprovement-plan-2023.pdf [Accessed September 2024]. Ref 7.17 Department for Levelling Up, Housing & Communities, (2023). National Planning Policy Framework [online]. Available at: https://assets.publishing.service.gov.uk/media/65a11af7e8f5ec000f1f8c46/NPPF_December_2023 .pdf [Accessed September 2024]. Ref 7.18 Mayor of London, (2021). The London Plan – The Spatial Development Strategy for Greater London [online]. Available at: https://www.london.gov.uk/sites/default/files/the_london_plan_2021.pdf [Accessed September 2024]. Ref 7.19 Mayor of London, (2018). London Environment Strategy [online]. Available at: https://www.london.gov.uk/sites/default/files/london_environment_strategy_0.pdf [Accessed September 2024]. Ref 7.20 LBL Council, (2011). Core Strategy – Development plan document [online]. Available at: https://lewisham.gov.uk/myservices/planning/policy/adopted-local-plan/core-strategy/about-ourcore-strategy-for-the-local-development-framework [Accessed September 2023]. Ref 7.21 LBL Council, (2014). Development Management local plan [online]. Available at: https://lewisham.gov.uk/myservices/planning/policy/adopted-local-plan/developmentpolicies/development-policy-documents [Accessed September 2024]. Ref 7.22 LBL Council, (2014). Lewisham town centre local plan [online]. Available at: https://lewisham.gov.uk/myservices/planning/policy/adopted-local-plan/lewisham [Accessed September 2024]. Ref 7.23 LBL Council, (2023). Lewisham Local Plan An Open Lewisham as part of an Open London Proposed submission document – Regulation 19 stage [online]. Available at: https://www.localplanservices.co.uk/lewishamlocalplan [Accessed September 2024]. Ref 7.24 Department for Levelling Up, Housing and Communities and Ministry of Housing, Communities & Local Government, (2019). Planning Practice Guidance – Air quality [online]. Available at: https://www.gov.uk/guidance/air-quality--3 [Accessed September 2024]. Ref 7.25 Mayor of London, (2019). London Local Air Quality Management (LLAQM) Technical Guidance 2019 (LLAQM.TG(19)) [online]. Available at: https://www.london.gov.uk/sites/default/files/llaqm_technical_guidance_2019.pdf [Accessed September 2024]. Ref 7.26 Defra, (2022). Part IV of the Environment Act 1995 as amended by the Environment Act 2021 Environment (Northern Ireland) Order 2002 Part III [online]. Available at: https://laqm.defra.gov.uk/wp-content/uploads/2022/08/LAQM-TG22-August-22-v1.0.pdf [Accessed September 2024]. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 7: Air Quality
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Ref 7.27 London Councils, (2007). Air Quality and Planning Guidance. The London Air Pollution Planning and the Local Environment (APPLE) working group. Ref 7.28 Mayor of London, (2014). The Control of Dust and Emissions During Construction and Demolition Supplementary Planning Guidance [online]. Available at: https://www.london.gov.uk/sites/default/files/gla_migrate_files_destination/Dust%20and%20Emissi ons%20SPG%208%20July%202014_0.pdf?token=zV3ZKTpP [Accessed September 2024]. Ref 7.29 IAQM, (2024). Guidance on the assessment of dust from demolition and construction version 2.2 [online]. Available at: https://iaqm.co.uk/wp-content/uploads/2013/02/ConstructionDust-Guidance-Jan-2024.pdf [Accessed September 2024]. Ref 7.30 IAQM, (2017). Land-Use Planning & Development Control: Planning for Air Quality [online]. Available at: https://iaqm.co.uk/text/guidance/air-quality-planning-guidance.pdf [Accessed September 2024]. Ref 7.31 Mayor of London, (2023). London Plan Guidance – Air Quality Positive [online]. Available at: https://www.london.gov.uk/sites/default/files/2023-02/Air%20Quality%20Positive%20LPG.pdf [Accessed September 2024]. Ref 7.32 Environment Agency, (2023). Environmental Permitting Regulations – Installations [online]. Available at: https://environment.data.gov.uk/public-register/view/search-industrialinstallations [Accessed September 2024]. Ref 7.33 LBL, (2023). London Borough of Lewisham Air Quality Annual Status Report for 2022. Ref 7.34 AECOM, (2023). Lewisham Nitrogen Dioxide Diffusion Tube Sruvey 2022 [online]. Available at: https://lewisham.gov.uk/myservices/environment/air-pollution/check-air-quality-levels [Accessed September 2024]. Ref 7.35 Defra, (2024). Air Quality Management Areas (AQMAs) [online]. Available at: https://ukair.defra.gov.uk/aqma/ [Accessed September 2024]. Ref 7.36 GLA, (2023). London Atmoshperic Emissions Inventory (LAEI) 2019 [online]. Available at: https://data.london.gov.uk/dataset/london-atmospheric-emissions-inventory--laei--2019 [Accessed September 2024]. Ref 7.37 Defra, (2020). Background Mapping data for local authorities – 2018 [online]. Available at: https://uk-air.defra.gov.uk/data/laqm-background-maps?year=2018 [Accessed September 2024]. Ref 7.38 Defra, (2013). MAGIC [online]. Available at: https://magic.defra.gov.uk/ [Accessed September 2024]. Ref 7.39 Cambridge Environmental Research Consultants, (2023). ADMS-Roads [online]. Available at: https://www.cerc.co.uk/environmental-software/ADMS-Roads-model.html [Accessed September 2024]. Ref 7.40 LBL, (2022). Air Quality Action Plan 2022-2027 [online]. Available at: https://lewisham.gov.uk/myservices/environment/air-pollution/read-our-air-quality-action-plan-andother-reports [Accessed September 2024]. Ref 7.41 The Royal Society, (2021). Effects of net-zero policies and climate change on air quality. Available at: https://royalsociety.org/-/media/policy/projects/air-quality/air-qualityand-climate-change-report.pdf [Accessed: October 2024]. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 7: Air Quality
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8.0 Transport & Accessibility 8.1
Introduction
8.1.1 This Chapter reports the likely significant effects of the Proposed Development on the Site and the surrounding area in terms of transport and accessibility matters. Where appropriate, it also identifies proposed mitigation measures to prevent, minimise or control likely negative effects arising from the Proposed Development and the subsequent anticipated residual effects. 8.1.2 The effects of the Proposed Development are considered over both the demolition & construction and operational phases. 8.1.3 The main transport and accessibility issues covered in this Chapter include the following: • • • •
• •
Severance of communities; Road vehicle driver and passenger delay Non-motorised user delay; Non-motorised user amenity; Fear and intimidation on and by road users; and Road user and pedestrian safety
.
8.1.4 This Chapter (and its associated figures and appendices) should be read together with the Introductory Chapters of this ES (Chapters 1 – 5), as well as Chapter 6: Noise and Vibration and Chapter 7: Air Quality 8.1.5 This Chapter is accompanied by the following appendices: •
Transport Assessment (TA) (Volume 3B of the ES).
Competence 8.1.6 This assessment has been written by River Burton, a Principal Transport Planner at SLR Consulting with more than 6 years’ experience in highways and transportation. River has a BSc (Hons) in Geography and is a member of the Chartered Institution of Highways and Transportation (CIHT). River has undertaken many Transport Assessments and prepared associated ES inputs for numerous developments in the residential and commercial sectors. River was supported and overseen by Andrew Ward an Associate Director at SLR Consulting. 8.1.7 SLR is a transport planning, infrastructure design and flood risk, hydrology and sustainable drainage consultancy specialising in assisting the property development industry to maximise the commercial value of land/assets through the planning process. 8.1.8 We regularly provide input to Environmental Impact Assessments focussing specifically on traffic and transport.
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8.1.9 In providing a comprehensive service on the transport aspects of Environmental Impact Assessments, our staff exercise their professional skill and judgement to the best of their ability and discharge any professional responsibilities with integrity and safeguard the public interest in matters of safety, health and otherwise pertaining to their work or other involvement in highways and transportation.
8.2
Legislation, Planning Policy and Guidance
8.2.1 The following national, regional and local planning policy and guidance is of relevance to the assessment of the effects of the Proposed Development in relation to transport and accessibility.
Planning Policy Context National 8.2.2 The following national level policy and guidance documents are of relevance to the Proposed Development: National Planning Policy Framework (2023) 8.2.3 The latest National Planning Policy Framework (NPPF) was published in December 2023 by the Ministry of Housing, Communities and Local Government. 8.2.4 The NPPF sets out the Government’s planning policies for England and how these are expected to be applied. At the heart of the Framework is a presumption in favour of sustainable development. 8.2.5 As part of promoting sustainable transport, paragraph 114 of the revised NPPF states that in assessing applications for development, it should be ensured that: a) appropriate opportunities to promote sustainable transport modes can be – or have been – taken up, given the type of development and its location; b) safe and suitable access to the Site can be achieved for all users; c) the design of streets, parking areas, other transport elements and the content of associated standards reflects current national guidance, including the National Design Guide and the National Model Design Code; and d) any significant impacts from the development on the transport network (in terms of capacity and congestion), or on highway safety, can be cost effectively mitigated to an acceptable degree. 8.2.6 Paragraph 115 goes on to state that “Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe”.
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Regional London Plan 2021 8.2.7 It is understood that the development is proposed to be car free. However, it is recommended that disabled parking is provided for both the residential and non-residential uses. 8.2.8 For non-residential uses, disabled persons parking should be provided in accordance with the parking standards. If the scheme is car free, all non-residential elements must provide access to at least one on or off-street disabled parking bay. The provision of non-residential disabled parking will be considered in the next work stage. 8.2.9 Regarding residential disabled parking, the New London Plan (2021) also states: “All disabled persons parking bays associated with residential development must: • • • • • •
be for residents’ use only (whether M4(2) or M4(3) dwellings) not be allocated to specific dwellings, unless provided within the curtilage of the dwelling be funded by the payment of a commuted sum by the applicant, if provided on-street (this includes a requirement to fund provision of electric vehicle charging infrastructure) count towards the maximum parking provision for the development be designed in accordance with the design guidance in BS8300vol.1 be located to minimise the distance between disabled persons parking bays and the dwelling or the relevant block entrance or lift core, and the route should be preferably level or where this is not possible, should be gently sloping (1:60-1:20) on a suitable firm ground surface.”
8.2.10 Within the New London Plan (2021), Lewisham falls in an area where higher cycle parking standards apply. TfL Healthy Streets 8.2.11 The proposed masterplan will need to consider TfL new Healthy Streets guidance, which incorporates a more site specific, holistic, human focused and evidence-based transport planning for new developments in London. 8.2.12 The Healthy Streets objective is to increase the proportion of trips by walking, cycling and public transport to 80% sustainable modes by 2041 as well as zero emissions by 2050 which is integral in the new way that TfL is looking for developers to assess transport impacts. Other targets include; 20 minutes of active travel per day for all by 2041; Vision zero for road danger; Zero emission by 2050; 10% less HGV in central London AM Peak 2026; 3 million fewer private car trips by 2041. 8.2.13 The new TfL approach focuses on: • • •
Active travel is critical to the future of London and its built environment; Expectation of the Healthy Streets Approach from Developers; Help the planning system support growth at high densities if & when the Healthy Streets Approach is used.
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8.2.14 The Site benefits from being in a highly accessible location, which will enable future residents, employees and visitors to travel by sustainable modes. In this context, it is important that the public realm is designed to be attractive, welcoming and pedestrian-friendly above all. If pedestrians are not prioritised, there is a risk they will not utilise the public realm and it could become a harsh and unattractive environment. 8.2.15 This would directly contravene TfL’s ‘Healthy Streets Guidance’, which puts non-motorised users first and aims to create streets that are “pleasant, safe and attractive, where noise, air pollution, accessibility and shelter are not barriers that prevent people from getting out and about.” Building Regulations (June 2022): Infrastructure for the charging of electric vehicles 8.2.16 This document was first published in 2010 and had further edition in 2021 that came into effect in June 2022. 8.2.17 This document states that for new residential developments: “The number of associated parking spaces which have access to electric vehicle charge points must be: (a) the total number of associated parking spaces, where there are fewer associated parking spaces than there are dwellings contained in the residential building; or (b) the number of associated parking spaces that is equal to the total number of dwellings contained in the residential building, where there are the same number of associated parking spaces as, or more associated parking spaces than, there are dwellings.” 8.2.18 In light of the above, as the development is only proposing disabled car parking, it is considered that all car parking spaces will need to be equipped with electric vehicle charging point (EVCP) infrastructure. Local London Borough of Lewisham Adopted Core Strategy (2011) 8.2.19 The Lewisham Core Strategy sets out the vision, objectives, strategy and policies that will guide public and private sector investment to manage development and regeneration in the Borough over the next 15 years. 8.2.20 The Core Strategy outlines a spatial vision for the Borough and also contains the priorities for the Borough to deliver the vision and will be supported through partnerships overseen by the Lewisham Strategic Partnership that are committed to: • •
“Reducing inequality – narrowing the gap in outcomes that exist in the life chances of the most disadvantaged Delivering together, efficiently, effectively and equitably – ensuring that all citizens have appropriate access to high quality local services.”
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8.2.21 Core Strategy Policy 14 refers to sustainable movement and transport, which states; • • •
•
“The access and safety of pedestrians and cyclists throughout the Borough will be
promoted and prioritised. A network of high quality, connected and accessible walking and cycling routes across the Borough will be maintained and improved. A managed and restrained approach to car parking provision will be adopted to contribute to the objectives of traffic reduction while protecting the operational needs of major public facilities, essential economic development and the needs of people with disabilities. The car parking standards contained within the London Plan will be used as a basis for assessment. Cycle parking will be required for new development and TfL guidelines will be used to assess provision. Design will need to incorporate safe and secure cycle storage and parking as well as other facilities including showers and lockers, where appropriate.”
London Borough of Lewisham Development Management Local Plan (2014) 8.2.22 The Development Management Local Plan was adopted in November 2014 and sets out additional planning policies to guide decisions on planning applications where locational or site-specific provision has not been outlined in the Core Strategy or the London Plan. 8.2.23 DM Policy 1 ‘Presumption in favour of sustainable development’ states that: •
• •
“When considering development proposals, the Council will take a positive approach that reflects the presumption in favour of sustainable development contained in the National Planning Policy Framework. It will work proactively with applicants to find solutions which mean that proposals secure development that improves the economic, social and environmental conditions in the Borough. Planning applications that accord with the policies in the Lewisham Local Plan (and, where relevant, with polices in neighbourhood plans) will be approved without delay, unless material considerations indicate otherwise. Where there are no policies relevant to the application or relevant policies are out of date at the time of making the decision then the Council will grant permission unless material considerations indicate otherwise, taking into account whether: any adverse impacts of granting permission would significantly and demonstrably outweigh the benefits, when assessed against the policies in the National Planning Policy Framework taken as a whole or specific policies in that Framework indicate that development should be restricted.”
Lewisham Local Plan – Proposed Submission Document (2022) 8.2.24 The Lewisham Local Plan – Proposed Submission Document is being consulted upon under Regulation 19 of The Town and Country Planning Regulations 2012. The plan will provide a vision for Lewisham between 2020 and 2040. The document will include a number of policies that will guide development across this 20-year period. 8.2.25 The Loal Plan was submitted to the Secretary of State for examination in November 2023. However, it has not yet been subject to examination in public yet and is considered to have a limited weighting.
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Lewisham Site Allocations Plan (2013) 8.2.26 The Lewisham Site Allocations Local Plan identifies and outlines sites of a notable size that are likely to be developed over the lifetime of the Lewisham Local Development Framework (2011-2026). 8.2.27 The Core Strategy sets out the retail hierarchy for the Borough and, in line with NPPF paragraph 23 and the London Plan, allows for the designation of primary and secondary frontages within the Borough's designated Major and District centres. Within Table 2.15 of the document Lewisham is classified as a major town centre in terms of retail hierarchy in the Borough. 8.2.28 Table 2.16 of the document sets out the primary and secondary frontages within each of the major and district shopping centres. The primary frontage for Lewisham Centre is designated as Lewisham Centre (including Unit 15 – Argos and 70-212 Lewisham High Street). The document also refers to the secondary frontages associated that include Lewisham High Street, Lewis Grove and Lee High Road. 8.2.29 With regards to the Lewisham Centre allocation the document states that reference should be made to the Lewisham Town Centre Local Plan. Lewisham Town Centre Local Plan (2014) 8.2.30 The Lewisham Town Centre Local Plan (LTCLP) is at the heart of regenerating the town centre. It provides a vision and a number of objectives for the town centre, supported by a suite of policies, guidance and a delivery plan. 8.2.31 The LTCLP demonstrates what is required to redevelop the area into a vibrant and successful centre, including improvements to shopping, living, working, and spending leisure time in the town centre. Further, the LTCLP will ensure individual developments support the town centre wide objectives, are well designed and environmentally smart. 8.2.32 In terms of transport the objective of the plan is to encourage patterns of development which support walking, cycling and the use of public transport, reduces the need for private car travel, maintains and where possible improves the high levels of public transport accessibility of the town centre and knits the centre in with the surrounding area. 8.2.33 Policies LTC20 and LTC21 are designed to support the development of transport facilities in the centre as the town develops.
Guidance 8.2.34 Guidance for preparing an assessment of transport issues within an EIA is provided within the following documents: • •
National Planning Practice Guidance (2014) - NPPG IEMA Guidelines: Environmental Assessment of Traffic and Movement (2023)
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8.2.35 The NPPG states that a Transport Assessment (TA) may identify the need for associated studies or feed into other studies, such as an EIA, however it specifies that the full range of studies required by a development should be determined early as it is unlikely that a TA could fulfil the specific role required of a transport element of an EIA. This is particularly relevant where there are environmentally sensitive areas nearby and where the proposal could have implications for breach of statutory thresholds in relation to noise and air quality either as a result of traffic generated by the site or as a consequence of the impact of existing traffic on the site under consideration. 8.2.36 To determine the potential environmental effects of the car and non-car trips associated with the Proposed development, the applied methodologies were informed by the guidelines on the Environmental Assessment of Road Traffic, produced by the Institute of Environmental Management and Assessment IEMA (subsequently referred to as the ‘IEMA guidelines’), which provides guidance on a range of potential traffic related effects arising from new development. Where no specific method is defined within IEMA guidelines, alternative means of assessment was undertaken based on published transportation assessment guidance and best practice. Each of these, as appropriate to this assessment are considered in turn. In the absence of definitive guidance professional judgement has been applied. 8.2.37 The IEMA Guidance is set out in the assessment methodology below.
8.3
Consultation
8.3.1 As discussed in Chapter 2: Approach to Assessment, consideration has been given to the formal EIA Scoping Opinion provided by the Council and consultees and any additional consultation that may have occurred during the design period of the Proposed Development. 8.3.2 Transport and accessibility related correspondence with highway officers at Lewisham Council and TfL is ongoing, to ensure all elements of the scheme are delivered in line with each of the individual consultees requirements. Table 8.1: Consultation Feedback Consultee
Comment
Where is this addressed?
The baseline conditions are generally acceptable and should be expanded on within the ES.
These have been updated and expanded upon.
The section beings at line 8.5.
The ES should either provide an interim scenario or adequate justification for why one is not required.
Two interim scenarios have been provided. One interim scenario for construction and one interim scenario for the phased build-out of the development.
This is detailed in section 8.6.
The ES should have a focus on receptors such as pedestrians and cyclists, and identify any sensitive
Focus on both pedestrians and cyclists is provided within describing the delays and
Throughout analysis
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receptors in the surrounding area. The ES should adequately distinguish between pedestrians and cyclists.
amenities for non-motorised users.
Where no cumulative operational assessment is provided on the basis that committed developments have been included in the future baseline scenario, the ES chapter shall include a table outlining which committed developments have been included, specifically for Transport, and a comparison of these to the schemes identified in Table 3.2 of the Scoping Report.
A list outlining which committed developments have been included within the future baseline is provided within section 8.6
A list outlining which committed developments have been included within the future baseline is provided within section 8.6.
No criteria have been presented for the assessment of effects. The criteria used should follow the IEMA guidelines, and TfL's Healthy Streets guidance where relevant.
Criteria has now been provided.
Detailed from line 8.4.
A figure showing the study area should be provided in the ES.
Provided at Figure 8.1.
TfL have advised that the assessment should be produced following TfL guidance as well as relevant policies within the London Plan
This has been undertaken.
Additionally, Network Rail have stated that the following information is provided either within the EIA or Transport Assessment:
Assessment on railway stations have been provided within the TA. No impact on railway bridges is forecast.
•
Impact on railway stations – Network Rail ask that railway trip information is provided which identifies any increase / decrease in rail trips made at Lewisham Railway Station. The information should detail how many people from the development are expected to use the railway, particularly at peak travel times when the rail network is under the most stress. • Impact on railway bridges – As this application is located in close proximity to a bridge, Network Rail would expect the Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
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Environmental Impact Assessment to contain information regarding any effect as a result of this proposal. Applications that are likely to generate an increase in trips under railway bridges may be of concern to Network Rail where there is potential for an increase in vehicles hitting railway bridges cause significant disruption and delay to rail users.
8.4
Assessment Methodology and Significance Criteria
8.4.1 The following section outlines the methodologies applied to identify and assess the potential impacts and likely effects to result from the Proposed Development. Scope of the Assessment 8.4.2 An EIA Scoping Report was issued to the Council in January 2024 (Appendix 2.1). The Council’s formal Scoping Opinion was issued in February 2024 (Appendix 2.2). 8.4.3 The ‘Guidelines for the Environmental Assessment of Road Traffic’ sets out a number of potential effects relating to highways and transport considerations, which potentially require assessment. The following potential effects were scoped into the assessment: • • • • • •
Severance of communities; Road vehicle driver and passenger delay Non-motorised user delay; Non-motorised user amenity; Fear and intimidation on and by road users; and Road user and pedestrian safety.
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8.4.4 It is considered unlikely that the construction, or operation, of the Project Site will generate or attract hazardous loads; on this basis, it is anticipated that there would be no significant effects relating to hazardous loads. An assessment of hazardous loads was therefore scoped out of the assessment and has not been considered any further in this ES chapter. 8.4.5 Delivery and servicing trips have been included in the above assessment. However, as the development will be reducing the number of car parking spaces on-site due to the removal of the multi-storey car park, it is considered that the impact on the potentially effects above will be overall beneficial. Potential Effect of Traffic Flows on the Local Highway Network 8.4.6 Following the determination of a study area, it is recommended the competent traffic and movement expert applies two broad rules of thumb as criteria to assist in delimiting the scale and extent of the environmental assessment: • •
"Rule 1: include highway links where traffic flows will increase by more than 30% (or the number of heavy goods vehicles will increase by more than 30%); and Rule 2: Include highway links of high sensitivity where traffic flows have increased by 10% or more”.
8.4.7 Where the predicted increase in traffic flows (as a result of a Project) are lower than the above thresholds, the IEMA guidelines suggest the significance of the effects can be stated to be negligible and further detailed assessments are not warranted. Increases in traffic flows below 10% are generally considered to be insignificant in environmental terms given that daily variations in background traffic flow may vary by this amount. 8.4.8 The criteria defining the sensitivity of the receptors are presented in Table 8.2. Table 8.2: Description of the Sensitivity of Receptors Receptor Sensitivity
Receptor Type
High
The receptor/resource has little ability to absorb change without fundamentally altering its present character, Receptors of greatest sensitivity to traffic flow: schools, colleges, playgrounds, accident clusters, retirement homes, roads without footways that are used by pedestrians.
Medium
The receptor/resource has moderate capacity to absorb change without significantly altering its present character. Traffic flow sensitive receptors: congested junctions, doctors’ surgeries, hospitals, shopping areas with roadside frontage, roads with narrow footways, recreation facilities
Low
The receptor/resource is tolerant of change without detriment to its character. Receptors with low sensitivity to traffic flow: places of worship, public open space, tourist attractions and residential areas with adequate footway provision.
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Negligible
Receptors with low sensitivity to traffic flows and those sufficiently distant from road affected roads and junctions.
Severance 8.4.9 The IEMA Guidelines note that “The Department for Transport has historically set out a range of indicators for determining the significance of severance. Changes in traffic flow of 30%, 60% and 90% are regarded as producing ‘slight’, ‘moderate’ and ‘substantial’ changes in severance respectively. Although these thresholds no longer appear in Department for Transport guidance, they have not been superseded by subsequent changes to guidance and are established through planning case law.” 8.4.10 However, caution needs to be observed when applying these thresholds as very low baseline flows are unlikely to experience severance impacts even with high percentage changes in traffic. 8.4.11 Where severance is thought likely to require more detailed investigation, it is recommended the assessment involves: • • •
Defining the facilities to which access is potentially impaired. Defining facility catchment areas from which users may be drawn. Estimating the populations within those areas, both in total and in vulnerable groups.
Driver Delay 8.4.12 IEMA guidelines note that Driver Delay can occur at several points on the network, although the effects are only likely to be significant when the traffic on the highway network is predicted to be at or close to the capacity of the system. 8.4.13 A quantitative assessment has been undertaken to establish the impact on driver delay as a result of the project. Non-motorised User Delay 8.4.14 Pedestrian and cyclist delay may change where: • • • • • • •
Pedestrians and cyclists cross existing roads where traffic flows are projected to change; Pedestrians and cyclists cross new roads; Existing roads which pedestrians and cyclists would have crossed are removed; Road speeds change; Pedestrian and cycle volumes change; New crossing facilities are provided; and Existing pedestrian crossing facilities change.
8.4.15 The assessment of pedestrian delay serves as a proxy for the delay that other modes of nonmotorised users may experience when crossing roads. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
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8.4.16 The IEMA guidelines do not set any thresholds, recommending instead that assessors use their professional judgement to determine the potential impact and likely effect. Within this assessment, the two-way traffic flow in any peak hour is assessed to identify whether the flows exceed 1,400. Professional judgement is then used to identify the impact of these flows. Non-motorised User Amenity 8.4.17 Non-motorised user amenity is broadly defined as the relative pleasantness of a journey and is considered to be affected by traffic flow, traffic composition and pavement width/separation from traffic. This definition also includes pedestrian fear and intimidation and can be considered to be a much broader category including consideration of the exposure to noise and air pollution, and the overall relationship between pedestrians and traffic. 8.4.18 The 1993 IEMA Guidelines suggest that a tentative threshold for judging the significance of changes in non-motorised amenity would be where the traffic flow (or HGV component) is halved or doubled, as was identified in Department for Transport (DfT) guidance at the time. The updated 2023 IEMA Guidelines set out that although these thresholds no longer appear in DfT guidance, they have not been superseded by subsequent changes to guidance and are established through planning case law. As such, non-motorised amenity is assessed based on whether the traffic flow is halved or doubled. Fear and Intimidation 8.4.19 The extent of fear and intimidation is dependent on: • • • •
The total volume of traffic; The heavy vehicle composition; The speed these vehicles are passing; and/or The proximity of traffic to people – and/or the feeling of the inherent lack of protection created by factors such as a narrow pavement median, a narrow path or a constraint (such as a wall or fence) preventing people stepping further away from moving vehicles.
8.4.20 While this is recognised as an important environmental effect there are no commonly agreed thresholds for estimating fear and intimidation from known traffic and physical conditions. The 2023 IEMA Guidelines have introduced a weighting system to help assessors provide a first approximation of the likelihood of pedestrian fear and intimidation based on average traffic flow, total 18-hour heavy vehicle flow and average vehicle speed. A combination of the following provides a degree of hazard score. 8.4.21 Table 8.3 below shows the criteria for the hazard score each link receives. Table 8.3: Fear and Intimidation Degree of Hazard Average Traffic Flow over 18-hour day - all vehicles/hour 2-way (a)
Total 18-hour heavy vehicle flow (b)
Average vehicle speed (c)
1800+
3,000+
>40
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Degree of hazard score
30
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1,200-1,800
2,000-3,000
30-40
20
600-1,200
1,000-2,000
20-30
10
<600
<1,000
<20
0
8.4.22 Table 8.4 below shows the level of fear and intimidation based on the hazard score each link receives. Table 8.4: Levels of Fear and Intimidation Level of fear and intimidation
Total hazard score (a) + (b) + (c)
Extreme
71+
Great
41-70
Moderate
21-40
Small
0-20
8.4.23 Table 8.5 below then details the magnitude of impact based on the change in step/traffic flows from the baseline conditions.
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Table 8.5: Fear and Intimidation Magnitude of Impact Magnitude of Impact Major Moderate
Minor
Negligible
Change in step/traffic flows (AADT) from baseline conditions Two step changes in level One step change in level, but with >400 vehicle increase in average 18-hour average vehicle two-way all vehicle flow; and/or >500 heavy vehicle increase in total 18-hour heavy vehicle flow One step change in level, with <400 vehicle increase in average 18-hour average vehicle two-way all vehicle flow; and/or <500 heavy vehicle increase in total 18-hour heavy vehicle flow No change in step level
Road Safety 8.4.24 The 2023 IEMA guidelines do not include a definition in relation to safety, stating only that the impact assessment should present calculated changes in levels of the roads’ intrinsic safety and the estimated annual reduction in fatal or serious injuries. The guidelines state that “it is recommended that the traffic and movement expert engages with the relevant authorities to determine the best approach for determining the significance of road safety effects.” Additionally, the standard and prescribed Road Safety Audits (GG 119 – Road Safety Audit DMRB) should be used to review the road safety attributes of any proposed engineering changes in the adopted highway prior to submission. 8.4.25 Based on the above, the assessment of road user and pedestrian safety has been based on a review of collision data to determine whether there are any existing safety concerns and whether the Completed Development or Construction phases will exacerbate these. Magnitude of Impact 8.4.26 Table 8.6 summarises the criteria that has been used to determine magnitude of impacts. However, consideration of the absolute level of an impact is also important e.g. the total flow of traffic or HGVs on a link. This is because an increase of, say, 100% in the traffic flow on a road is likely to still lead to negligible or minor effect if the existing flows are low.
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Table 8.6: Magnitude of Impact Effect
Negligible
Severance
Change in total traffic or HGV flows of less than 30%
NonMotorised User Delay NonMotorised User Amenity Driver Delay
Fear and Intimidation
Accidents & Safety
Two-way traffic flow < 1,400 vehicles per hour Change in total traffic or HGV flows < 100%
Minor
Moderate
Major Change in Change in total Change in total total traffic or traffic or HGV flows traffic or HGV flows HGV flows of 30-60% of 60-90% over 90% Professional judgement based on the road links with twoway traffic flow exceeding 1,400 vehicles per hour in context of the individual characteristics Professional judgement based on the routes with >100% change in context of their individual characteristics
Professional judgement based on the results of journey time assessments undertaken. One step change One step change in level, with in level, but with <400 vehicle >400 vehicle increase in increase in average 18-hour average 18-hour Two step average vehicle average vehicle changes in No change in step level two-way all vehicle two-way all vehicle level flow; and/or flow; and/or <500 heavy vehicle >500 heavy vehicle increase in total increase in total 18-hour heavy 18-hour heavy vehicle flow vehicle flow Professional judgement based on qualitative analysis
Magnitude of Impact - Screening Methodology 8.4.27 To assist with the judgement of magnitude of impact, reference has been made to the IEMA guidelines. This guidance sets out the effects considered, as well as thresholds, in respect to potential changes in the volume and composition of traffic, in order to facilitate a subjective judgement of the potential highways and transport effect. The thresholds described above are guidance only and provide a starting point by which a detailed analysis will inform a qualitative assessment. Likely Significant Effects 8.4.28 A critical feature of an environmental assessment is determining whether a given effect is significant. 8.4.29 The guidance states that: “There is no definition of a ‘significant effect’ in the EIA Regulations. The competent traffic and movement expert will need to make it clear how they have defined whether a change (and the resultant effect) is considered significant or not.” Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
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8.4.30 The scale of the resulting effect is judged on the relationship of the magnitude of impact against the sensitivity and / or importance of the receptor. The predicted scale of effects is summarised in Table 8.7. Table 8.7: Scale of Effects Sensitivity of Receptor High
Magnitude of Impact Moderate Minor
Negligible
Major (Significant)
Major (Significant)
Minor (Not Significant)
Medium
Major (Significant)
Low
Moderate (Significant or Not Significant) Minor (Not Significant)
Moderate (Significant or Not Significant) Minor (Not Significant)
Moderate (Significant or Not Significant) Minor (Not Significant)
Minor (Not Significant)
Negligible (Not Significant)
Negligible (Not Significant)
Negligible (Not Significant)
Negligible
Major
Minor (Not Significant)
Minor (Not Significant)
8.4.31 It should be noted that when evaluating effects such as Pedestrian and Cyclist Delay and Driver Delay, the above table is supplemented by professional judgements that takes into account actual changes over and above a baseline position. For example, a small reduction in junction capacity on a receptor of high sensitivity can still be classified as having a negligible effect on delays being incurred to road users. 8.4.32 The nature of effects is described as either: • • •
Beneficial – meaning that there is an overall positive impact; Adverse – meaning that there is an overall negative impact; or Negligible – meaning that there is an insignificant impact.
Significance of Effects 8.4.33 The following criteria is applied in relation to the significance of effects: • • •
‘Moderate’ or ‘Major’ effects are deemed to be ‘significant’. ‘Minor’ effects are considered to be ‘not significant’, although they may be a matter of local concern; and ‘Negligible’ effects are considered to be ‘not significant’.
Geographic Extent of Effect 8.4.34 The geographic extent of the effects is identified at a spatial level, ‘Site’ or ‘local’ effects are those affecting the Project Site and neighbouring receptors, while effects upon receptors beyond the vicinity of the Site and its neighbours are at a ‘district’ level. Effects affecting the wider city of London are at a ‘regional’ level, whilst those which affect different parts of the country, or England, are considered being at a ‘national’ level. Given the scale of the development, its effects will be limited to the ‘local’ level. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
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Effect Duration 8.4.35 The temporal scope of the effect identified is described as either short, medium, long term or permanent as described below. 8.4.36 For the operational assessment the likely effects are deemed permanent whereas for construction effects they are likely to be medium term: • • • •
Short term – < 12 months; Medium term – 1 to 5 years; Long term – + 5 years; and Permanent – effects that are considered to be ‘irreversible’ or extremely long-lasting.
Direct and Indirect Effects 8.4.37 The below assessment will also identify whether the effect is ‘direct’ (i.e. resulting without any intervening factors) or ‘indirect’ or ‘secondary’ (i.e. not directly caused or resulting from something else). Demolition and Construction Phase 8.4.38 The environmental implications of construction traffic are considered to relate to issues of dust and dirt, potentially hazardous loads, driver delay and highway safety as a result of road works. 8.4.39 At this stage of the planning process, a forecast of construction traffic has not been undertaken. However, from experience, the construction traffic movements are usually a low level of regular movements over the course of the working day and the timing of deliveries can be controlled to avoid peak hours. Construction activity typically begins prior to the morning peak hour and is complete before the evening peak period. 8.4.40 The environmental implications of dust and dirt could arise on the construction site from the movement of construction vehicles. Finally, driver delay and highway safety issues could arise as a result of temporary lane closures and road works associated with the different phases of construction, with the majority of works coordinated to be outside of peak times (where possible). Operational Phase 8.4.41 The environmental implications associated with operation of the Proposed Development are considered to relate to driver delay, pedestrian/cycle delay, pedestrian amenity, severance and highway safety. 8.4.42 The nature of the Site as a car free development provides the basis for the limited impact of development traffic on the local area.
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Extent of The Study Area 8.4.43 Molesworth Street (A21) is a dual carriageway which runs along the western boundary of LSC. Lewisham High Street is a two-way single carriageway forming the eastern boundary of the Site. The High Street also provides access to Lewisham market, located to the immediate east of LSC, and continues south to provide access to residential areas within Lewisham. 8.4.44 Molesworth Street (A21) and Lewisham High Street connect to the A20 to the north of the Site. The A20 forms a connection between the A2 in the north-west and the M25 in the southeast. Molesworth Street (A21) and the A20 are part of the TfL ‘red route’ network, which form part of the major road network within London. 8.4.45 There are two main vehicular access points to the existing shopping centre from Molesworth Street. To the north, a ramp provides access to the multi-story car park (MSCP). A separate ramp provides access to the servicing deck for the shopping centre, which is located at first floor. Similarly, separate egress ramps are located at the south-west corner of the shopping centre for vehicles exiting the MSCP and servicing deck. 8.4.46 Salisbury Yard, which is located to the north of the shopping centre, is accessed from the A20, is also used by vehicles, although this is a no through road, and does not provide direct access to the shopping centre. 8.4.47 The Links that form the study area are provided below: 1. Lewisham High Street (south of Ladywell Road) 2. Ladywell Road 3. Lewisham High Street (north of Ladywell Road) 4. Lewisham High Street (north of Molesworth Street) 5. Lewis Grove 6. Belmomt Hill 7. Lee High Road 8. Lewisham High Street (west of Lewis Grove) 9. Rennell Street 10. Lewisham High Street (north of Rennell Street) 11. Loampit Vale (east of A2210) 12. Loampit Vale (Between A2210 & Elmira Street) 13. Loampit Vale (west of A2210) 14. Thurston Road (west of A2210) Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
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15. Molesworth Road 8.4.48 The location of these ATC surveys is provided on Figure 8.1. Figure 8.1: Link Locations
Method of Baseline Collection 8.4.49 The existing baseline conditions on the highways and transport networks associated with and surrounding the Proposed Development have been informed by: • •
On-site observations Desktop research and review of relevant published information including: o National Rail timetables o Local bus timetables o Google Maps o Discussions with Transport for London (TfL) o Traffic surveys; and o Accident Data (of the most recent five-year period).
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8.4.50 Automatic Traffic Counts (ATCs) were laid by Nationwide Data Collection for a survey period of 7 days between 23rd and 29th September 2023 in the locations provided in Figure 8.1. 8.4.51 The 2023 24-hour two-way Annual Average Daily Traffic (AADT) flows for vehicles and Heavy Goods Vehicles (HGVs) are provided in Table 8.8 below. Table 8.8: 24-Hour Two-way Annual Average Daily Baseline Traffic AADT Link
Link Name
Total Vehicles
HDV
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
13423 16765 9769 5449 4205 5540 18347 26015 31002 16459 30581 23665 19609 7274 18354
1806 1715 1060 1912 2026 681 1795 4495 2866 2659 3919 1716 1836 669 2293
8.4.52 Table 8.9 outlines the baseline two-way traffic flows in the AM peak period (09:00-10:00) for the Base Year 2023 at each of the links within the study area. Table 8.9: AM Peak Hour Two-way Baseline Traffic
Link
Link Name
1 2 3 4 5 6 7 8 9 10 11 12 13
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210)
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AM Peak Hour Total HDV Vehicles
658 953 471 274 196 315 941 1373 1738 857 1557 1370 1128
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14 15
Thurston Road (west of A2210) Molesworth Road
371 999
42 154
8.4.53 Table 8.10 outlines the baseline two-way traffic flows in the PM peak period (18:00-19:00) for the Base Year 2023 at each of the links within the study area. Table 8.10: PM Peak Hour Two-way Baseline Traffic
Link
Link Name
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
PM Peak Hour Total HDV Vehicles
762 1159 421 334 266 355 1133 1654 2116 1087 1965 1436 1254 531 1053
81 80 55 104 97 27 67 210 110 131 167 90 92 36 100
Receptor Sensitivity 8.4.54 Table 8.11 presents the receptors likely to be affected by the Proposed Development, and their sensitivity. This considers the location of the receptor in question and its relationship with the Site. 8.4.55 The sensitivity of a road being considered can be defined by the vulnerability of the user groups who may use it, such as elderly people or children, e.g. a road where pedestrian activity is high in the vicinity of a school, or where there is already an existing accident issue may be highly sensitive. It also takes account of the existing nature of the road e.g. an existing “A” road is likely to have a lower sensitivity than a minor residential road. 8.4.56 A road link is considered to have a Negligible, Low, Medium, or High sensitivity. The criteria for analysing the sensitivity of a receptor is set out in Table 8.2 above.
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Table 8.11: Link Receptor Sensitivity
8.5
Link
Link Name
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
Sensitivity Medium Low Low Medium Medium Low Medium Medium Medium Low Low Low Low Low Low
Baseline Conditions
8.5.1 This section outlines the existing baseline conditions of the Site. Pedestrian Network 8.5.2 Figure 8.2 shows the existing pedestrian connectivity and infrastructure around the Site.
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Figure 8.2: Existing Pedestrian Connectivity and Infrastructure
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8.5.3 Figure 8.2 shows that there are five pedestrian access points into the Site. Two of these accesses are located along Molesworth Street on the western boundary, two along Lewisham High Street on the eastern boundary and one on Rennell Street. 8.5.4 Within the vicinity of the Site, Lewisham High Street, where Lewisham Market is located, provides wide pedestrianised areas along both sides of the road, reaching widths of over 4m on both sides. These are well lit and provide dropped kerbs and tactile paving at crossing points. This provides a large pedestrianised area fronting immediately east of the Site, as well as areas of shared surface, enabling retail units and market stalls to be serviced whilst maintaining the pedestrian environment. As a result, this enhances pedestrian journeys along Lewisham High Street, by offering pedestrians things to see and do. 8.5.5 On the western side of the development, i.e. the opposite side to Lewisham Market, Molesworth Street runs in a north-south alignment bordering the Site. 8.5.6 Footways are provided along both sides of Molesworth Street. Three signalised crossing points are provided on Molesworth Street; however, it is considered that the northern most crossing is not provided along the desire line for pedestrians. The perceived desire line would enable pedestrians to cross Molesworth Street to access the railway underpass, which connects to the green spaces to the west of Ravensbourne River. Whilst pedestrian crossings are provided on Molesworth Street, the width of the carriageway does result in severance for pedestrians and the general quality of the public realm is poor. As a result, the Proposed Development seeks to enhance this area. 8.5.7 A pedestrian crossing across the A20 Rennell Street is present to the north of the Site. This provides a safe walking route from the shopping centre to the railway and DLR stations located on the A20, as well as connecting to the residential and retail elements of the Lewisham Gateway development once this is fully built and occupied. 8.5.8 LSC hosts a wide range of food and non-food retail including supermarkets and facilities such as a post office and a pharmacy. Cycle Network 8.5.9 Figure 8.3 shows the existing cycling connectivity and infrastructure around the Site.
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Figure 8.3: Existing Cycling Connectivity and Infrastructure
8.5.10 Cycling improvements have already been made to a section of the A21 between Lewisham and Catford. These were introduced in late 2020 to encourage a healthy and sustainable recovery from COVID-19. Along Molesworth Street, this includes an on-carriageway cycleway, enabling cyclists to travel northbound in a separate lane. Moreover, a shared footway/cycleway on the western side of Molesworth Street permits cyclists to travel southbound, segregated from the traffic. 8.5.11 Lewisham High Street / Rennell Street, Molesworth Street / Rennell Street, and Molesworth Street / Lewisham High Street / Engate Street junctions all feature advanced cycle stop lines. 8.5.12 National Cycle Route (NCR) 21 passes through Lewisham to the west of Ravensbourne River along Marsala Road and providing off-road cycling opportunities. The proposed relocated toucan crossing would improve the link to NCR 21 from the Site. Public Transport 8.5.13 The Public Transport Accessibility Level (PTAL) is a measure of the relative accessibility to public transport in an area. It takes into consideration factors such as distance, type and frequency of services in this. PTAL is categorised in eight levels, 1a to 6b where 6b represents a high level of accessibility and 1a the lowest level of accessibility. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
Plowman Craven 46730 October 2024
8.5.14 The Site has a PTAL of 6b, the highest level available. The WebCAT PTAL report is contained at Volume 3B. 8.5.15 The public transport nodes in proximity to the Site are excellent, as evidenced by the maximum PTAL score. The key public transport bus stops and stations are illustrated in Figure 8.4 below. Figure 8.4: Public Transport Plan
Bus 8.5.16 On the eastern side of the Site, Lewisham High Street provides 7 bus stops. Similarly, on the western side, Molesworth Street provides 2 sets of bus stops. Each stop is no more than circa 50m walking distance from a pedestrian access to LSC. A summary of the frequency of services from all bus stops within the vicinity of the Site are presented in Table 8.12. Table 8.12: Summary of Bus Service Frequencies
Number 21 47 54 75
Route Lewisham Centre – Newington Green Shoreditch – Newquay Road Elmers End – Woolwich Lewisham Station – Fairfield Halls
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
Weekday
Frequency Saturday
Sunday
7-11 mins
8-12 mins
10-14 mins
10-13 mins 9-12 mins 10-14 mins
11-13 mins 10-13 mins 12-14 mins
20 mins 15 mins 15 mins
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Number 89 108 122 136 178 180 181 185 199 208 225 261 273 284 321 380 436 484 621 N21 N89 N136 N199 P4
Route Lewisham Station – Slade Green Station Lewisham Station – Stratford International Station Plumstead Station – Crystal Palace Grove Park Bus Station – elephant & Castle Lewisham Station – Woolwich Crabtree Manorway North – Molesworth Street Lewisham Station – Grove Park Bus Station Lewisham station – Victoria Station Canada Water Bus Station – Catford Lewisham Station – Orpington Hither Green Station – Canada Water Bus Station Lewisham Station – Princess Royal Hospital Conington Road – Petts Wood Station Lewisham Station – Grove Park Cemetery Foots Cray – New Cross Belmarsh Prison – Molesworth Street Lewisham – Battersea Park Station Lewisham Station – Denmark Hill Lewisham Station – Crown Woods School Bexleyheath – Charing Cross Trafalgar Square - Erith Chislehurst – Regents Street Trafalgar Square – St Mary Cray Station Lewisham station – Brixton Station
Weekday
Frequency Saturday
Sunday
9-13 mins
9-13 mins
20 mins
8-12 mins
8-11 mins
15 mins
9-13 mins
11-13 mins
15 mins
9-13 mins
10-14 mins
20 mins
8-12 mins
9-13 mins
15 mins
15 mins
15 mins
15 mins
9-13 mins
11-13 mins
15 mins
7-10 mins 10-14 mins 10-14 mins
7-10 mins 12-13 mins 10-13 mins
11-13 mins 15 mins 15 mins
20 mins
20 mins
20 mins
9-13 mins
11-13 mins
15 mins
20 mins
20 mins
30 mins
9-13 mins
11-12 mins
20 mins
8-12 mins
8-12 mins
10-14 mins
10-13 mins
11-13 mins
15 mins
10-13 mins 9-13 mins School Service 30 mins 30 mins 30 mins
11-13 mins 11-13 mins
11-13 mins 15 mins
No Service
No Service
20 mins 30 mins 30 mins
30 mins 30 mins 30 mins
30 mins
30 mins
30 mins
10-14 mins
10-13 mins
12-14 mins
8.5.17 Table 8.12 shows that the bus stops provide access to 28 bus routes, including 4 night-time services. As such, each stop is served by an average of a bus every 2 minutes.
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Rail & DLR 8.5.18 The nearest train station is Lewisham Station, approximately a 290m (4-minute) walk to the north of the Site. The station provides both DLR and Southeastern (National Rail) services. A summary of the frequency of Southeastern and DLR services are presented in Table 8.13. Table 8.13: Summary of Rail and DLR Service Frequencies Destination London Charing Cross London Victoria London Cannon Street Dartford Hayes Slade Green Orpington Woolwich Arsenal Bank
Frequency (per hour) Weekday Saturday Lewisham Railway Station 8 7 2 2 3 2 6 5 2 2 2 2 3 2 2 2 Lewisham DLR Station 15 12
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Sunday 4 2 2 4 2 2 2 2 6
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8.5.19 Table 8.13 indicates a DLR service departs approximately every 4 minutes, terminating at Bank. For Southeastern services, Lewisham Station provides up to 13 trains an hour into central London, 10 eastbound trains per hour and 5 southbound trains per hour. Local Highway Network 8.5.20 Figure 8.5 illustrates the key roads in proximity to the Site as well as access for public and delivery and servicing vehicles. Table 8.5: Existing Highway Network
Personal Injury Collisions 8.5.21 This section analyses the Personal Injury Collisions (PICs) for the assessed routes in the ATZ. This analysis has been undertaken for the most recent five-year period available, between March 2019 to March 2024. 8.5.22 A total of 251 collisions were recorded in the study area over the most recent five-year period; none of which were fatal, 29 of which were serious and 222 of which were slight. 8.5.23 TfL guidance states that a collisions cluster is defined as a location where there have been one fatal / two or more serious clusters. In line with this guidance, four clusters were identified within the study area. 8.5.24 The location of these clusters is shown in Figure 8.6. The clusters are summarised within Table 8.14. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
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Figure 8.6: PIC Data on ATZ Routes
Table 8.14: PIC Cluster Summary
Cluster 1
2
3
Location A20 / Station Road Junction
Lewisham High Street / Molesworth Street Roundabout Lewisham High Street / Morley Road Priority Junction
Severity
Year
Casualty
Serious
2019
Pedestrian
Serious
2021
Driver / Rider
Serious
2020
Driver / Rider
Serious
2020
Serious
2021
Driver / Rider Pedestrian
Serious
2019
Pedestrian
Serious
2021
Pedestrian
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
Description Crossing masked by stationary / parked vehicles Involved a goods vehicle between 3.5-7.5 tonnes and a pedal cyclist The vehicle undertook an Illegal turn or direction of travel and was impaired by alcohol Illegal turn / direction of travel and failed to look properly Failed to look properly Too close to cyclist, exceeding speed limit, failed to look properly Dangerous action in carriageway / disability or illness, mental or physical
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Cluster
4
Location
Lewisham High Street / Ladywell Road Priority Junction
Severity
Year
Serious
2022
Serious
2019
Serious
2022
Serious
2023
Casualty Driver / Rider Front Seat Passenger Driver / Rider Seated Passenger
Description Failed to look properly Failed to look properly, careless reckless on in a hurry Following too close A private vehicle was careless / reckless or in a hurry
8.5.25 Cluster 1 has been reviewed and shows no clear link between the collisions. As such it is considered that these collisions are the result of human error rather than an issue with the road layout. The location which the pedestrian is deemed to have crossed is adjacent to nearby signalised crossings towards key destinations only circa 20m walk from where the collision took place. As such, no improvements are suggested at this junction. 8.5.26 Cluster 2 comprised a pattern at the Lewisham High Street / Molesworth Street Roundabout where vehicles were undertaking illegal turning manoeuvres. Although the collision description does not specific exactly what illegal manoeuvre was undertaken, a potential improvement could be to ensure that all signage / road markings are clear to ensure that drivers have all necessary information to make the correct turning manoeuvre. It should be noted that poor signage or road markings were not highlighted as an issue as a part of the Site visit, undertaken on the 4th of July 2024. 8.5.27 Cluster 3 was located at the Lewisham High Street / Morley Road Priority Junction are not linked or repeat collisions and as such do not appear to be a result of an inherent issue within the road layout. As such, no improvements are suggested at this junction. 8.5.28 Cluster 4 located at the Lewisham High Street / Ladywell Road Priority Junction are described as being attributed to human error. As such, no improvements are suggested at this cluster. 8.5.29 As such the above collisions do not indicate an inherent safety issue within the surrounding road network.
8.6
Assessment Scenarios
8.6.1 The assessment scenarios set out in ES Volume 1, Chapter 2: EIA Methodology are considered within this ES chapter. A summary of these scenarios are listed below: • • • • • •
Baseline Conditions (2023) (Scenario 1); Baseline plus Demolition and Construction Flows – Phase 1a (Scenario 2); Baseline plus Peak Construction (Scenario 3); Core Assessment: Future Baseline (Scenario 4); Core Assessment: Future Baseline plus Proposed Development - Phase 1a (Scenario 5); Core Assessment: Future Baseline plus Proposed Development (Scenario 6).
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8.6.2 The construction vehicle movements associated with the Detailed Planning Application has been considered within Scenario 2. Consideration of the construction related vehicle movements associated with the Detailed and Outline Planning Applications is considered within Scenario 3.
Baseline Conditions (2023) – Scenario 1 8.6.3 The construction vehicle movements associated with the Detailed Planning Application has been considered within Scenario 2. Consideration of the construction related vehicle movements associated with the Detailed and Outline Planning Applications is considered within Scenario 3. 8.6.4 The baseline traffic flows used to inform the assessment within the TA and this ES chapter have been gathered using a variety of data sources. 8.6.5 The following information sources were recorded in respect to the existing traffic and transport conditions of the Proposed Development and study area: • • •
Traffic counts - Automatic Traffic Count (ATC) between 23rd September 2023 to 29th September 2023. On-site observations; and Collision Data obtained from TfL in July 2024.
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8.6.6 Detail regarding the information sources is provided within the TA.
Baseline plus Site Preparation, Enabling Works – Scenario 2 (relevant to the Detailed Planning Application Works only) 8.6.7 This scenario includes the baseline as previously described plus the peak traffic associated with the Site Preparation and Enabling Works (relevant to the Detailed Planning Application only). No operational traffic is included in this assessment as the first phase of the Proposed Development is anticipated to occupied until after these works have been concluded. 8.6.8 This scenario does not include any growth in traffic on the local road network associated with the cumulative schemes because this would result in the highest percentage change on the local transport network and thereby reflect the worst-case in terms of impacts. 8.6.9 This scenario does not account for any cumulative development traffic on the local transport network as the enabling works that have been considered are due to commence Q1 2028 and to represent a worst-case assessment in relation to a percentage impact.
Baseline plus Peak Construction – Scenario 3 (relevant to the Outline Planning Application Works) 8.6.10 This scenario includes the baseline as previously described in Scenario 1 plus the construction traffic (relevant to the Outline Planning Application). The construction phase assessment is based on the peak period for the construction of the Proposed Development (i.e. the point in the construction programme where the most construction related works are anticipated to take place on-site). 8.6.11 This scenario does not account for any cumulative development traffic on the local transport network as the enabling works that have been considered are due to commence Q2 2030 and to represent a worst-case assessment in relation to a percentage impact. 8.6.12 This scenario does include traffic generated by Phase 1A, which will be occupied and in operation.
Future Baseline – Scenario 4 8.6.13 The Core Assessment Future Year Scenarios are designed to assess the local highway network in future years with an allowance for Committed Developments (i.e., cumulative schemes). It has been assumed that all cumulative schemes identified are fully complete within the Future Baseline (Scenario 4) with the exception of Lewisham Retail Park. 8.6.14 The only committed development included as part of the future baseline is Lewisham Gateway (DC/06/62375) as this will be occupied once the development is occupied. The remaining developments were excluded for the following reasons: • •
Carpetright, Loampit Vale (DC/20/118766) – Built out and occupied and car free. 1 Silver Road, London (DC/18/109972) – Built out and occupied with negligible vehicle trips
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• •
Land at former car parks, Tesco Store, Conington Road, Lewisham (DC/21/121768) – Built out and occupied and no construction information is provided and only 9 disabled spaces are provided which provides negligible vehicle trips Lewisham Retail Park (DC/16/097629) – The timing for construction is unknown as it was scheduled for 2019 but has not yet commenced as such has been excluded from the assessment for robustness. Negligible operational vehicle trips are forecast.
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Future Baseline plus Proposed Development - Scenarios 5 and 6 8.6.15 In the Core Assessment Future Year with Proposed Development (Scenario 5), a multi modal trip generation assessment has been undertaken to identify the quantum of movements by mode by time as a result of the completed Phase 1a and these will then be assigned to the transport network and the effects assessed against the Future Baseline. It is expected that Phase 1a will be fully complete in this scenario and the Proposed Development traffic has been calculated on a site-specific methodology as set out in detail within the Transport Assessment. 8.6.16 In the Core Assessment Future Year with Proposed Development (Scenario 6), an assessment of the completed Proposed Development will be assessed against the Future Baseline (Scenario 4). It is expected that Proposed Development will be fully complete in this scenario. 8.6.17 Scenarios 5 and 6 are considered the core assessments that any planning application should be assessed against to determine the effects of the Proposed Development and any required mitigation.
8.7
Impact Assessment Methodology Site Preparation, Enabling Works and Construction Works of the Proposed Development
8.7.1 Site Preparation and Enabling Works (relevant to the Detailed Planning Application only) 8.7.2 The detailed planning application works traffic forecast has been determined using information provided in Chapter 5 of the ES which is based on estimates of quantities and volumes for that phase of works which has then been used to estimate the number of vehicles associated with the works programme. This assessment is based on the peak period of works sought for by the Detailed Planning Application of the Proposed Development (i.e. the point in the programme where the most enabling related works are anticipated to take place on site during this period). An indicative construction programme of the works relating to the Detailed Planning Application is presented in Chapter 5 of the ES. 8.7.3 As set out within this ES chapter, during the demolition and enabling period of works there will be an average one-way 72 HGV movements per day (144 two-way movements). 8.7.4 With regards to hazardous loads during this phase of works, the traffic and movement assessment needs to clearly outline the estimated number and composition of such loads. Where the number of movements is considered to be significant, the assessment should include a risk or catastrophe analysis to illustrate the potential for an accident to happen and the likely effect of such an event. The extent of such analysis should clearly reflect the nature of the load being transported. For instance, much more detail is required for a development that involves the transportation of nuclear products than for one that involves the delivery of petroleum.
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Construction Works (relevant to Outline Planning Application only) 8.7.5 The construction traffic forecast has been determined using information provided in Chapter 5 of the ES, which is based on estimates of quantities and volumes for those phases of works relating to the Construction Works of the Proposed Development, which has then been used to estimate the number of vehicles associated with the works programme. 8.7.6 The construction phase assessment (relevant to the Outline Planning Application) is based on the peak periods for the construction of the Proposed Development (i.e. the points in the construction programme where the most construction related works are anticipated to take place as set out in Chapter 5 of the ES. 8.7.7 As set out within Chapter 5 of the ES, during the demolition and enabling period of works there will be an average one-way 168 HGV movements per day (336 two-way movements). 8.7.8 Heavy Duty Vehicle (HDV) trips have been distributed on the local highway network using the indicative construction routing set out in Chapter 5 of the ES.
Completed Development 8.7.9 The description of the Proposed Development which has been assessed within this ES Chapter is set out in Chapter 4: Proposed Development. 8.7.10 The methodology for estimating the trip generation of the Proposed Development is set out in detail within the TA. This in part utilises the information from traffic surveys and the TRICS database which is an industry standard database of sites with various land uses which have been surveyed to understand the likely trip generating propensity of each land use which can then be applied to similar developments with similar accessibility characteristics. 8.7.11 The vehicle trips associated with the Proposed Development have then been distributed across the study area based on the methodology described within the TA which utilises a variety of sources including Census Data, Traffic Survey data and Google Maps.
8.8
Assumptions and Limitations
8.8.1 The TA which has informed this ES chapter, is subject to several limitations and assumptions. 8.8.2 The assessment set out in ‘Likely Significant Effects’ section of this ES chapter assesses the traffic movements associated Scenarios 2 and 3 listed above in relation to the site preparation and enabling works and construction phases in addition to the Proposed Development generated traffic flows prior to the implementation of any mitigation measures. 8.8.3 The following assumptions have been made: •
The main limitation to the baseline conditions presented within this ES chapter is the precision of the traffic counts that form the baseline scenario. The link counts would have been recorded over a week and are typically subject to an accuracy of + or – 10%.
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•
•
8.9
The precise occupation of some of the committed developments which have planning approval but have not yet been built-out at the time of the September 2023 traffic surveys is not known. It is assumed that committed developments are not occupied at the time of the traffic surveys. A number of assumptions have been made in order to establish the trip generation of the operational Proposed Development, including the proportion of new vehicle trips on the local highway network. The trip forecasts are based upon consideration of floor areas with trip rates proportional to the quantum of floorspace and the uses proposed. Further assumptions have been made regarding the assignment of these trips onto the highway network. The methodology for trip distribution is detailed within the TA.
Introduced Receptors
8.9.1 There are no traffic and transport receptors being introduced as part of the Proposed Development which warrant inclusion within this chapter of the ES. Whilst the proposals will provide new areas of highway and dedicated footway and cycle ways, these will be designed to accommodate the forecast levels of pedestrian, cyclist and vehicle flow and as such there is no potential for likely significant effects upon these introduced routes. 8.9.2 Any off-road routes are not required to form part of this assessment as they will be unaffected by changes in traffic levels or composition through their design and will not therefore be adversely affected by the Proposed Development.
8.10 Embedded Mitigation 8.10.1 As part of the design of the Proposed Development, there are several embedded mitigation features which will be delivered. These mitigation features will significantly enhance the walking, cycling and driving experience across the Site. A list of the embedded mitigation which comprises the following; • • •
Improvements to pedestrian facilities on Molesworth Street; Improved connectivity through the Site for active travel; and Improvements to Rennell Street pedestrian crossing.
8.10.2 As part of the Proposed Development, improvements to the footways on Molesworth Street/Rennell Street in the vicinity of the Site will reduce the effects of severance along with pedestrian and cycle delay through the provision of well-designed crossing points whilst improving the pedestrian and cycle amenity.
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8.11 Assessment of Effects, Mitigation and Residual Effects Demolition & Construction Phase – Scenario 2: Baseline plus Site Preparation and Enabling Works 8.11.1 Assessment Scenario 2 considers the 2023 Baseline traffic flows plus the peak remediation, Site preparation, enabling works HDV movements. 8.11.2 The enabling works traffic forecast has been determined using information provided in Chapter 5 of the ES. 8.11.3 The maximum number of vehicles which the enabling works could generate is 72 HDVs (144 two-way movements) so the consideration of the peak vehicle trip generation represents a worst-case assessment. 8.11.4 It is estimated that 90% of construction works vehicles are HDVs as construction staff trips will predominately travel using public transport or active travel modes. 8.11.5 The AM and PM vehicle trips have been calculated based on the average number of vehicles arriving across the day i.e. 10 working hours for the peak number of vehicles expected onsite. 8.11.6 A summary of the construction trip generation anticipated for Assessment Scenario 2 is set out in Table 8.15. Table 8.15: Forecast Site Preparation and Enabling Works Traffic
Vehicle Type
HDV (>7.5t + <7.5t)
Daily Vehicle Trips (AADT)
AM Peak Hour
PM Peak Hour
Arr
Dep
Two-way
Arr
Dep
Twoway
Arr
Dep
Twoway
72
72
144
7
7
14
7
7
14
Distribution 8.11.7 The distribution of HDVs and LGVs is set out in Table 8.16 and is based on the same distribution as operational goods vehicles given that at this point the sources of materials are largely unknown. For clarity, 66% of construction movements have been equally distributed east and west on the A20 and 33% have been distributed south via Lewisham High Street. Table 8.16: Scenario 2 – HDV & LGV Distribution – 24hr AADT Link
HDVs
LGVs
Total
1 2 3 4 5 6
43 0 43 0 0 0
5 0 5 0 0 0
48 0 48 0 0 0
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7 8 9 10 11 12 13 14 15
43 43 86 0 43 43 43 0 43
5 5 10 0 5 5 5 0 5
48 48 96 0 48 48 48 0 48
8.11.8 The AM and PM peak hour distribution of enabling works HDVs and LGVs is set out in Table 8.17. Table 8.17: Scenario 2 – HDV & LGV Distribution – AM Peak & PM Peak Link
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
HDVs
AM LGVs
Total
HDVs
PM LGVs
Total
4 0 4 0 0 0 4 4 8 0 4 4 4 0 4
1 0 1 0 0 0 1 1 2 0 1 1 1 0 1
5 0 5 0 0 0 5 5 10 0 5 5 5 0 5
4 0 4 0 0 0 4 4 8 0 4 4 4 0 4
1 0 1 0 0 0 1 1 2 0 1 1 1 0 1
5 0 5 0 0 0 5 5 10 0 5 5 5 0 5
8.11.9 The traffic impact of the Scenario 2 has been compared to the 2023 baseline traffic in Table 8.18. Table 8.18: 2023 Baseline Compared to Scenario 2 (24 hr AADT)
Link
1 2 3
Location
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road)
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
2023 Baseline Total HDV Vehs
Scenario 2 Total HDV Vehs
% Change Total HDV Vehs
13423
1806
13471
1849
0.4%
2.4%
16765
1715
16765
1715
0.0%
0.0%
9769
1060
9817
1103
0.5%
4.1%
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4 5 6 7 8 9 10 11 12 13 14 15
Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
5449
1912
5449
1912
0.0%
0.0%
4205 5540 18347
2026 681 1795
4205 5540 18395
2026 681 1838
0.0% 0.0% 0.3%
0.0% 0.0% 2.4%
26015
4495
26063
4538
0.2%
1.0%
31002
2866
31098
2952
0.3%
3.0%
16459
2659
16459
2659
0.0%
0.0%
30581
3919
30629
3962
0.2%
1.1%
23665
1716
23713
1759
0.2%
2.5%
19609
1836
19657
1879
0.2%
2.3%
7274
669
7274
669
0.0%
0.0%
18354
2293
18402
2336
0.3%
1.9%
8.11.10 The traffic impact of the Scenario 2 (AM Peak Hour) has been compared to the 2023 baseline traffic in Table 8.19. Table 8.19: 2023 Baseline Compared to Scenario 2 (AM Peak)
Link
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Location
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
2023 Baseline Total HDV Vehs
Scenario 2 Total HDV Vehs
% Change Total HDV Vehs
658
95
663
99
0.8%
4.2%
953
123
953
123
0.0%
0.0%
471
54
476
58
1.1%
7.4%
274
94
274
94
0.0%
0.0%
196 315 941
102 44 104
196 315 946
102 44 108
0.0% 0.0% 0.5%
0.0% 0.0% 3.9%
1373
270
1378
274
0.4%
1.5%
1738
192
1747
200
0.6%
4.2%
857
158
857
158
0.0%
0.0%
1557
237
1562
241
0.3%
1.7%
1370
96
1375
100
0.4%
4.2%
1128 371 999
118 42 154
1133 371 1004
122 42 158
0.4% 0.0% 0.5%
3.4% 0.0% 2.6%
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8.11.11 The traffic impact of the Scenario 2 (PM Peak Hour) has been compared to the 2023 baseline traffic in Table 8.20. Table 8.20: 2023 Baseline Compared to Scenario 2 (PM Peak)
Link
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Location
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
2023 Baseline Total HDV Vehs
Scenario 2 Total HDV Vehs
% Change Total HDV Vehs
762
81
767
85
0.6%
4.9%
1159
80
1159
80
0.0%
0.0%
421
55
426
59
1.2%
7.2%
334
104
334
104
0.0%
0.0%
266 355 1133
97 27 67
266 355 1138
97 27 71
0.0% 0.0% 0.4%
0.0% 0.0% 6.0%
1654
210
1659
214
0.3%
1.9%
2116
110
2125
118
0.5%
7.2%
1087
131
1087
131
0.0%
0.0%
1965
167
1970
171
0.3%
2.4%
1436
90
1441
94
0.3%
4.5%
1254 531 1053
92 36 100
1259 531 1058
96 36 104
0.4% 0.0% 0.5%
4.3% 0.0% 4.0%
Plowman Craven 46730 October 2024
8.11.12 As set out previously, the impact of the traffic associated with demolition and construction of Phase 1A needs to be considered in relation to Rule 1 and Rule 2 of the screening criteria. 8.11.13 In terms of the impact of the AADT flows (Table 8.18) this does not exceed 5% on any link. Therefore, considering Rule 1 (+30% of any link) and Rule 2 (+10% on sensitive links) of the IEMA Guidelines, the screening thresholds are not met or exceeded, and as such no links require further investigation. 8.11.14 In the AM and PM peak hours, no links experience traffic increases exceeding 10% in terms of Total Vehicles or HDVs. Therefore, considering Rule 1 (+30% of any link) and Rule 2 (+10% on sensitive links) of the IEMA Guidelines, the screening thresholds are not met or exceeded, and as such no links require further investigation. Severance 8.11.15 The maximum increase in movements in either peak hour is 8 i.e. one HDV circa 7-8 minutes which equates to a less than 10% increase in HDVs; accordingly, this equates to a Negligible magnitude of impact in terms of total traffic and HDVs on a link which would therefore equate to a Negligible effect (Not Significant) in terms of Severance which would be local and temporary. Driver Delay 8.11.16 On the basis of the volume of traffic generated by this phase of works it is not predicted to result in any material change to the operation of the highway network and as a result there will not be a material change in driver delay during this stage. 8.11.17 As a result, the magnitude of the impact is considered to be low on receptors which all have either a Low or Very Low sensitivity, resulting in a Negligible (Not Significant) effect overall, which would be local and temporary. Pedestrian Delay (including all non-motorised users) 8.11.18 Pedestrian delay is the increase in delay to pedestrians crossing a road as a result of the traffic flow and the facilities for pedestrians to cross the road. As per Table 8.3, pedestrian delay only becomes a consideration where vehicle flows in any peak hour are greater than 1,400 vehicles per hour and the increases are greater than 10%. 8.11.19 Links 8, 9, 11 and 12 have a flow greater than 1,400 vehicles per hour; however, each of these links experience an increase of less than 10% in total vehicles and the impact on the baseline is considered to have a negligible impact on pedestrian delay. Accordingly, this would result in a Negligible effect (Not Significant) effect in terms of pedestrian delay which would be local and temporary.
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Plowman Craven 46730 October 2024
8.11.20 Within the IEMA Guidance on the Environmental Assessment of Traffic and Movement (July 2023) Pedestrian Delay also includes delay to non-motorised users which is applicable to cyclists. Paragraph 3.26 states that “given the range of local factors and conditions that can influence pedestrian delay (e.g. a discrete delay may have a lesser impact in an urban environment than a rural setting), it is not considered wise to set down definitive thresholds. Instead, it is recommended that a competent traffic and movement expert use their judgement to determine whether pedestrian delay [including all non-motorised users] constitutes a significant effect” [brackets added by author]. 8.11.21 As shown at Figure 8.2 and Figure 8.3, within the study area, many of the links provide off-carriageway cycle routes/on-carriageway routes and signalised crossing points are provided along these routes to enable cyclists to cross the road if necessary. 8.11.22 On the basis of the volume of traffic generated by Phase 1A construction traffic it is not predicted to result in any material change to the delay experienced by non-motorised users and as a result there will not be a material change in delay during this stage. 8.11.23 As a result, the magnitude of the impact is considered to be low on receptors resulting in a Negligible (Not Significant) effect overall, which would be local and temporary. Pedestrian Amenity 8.11.24 Pedestrian amenity becomes a consideration when the change in total traffic or HDV flows exceeds 100%. As no link experiences an increase greater than 100%, this would result in a Negligible effect (Not Significant) in terms of pedestrian amenity which would be local and temporary. Fear and Intimidation 8.11.25 Fear and intimidation is set out in Table 8.3 and is a judgement based on the volume of traffic, HDV composition, proximity to people and the level of protection. The enabling works would add 8 two-way HDV movements on any given link during the peak hours and this quantity of additional HDVs would not be perceptible to a pedestrian. As such, the effect of the Proposed Development on fear and intimidation is considered to be Negligible (Not Significant). Accident and Safety 8.11.26 A full review of the PIC data is included in the ES Volume 3B. The TA has identified that there are no inherent safety issues within the road environment. 8.11.27 The increase in traffic flows on the wider study network as a result of the enabling works associated with the Proposed Development is low and therefore, the overall effect in relation to accidents and safety is considered to be Negligible (Not Significant).
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Plowman Craven 46730 October 2024
Demolition & Construction Phase – Scenario 3: Baseline Plus Peak Construction & Phase 1a (Relevant to Outline Application only) 8.11.28 Scenario 3 considers the 2023 Baseline traffic flows plus the traffic associated with the peak construction HDV movements. 8.11.29 The peak construction works traffic forecast has been determined using information provided in Chapter 5 of the ES. 8.11.30 This scenario includes the baseline as previously described in Scenario 1 plus the construction traffic (relevant to the Outline Application). The construction phase assessment is based on the peak period for the construction of the Proposed Development (i.e. the point in the construction programme where the most construction related works are anticipated to take place on-site). 8.11.31 This scenario does not account for any cumulative development traffic on the local transport network as the enabling works that have been considered are due to commence Q2 2030 and to represent a worst-case assessment in relation to a percentage impact. 8.11.32 This scenario does include traffic generated by Phase 1A, which will be occupied and in operation. 8.11.33 The maximum number of daily vehicles anticipated during peak construction is 168 vehicles (336 two-way movements). 8.11.34 The number of daily vehicles anticipated during Phase 1a is 53 vehicles (106 twoway movements). 8.11.35 The AM and PM vehicle trips have been calculated based on the average number of vehicles arriving across the day i.e. 10 working hours for the peak number of vehicles expected on-site. The daily vehicle trips set out in Table 8.21 have been assigned based on the proposed distribution for the HDVs as detailed within the TA. Table 8.21: Forecast Construction Works Traffic + Phase 1A
Vehicle Type
HDV (>7.5t + <7.5t) Phase 1a Total
Daily Vehicle Trips (AADT)
AM Peak Hour
PM Peak Hour
Arr
Dep
Two-way
Arr
Dep
Twoway
Arr
Dep
Twoway
168
168
336
17
17
34
17
17
34
53 221
53 221
106 442
1 18
1 18
2 36
4 21
4 21
8 42
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Plowman Craven 46730 October 2024
Distribution 8.11.36 The distribution of HDVs is set out in Table 8.22 below and is based on the same distribution as operational goods vehicles given that at this point the sources of materials are largely unknown. For clarity, 66% of construction movements have been equally distributed east and west on the A20 and 33% have been distributed south via Lewisham High Street. Table 8.22: Scenario 3 – HDV & LGV Distribution – 24hr AADT Link
HDVs
LGVs
Total
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
102 0 102 3 3 0 102 103 203 0 102 102 102 0 103
48 0 48 56 3 0 66 67 78 0 48 48 48 0 67
150 0 150 58 5 0 168 170 281 0 150 150 150 0 170
8.11.37 The AM and PM peak hour distribution of construction and Phase 1A HDVs is set out in Table 8.23. Table 8.23: Scenario 3 – HDV & LGV Distribution – AM Peak & PM Peak Link
1 2 3 4 5 6 7 8 9 10 11 12 13
HDVs
AM LGVs
Total
HDVs
PM LGVs
Total
10 0 10 0 0 0 10 10 20 0 10 10 10
2 0 2 1 0 0 2 2 4 0 2 2 2
12 0 12 2 0 0 12 13 24 0 12 12 12
10 0 10 0 0 0 10 10 20 0 10 10 10
4 0 4 4 0 0 5 5 6 0 4 4 4
14 0 14 4 0 0 15 15 26 0 14 14 14
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
Plowman Craven 46730 October 2024
14 15
0 10
0 2
0 13
0 10
0 5
0 15
8.11.38 The traffic impact of the Scenario 3 has been compared to the 2023 baseline traffic in Table 8.24. Table 8.24: 2023 Baseline Compared to Scenario 3 (24 hr AADT)
Link
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Location
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
2023 Baseline Total HDV Vehs
Scenario 3 Total HDV Vehs
% Change Total HDV Vehs
13460
1808
13610
1910
1.1%
5.6%
16765
1715
16765
1715
0.0%
0.0%
9806
1062
9956
1164
1.5%
9.6%
5505
1915
5563
1918
1.1%
0.1%
4208 5540 18402
2029 681 1797
4213 5540 18570
2032 681 1899
0.1% 0.0% 0.9%
0.1% 0.0% 5.7%
26071
4497
26241
4600
0.7%
2.3%
31058
2868
31339
3071
0.9%
7.1%
16459
2659
16459
2659
0.0%
0.0%
30618
3921
30768
4023
0.5%
2.6%
23703
1718
23853
1820
0.6%
5.9%
19646
1838
19796
1940
0.8%
5.5%
7274
669
7274
669
0.0%
0.0%
18410
2296
18580
2399
0.9%
4.5%
8.11.39 The traffic impact of the Scenario 3 (AM Peak Hour) has been compared to the 2023 baseline traffic in Table 8.25. Table 8.25: 2023 Baseline Compared to Scenario 3 (AM Peak)
Link
1 2 3
Location
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road)
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
2023 Baseline Total HDV Vehs
Scenario 3 Total HDV Vehs
% Change Total HDV Vehs
658
95
670
105
1.8%
10.6%
953
123
953
123
0.0%
0.0%
471
54
483
64
2.6%
18.8%
Plowman Craven 46730 October 2024
4 5 6 7 8 9 10 11 12 13 14 15
Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
274
94
275
95
0.5%
0.2%
196 315 941
102 44 104
197 315 953
102 44 114
0.2% 0.0% 1.3%
0.2% 0.0% 9.8%
1373
270
1385
281
0.9%
3.8%
1738
192
1761
212
1.4%
10.5%
857
158
857
158
0.0%
0.0%
1557
237
1570
248
0.8%
4.3%
1370
96
1382
106
0.9%
10.6%
1128
118
1140
128
1.1%
8.6%
371
42
371
42
0.0%
0.0%
999
154
1012
164
1.3%
6.6%
8.11.40 The traffic impact of the Scenario 3 (PM Peak Hour) has been compared to the 2023 baseline traffic in Table 8.26. Table 8.26: 2023 Baseline Compared to Scenario 3 (PM Peak)
Link
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Location
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
2023 Baseline Total HDV Vehs
Scenario 3 Total HDV Vehs
% Change Total HDV Vehs
762
81
776
91
1.8%
12.4%
1159
80
1159
80
0.0%
0.0%
421
55
435
66
3.3%
18.2%
334
104
338
105
1.2%
0.1%
266 355 1133
97 27 67
266 355 1148
97 27 77
0.0% 0.0% 1.3%
0.1% 0.0% 15.0%
1654
210
1669
220
0.9%
4.8%
2116
110
2142
131
1.2%
18.2%
1087
131
1087
131
0.0%
0.0%
1965
167
1979
178
0.7%
6.0%
1436
90
1450
100
1.0%
11.2%
1254
92
1268
102
1.1%
11.0%
531
36
531
36
0.0%
0.0%
1053
100
1068
110
1.4%
10.1%
Plowman Craven 46730 October 2024
8.11.41 As set out previously, the impact of the traffic associated with the construction needs to be considered in relation to Rule 1 and Rule 2 of the screening criteria. 8.11.42 In terms of the impact of the AADT flows this does not exceed 10% on any link. Therefore, considering Rule 1 (+30% of any link) and Rule 2 (+10% on sensitive links) of the IEMA Guidelines, the screening thresholds are not met or exceeded, and as such no links require further investigation. 8.11.43 In the AM and PM peak hours, no links experience traffic increases exceeding 30% in terms of Total Vehicles or HDVs however links 1, 3, 7, 9, 12, 13 and 15 experience increases over 10% on HDVs only. However, as none of the above links have high sensitivity, none conform to Rule 2. Therefore, considering Rule 1 (+30% of any link) and Rule 2 (+10% on sensitive links) of the IEMA Guidelines, the screening thresholds are not met or exceeded, and as such no links require further investigation. Severance 8.11.44 As outlined above, severance is the perceived division that can occur within a community when it becomes separated by a major traffic artery. 8.11.45 The maximum increase in movements in either peak hour is 20 i.e. one HDV circa 3 minutes where there is currently a signalised crossing across Rennell Street; accordingly, this equates to a Negligible magnitude of impact in terms of total traffic and HDVs on a link which would therefore equate to a Negligible effect (Not Significant) in terms of Severance which would be local and temporary. Driver Delay 8.11.46 On the basis of the volume of traffic generated by this phase of works it is not predicted to result in any material change to the operation of the highway network and as a result there will not be a material change in driver delay during this stage. As a result, the magnitude of the impact is considered to be low on receptors which all have a Low sensitivity, resulting in a Negligible effect (Not Significant) overall, which would be local and temporary. Pedestrian Delay (including all non-motorised users) 8.11.47 Pedestrian delay is the increase in delay to pedestrians crossing a road as a result of the traffic flow and the facilities for pedestrians to cross the road. As per Table 8.3, pedestrian delay only becomes a consideration where vehicle flows in any peak hour are greater than 1,400 vehicles per hour and the increases are greater than 10%. 8.11.48 Links 8, 9, 11 and 12 have a flow greater than 1,400 vehicles per hour; however, each of these links experience an increase of less than 10% in total vehicles and the impact on the baseline is considered to have a negligible impact on pedestrian delay. Accordingly, this would result in a Negligible effect (Not Significant) effect in terms of pedestrian delay which would be local and temporary.
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Plowman Craven 46730 October 2024
8.11.49 Within the IEMA Guidance on the Environmental Assessment of Traffic and Movement (July 2023) Pedestrian Delay also includes delay to non-motorised users which is applicable to cyclists. Paragraph 3.26 states that “given the range of local factors and conditions that can influence pedestrian delay (e.g. a discrete delay may have a lesser impact in an urban environment than a rural setting), it is not considered wise to set down definitive thresholds. Instead, it is recommended that a competent traffic and movement expert use their judgement to determine whether pedestrian delay [including all non-motorised users] constitutes a significant effect” [brackets added by author]. 8.11.50 As shown at Figure 8.2, there is an existing signalised pedestrian crossing on Rennell Street, which provides a safe crossing point for pedestrians. 8.11.51 On the basis of the volume of traffic generated by Scenario 3 it is not predicted to result in any material change to the delay experienced by non-motorised users and as a result there will not be a material change in delay during this stage. 8.11.52 As a result, the magnitude of the impact is considered to be low on receptors resulting in a Negligible (Not Significant) effect overall, which would be local and temporary. Pedestrian Amenity 8.11.53 Pedestrian amenity becomes a consideration when the change in total traffic or HDV flows exceeds 100%. As no link experiences an increase greater than 100%, this would result in a Negligible (Not Significant) effect in terms of pedestrian amenity which would be local and temporary. Fear and Intimidation 8.11.54 Fear and intimidation is a judgement based on the volume of traffic, HDV composition, proximity to people and the level of protection. The construction works would add up to 20 two-way HDV movements on Link 9, and up to 10 two-way HDV movements on any other link during the peak hours. This quantity of additional HDVs would not be perceptible to a pedestrian. As such, the effect of the Proposed Development on fear and intimidation is considered to be Negligible effect (Not Significant). Accident and Safety 8.11.55 A full review of the PIC data is included in the TA. The TA has identified that there are no inherent safety issues within the road environment. 8.11.56 The increase in traffic flows on the wider study network as a result of the construction traffic associated with the Proposed Development is low and therefore, the overall effect in relation to accidents and safety is considered to be Negligible effect (Not Significant).
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
Plowman Craven 46730 October 2024
Operational Phase – Scenarios 4 & 5: Core Assessment Future Year 8.11.57 The Future Baseline comprises the 2023 Baseline plus the movements associated with the known committed developments (i.e. those with planning permission). For clarity this assumes the full completion of all committed development and the full Proposed Development as set out previously. Proposed Development Operational Traffic (Phase 1a) 8.11.58 Scenario 5 includes the operational traffic for Phase 1a when fully built-out and occupied. The operational traffic is shown in Tables 8.27-29. Table 8.27: Proposed Development (Phase 1a) Traffic – AADT
Link 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Location Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
Total Vehicles 37 0 37 56 3 0 55 56 56 0 37 37 37 0 56
HDV 2 0 2 3 3 0 2 3 3 0 2 2 2 0 3
Total Vehicles 1 0 1 1 0 0 1 1 1 0 1 1 1 0 1
HDV 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Table 8.28: Proposed Development (Phase 1a) Traffic – AM Peak
Link 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Location Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
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Plowman Craven 46730 October 2024
Table 8.29: Proposed Development (Phase 1a) Traffic – PM Peak
Link 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Location Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
Total Vehicles 3 0 3 4 0 0 4 4 4 0 3 3 3 0 4
HDV 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
8.11.59 The daily vehicle trips set out in Tables 8.27-29 have been distributed on the network, as detailed within the TA. 8.11.60 The traffic impact of the Scenario 5 has been compared to Scenario 4 traffic in Tables 8.30-32. Table 8.30: Scenario 4 Compared to Scenario 5 – 24 hr AADT
Link
1 2 3 4 5 6 7 8 9 10 11 12
Location
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street)
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
Scenario 4 Total HDV Vehs
Scenario 5 Total HDV Vehs
% Change Total HDV Vehs
13969
1806
14006
1808
0.3%
0.1%
16765
1715
16765
1715
0.0%
0.0%
10315
1060
10352
1062
0.4%
0.2%
5449
1912
5505
1915
1.0%
0.1%
4205 5540 19035
2026 681 1795
4208 5540 19090
2029 681 1797
0.1% 0.0% 0.3%
0.1% 0.0% 0.1%
26703
4495
26759
4497
0.2%
0.1%
32501
2866
32557
2868
0.2%
0.1%
18646
2659
18646
2659
0.0%
0.0%
31534
3919
31571
3921
0.1%
0.0%
24618
1716
24656
1718
0.2%
0.1%
Plowman Craven 46730 October 2024
13 14 15
Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
20562
1836
20599
1838
0.2%
0.1%
7274
669
7274
669
0.0%
0.0%
18900
2293
18955
2296
0.3%
0.1%
Table 8.31: Scenario 4 Compared to Scenario 5 – AM Peak
Link
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Location
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
Scenario 4 Total HDV Vehs
Scenario 5 Total HDV Vehs
% Change Total HDV Vehs
696
95
697
95
0.1%
0.1%
953
123
953
123
0.0%
0.0%
509
54
510
54
0.2%
0.2%
274
94
275
95
0.5%
0.2%
196 315 986
102 44 104
197 315 987
102 44 104
0.1% 0.0% 0.1%
0.2% 0.0% 0.1%
1417
270
1419
271
0.1%
0.1%
1839
192
1840
192
0.1%
0.1%
1003
158
1003
158
0.0%
0.0%
1620
237
1621
238
0.1%
0.0%
1433
96
1433
96
0.1%
0.1%
1191 371 1038
118 42 154
1192 371 1039
118 42 154
0.1% 0.0% 0.1%
0.1% 0.0% 0.1%
Table 8.32: Scenario 4 Compared to Scenario 5 – PM Peak
Link
1 2 3 4 5 6 7
Location
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
Scenario 4 Total HDV Vehs
Scenario 5 Total HDV Vehs
% Change Total HDV Vehs
804
81
806
81
0.3%
0.0%
1159
80
1159
80
0.0%
0.0%
463
55
466
55
0.6%
0.1%
334
104
338
104
1.2%
0.1%
266 355 1189
97 27 67
266 355 1193
97 27 67
0.0% 0.0% 0.3%
0.1% 0.0% 0.1%
Plowman Craven 46730 October 2024
8 9 10 11 12 13 14 15
Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
1711
210
1715
210
0.2%
0.0%
2235
110
2239
110
0.2%
0.1%
1263
131
1263
131
0.0%
0.0%
2042
167
2045
167
0.1%
0.0%
1513
90
1516
90
0.2%
0.0%
1331 531 1095
92 36 100
1334 531 1099
92 36 100
0.2% 0.0% 0.4%
0.0% 0.0% 0.1%
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8.11.61 As set out previously, the impact of the traffic associated with the Proposed Development needs to be considered in relation to Rule 1 and Rule 2 of the screening criteria. 8.11.62 In terms of the impact of total vehicles, no links exceed do not exceed 10% or 30%. Therefore, considering Rule 1 (+30% of any link) and Rule 2 (+10% on sensitive links) of the IEMA Guidelines, the screening thresholds are not met or exceeded, and as such no links require further investigation. Severance 8.11.63 No Link experiences a change in total traffic or HDV flows greater than 30%; accordingly, this equates to a Negligible magnitude of impact in terms of total traffic and HDVs on a link which would therefore equate to a Negligible effect (Not Significant) in terms of Severance which would be local and permanent. Driver Delay 8.11.64 Within the Transport Assessment an assessment of driver delay has been undertaken. The assessment has shown that there are no significant changes in driver delay as a result of Phase 1a. 8.11.65 As a result, the magnitude of the impact is considered to be low on receptors which all have either a Low or Very Low sensitivity, resulting in a Negligible (Not Significant) effect overall, which would be local and permanent. Pedestrian Delay (including all non-motorised users) 8.11.66 Pedestrian delay is the increase in delay to pedestrians crossing a road as a result of the traffic flow and the facilities for pedestrians to cross the road. Pedestrian delay only becomes a consideration where vehicle flows in any peak hour are greater than 1,400 vehicles per hour and the increases are greater than 10%. 8.11.67 Links 8, 9, 11 and 12 have a flow greater than 1,400 vehicles per hour however each of these links experience an increase of less than 10% in total vehicles and the impact on the baseline is considered to have a negligible impact on pedestrian delay. Accordingly, this would result in a Negligible (Not Significant) effect in terms of pedestrian delay which would be local and permanent. Pedestrian Amenity 8.11.68 Pedestrian amenity becomes a consideration when the change in total traffic or HDV flows exceeds 100%. As no link experiences an increase greater than 100%, this would result in a Negligible (Not Significant) effect in terms of pedestrian amenity which would be local and permanent.
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Fear and Intimidation 8.11.69 Fear and intimidation is a judgement based on the volume of traffic, HDV composition, proximity to people and the level of protection. The operational traffic would add no more than 2 two-way HDV movements on any given link during the peak hours and this quantity of additional HDVs would not be perceptible to a pedestrian. As such, the effect of the operational traffic associated with the Proposed Development on fear and intimidation is considered to be Negligible (Not Significant). Accident and Safety 8.11.70 A full review of the PIC data is included within the TA, which identified that there are no inherent safety issues within the road environment. 8.11.71 The increase in traffic flows on the wider study network as a result of the operational traffic associated with Phase 1a is low and therefore, the overall effect in relation to accidents and safety is considered to be Negligible (Not Significant).
8.12 Scenarios 4 & 6: Future Baseline Vs Full Development 8.12.1 This Assessment Scenario provides an understanding of the effects of the completed Proposed Development on the Future Baseline. 8.12.2 The Proposed Development operational traffic is summarised in Tables 8.33-35. Table 8.33: Proposed Development Traffic – AADT
Link 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Location Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
Total Vehicles -405 -183 -588 -120 2 -49 -179 -235 -232 -243 -279 -234 -190 -89 -302
HDV 9 0 9 5 2 0 8 1 2 0 9 9 9 0 29
Total Vehicles -18 -7
HDV 1 0
Table 8.34: Proposed Development Traffic – AM Peak
Link 1 2
Location Lewisham High Street (south of Ladywell Road) Ladywell Road
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3 4 5 6 7 8 9 10 11 12 13 14 15
Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
-25 2 0 -2 -12 -15 -23 -9 -14 -11 -10 -3 -19
1 0 0 0 1 0 0 0 1 1 1 0 2
Total Vehicles -16 -10 -26 -11 0 -3 -3 -6 2 -13 -9 -8 -4 -5 -4
HDV 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1
Table 8.35: Proposed Development Traffic – PM Peak
Link 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Location Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
8.12.3 The vehicle trips set out in the tables above have been distributed using the same methodology as the Proposed Development trips, as detailed within the TA. 8.12.4 The traffic impact of the Scenario 6 has been compared to the Future baseline traffic in Table 8.36. Table 8.36: Scenario 4 Compared to Scenario 6 – 24 hr AADT
Link
1 2
Location
Lewisham High Street (south of Ladywell Road) Ladywell Road
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
Scenario 4 Total HDV Vehs
Scenario 6 Total HDV Vehs
% Change Total HDV Vehs
13969
1806
13564
1815
-3.0%
0.5%
16765
1715
16582
1715
-1.1%
0.0%
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3 4 5 6 7 8 9 10 11 12 13 14 15
Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
10315
1060
9726
1069
-6.0%
0.9%
5449
1912
5329
1917
-2.3%
0.2%
4205 5540 19035
2026 681 1795
4207 5491 18857
2028 681 1803
0.0% -0.9% -0.9%
0.1% 0.0% 0.5%
26703
4495
26468
4496
-0.9%
0.0%
32501
2866
32269
2868
-0.7%
0.1%
18646
2659
18403
2659
-1.3%
0.0%
31534
3919
31256
3928
-0.9%
0.2%
24618
1716
24384
1725
-1.0%
0.5%
20562
1836
20372
1845
-0.9%
0.5%
7274
669
7185
669
-1.2%
0.0%
18900
2293
18597
2322
-1.6%
1.2%
8.12.5 The traffic impact of the Scenario 6 (AM Peak Hour) has been compared to the Future baseline traffic in Table 8.37. Table 8.37: Scenario 4 Compared to Scenario 6 – AM Peak
Link
1 2 3 4 5 6 7 8 9 10 11 12 13 14
Location
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street) Lewis Grove Belmont Hill Lee High Road Lewisham High Street (west of Lewis Grove) Rennell Street Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210)
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
Scenario 4 Total HDV Vehs
Scenario 6 Total HDV Vehs
% Change Total HDV Vehs
696
95
678
96
-2.6%
0.6%
953
123
947
123
-0.7%
0.0%
509
54
484
54
-4.9%
1.1%
274
94
275
95
0.6%
0.3%
196 315 986
102 44 104
197 313 973
102 44 104
0.0% -0.6% -1.3%
0.1% 0.0% 0.5%
1417
270
1402
270
-1.1%
0.0%
1839
192
1816
192
-1.2%
0.0%
1003
158
994
158
-0.9%
0.0%
1620
237
1607
238
-0.8%
0.2%
1433
96
1422
96
-0.7%
0.6%
1191 371
118 42
1181 368
119 42
-0.9% -0.9%
0.5% 0.0%
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15
Molesworth Road
1038
154
1019
156
-1.8%
1.2%
8.12.6 The traffic impact of the Scenario 6 (PM Peak Hour) has been compared to the Future baseline traffic in Table 8.38. Table 8.38: Scenario 4 Compared to Scenario 6 – PM Peak
Link
1 2 3 4
Location
Lewisham High Street (south of Ladywell Road) Ladywell Road Lewisham High Street (north of Ladywell Road) Lewisham High Street (north of Molesworth Street)
Scenario 4 Total HDV Vehs
Scenario 6 Total HDV Vehs
% Change Total HDV Vehs
804
81
787
81
-2.0%
0.0%
1159
80
1149
80
-0.9%
0.0%
463
55
436
55
-5.7%
0.0%
334
104
323
104
-3.2%
0.1% 0.2% 0.0% 0.1% 0.2% 0.3%
5
Lewis Grove
266
97
266
97
-0.1%
6
Belmont Hill
355
27
353
27
-0.8%
7
Lee High Road
1189
67
1187
67
-0.2%
8
Lewisham High Street (west of Lewis Grove)
1711
210
1705
210
-0.3%
9
Rennell Street
2235
110
2237
110
0.1%
1263
131
1250
131
-1.1%
0.0%
2042
167
2033
167
-0.5%
0.0%
1513
90
1505
90
-0.6%
0.0%
1331 531 1095
92 36 100
1327 527 1091
92 36 101
-0.3% -0.9% -0.4%
0.0% 0.0% 0.6%
10 11 12 13 14 15
Lewisham High Street (north of Rennell Street) Loampit Vale (east of A2210) Loampit Vale (Between A2210 & Elmira Street) Loampit Vale (west of A2210) Thurston Road (west of A2210) Molesworth Road
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8.12.7 As set out previously, the impact of the traffic associated with the Proposed Development needs to be considered in relation to Rule 1 and Rule 2 of the screening criteria. 8.12.8 In terms of the impact of total vehicles, no links exceed 10%. Therefore, considering Rule 1 (+30% of any link) and Rule 2 (+10% on sensitive links) of the IEMA Guidelines, the screening thresholds are not met or exceeded, and as such no links require further investigation. 8.12.9 The Proposed Development will remove the existing multi-storey car park on-site. This results in a significant reduction in traffic attracted to the shopping centre. As summarised above, the majority of links will experience a reduction in traffic as a result of the Proposed Development. Severance 8.12.10 Most links experience a low reduction in traffic as a result of the Proposed Development. This would therefore equate to a beneficial effect in terms of Severance. Driver Delay 8.12.11 Within the Transport Assessment, an assessment of driver delay has been undertaken. Whilst the Proposed Development results in a reduction in traffic, it is inevitable that within a network that some routes will improve in journey times and some will get worse as the proposals. However, the assessment has shown that there are no significant changes in driver delay as a result of the Proposed Development. 8.12.12 As a result, the magnitude of the impact is considered to be Negligible (Not Significant) effect overall. Pedestrian Delay (including all non-motorised users) 8.12.13 Pedestrian delay is the increase in delay to pedestrians crossing a road as a result of the traffic flow and the facilities for pedestrians to cross the road. 8.12.14 Links 8, 9, 11 and 12 have a flow greater than 1,400 vehicles per hour however each of these links experience a minor reduction in traffic. As such, it is considered that the impact on the baseline is considered to have a negligible impact on pedestrian delay. Accordingly, this would result in a Negligible effect (Not Significant) in terms of pedestrian delay. 8.12.15 On the basis of the volume of traffic generated by the Proposed Development it is not predicted to result in any material change to the delay experienced by non-motorised users and as a result there will not be a material change in delay during the operational phase of the Proposed Development. Pedestrian Amenity 8.12.16 Pedestrian amenity becomes a consideration when the change in total traffic or HDV flows exceeds 100%. As no link experiences an increase greater than 100%, this would result in a Negligible effect (Not Significant) in terms of pedestrian amenity which would be local and temporary. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
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Fear and Intimidation 8.12.17 Fear and intimidation is a judgement based on the volume of traffic, HDV composition, proximity to people and the level of protection. The operational traffic would add no more than 2 two-way HDV movements on any given link during the peak hours and this quantity of additional HDVs would not be perceptible to a pedestrian. As such, the effect of the operational traffic associated with the Proposed Development on fear and intimidation is considered to be Negligible (Not Significant). Accident and Safety 8.12.18 A full review of the PIC data is included in the TA, which identified that there are no inherent safety issues within the road environment. 8.12.19 As noted above, the Proposed Development will result in a reduction in traffic on the local highway network. Therefore, the overall effect in relation to accidents and safety is considered to be Minor Beneficial.
8.13 Mitigation, Monitoring and Residual Effects Enabling and Construction 8.13.1 It is proposed that a Construction Environmental Management Plan (CEMP) will be implemented to minimise the risk of the likely environmental effects occurring during the construction phases and to effectively reduce the effect associated with construction activities, including the use of defined routes and timing. The CEMP will be submitted and conditioned to both the Outline and Detailed Applications and subsequent planning permissions. This will be secured by planning condition. The type of vehicle that will transport materials to the Site will be determined in advance to ensure safe and efficient delivery taking into consideration local constraints. The future detailed CEMP(s) will adhere to the Outline CEMP submitted with the Detailed and Outline Applications. 8.13.2 Construction traffic movements will be kept to agreed working hours where practicable and designed to minimise disruption to the highway network and local residents. 8.13.3 The CEMP will also include the following measures: • • • • • • •
Management of construction traffic including the avoidance of any sensitive Site boundaries; The Construction Logistics and Community Safety (CLOCS) standards for all vehicles shall be adopted; Safety for pedestrians through separate pedestrian gates and footpaths; Maintenance and protection of existing public and private routine and emergency access routes; Details of access and egress with wheel cleaning facilities and agreed HGVs access routes to and from the Site including specific measures relating to the transportation of any hazardous loads; Procedures for the management of deliveries (including organised time slots / just in time deliveries); Construction deliveries would be carefully planned with delivery times agreed with each contractor using a web-based booking system. Delivery schedules would be produced to look at the profiles of forthcoming deliveries to regulate journeys and eliminate bottlenecks and reduce over ordering of materials and waste generation; and
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•
A proportion of the trips will be scheduled to arrive at the construction Site outside of peak hours, thus avoiding the busiest times on the local road network.
8.13.4 The measures set out in the CEMP will be implemented and monitored in accordance with best practice construction management processes. Further details of remediation, Site preparation, enabling works and construction activities is provided in Chapter 5 of the ES. Completed Development Mitigation 8.13.5 The proposed sustainable transport and highway mitigation which are embedded in the design of the Proposed Development have been set out previously. The additional mitigation is set out below: • • • • •
Site-wide Outline Travel Plan which accompanies the Application will be secured by planning condition and implemented by the Site management team; Delivery and Servicing Management Plan Operational Waste Management Strategy (OWMS); Car club bays; and Contribution towards off-site active travel improvements.
8.13.6 These additional mitigation measures are designed to minimise the effect of the Proposed Development and will be secured by planning condition. 8.13.7 The introduction of the additional mitigation would result in a low magnitude of impact on all links resulting in a Negligible (Not Significant) effect overall, which would be local and permanent. Residual Effects 8.13.8 All of the residual effects resulting from the Proposed Development are presented in Table 8.39 below. Climate Change 8.13.9 Climate change will not have a direct effect on severance, driver delay, pedestrian delay or amenity, fear and intimidation or accidents and safety. However, changing travel behaviour in response to climate change concerns is expected to result in a switch to more sustainable and active travel modes, lower emission vehicles, and encourage advances in technology which in turn would support improved telecommuting and flexible working, which would reduce the scale of peak hour travel. 8.13.10 The Proposed Development, designed based on current behaviour patterns, is therefore considered to be resilient. Any future changes in travel patterns would serve to increase benefits for users of the site as well as visitors and employees of the local area, although this benefit is not expected to be of a scale that would change the overall residual effects and their significance.
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Table 8.39: Summary of Effects DESCRIPTION SUMMARY OF SIGNIFICANCE OF EFFECTS OF MITIGATION / MAJOR / POSITI SIGNIFICANT RECEPTOR ENHANCEMENT ST / MODERATE VE / P/ EFFECTS MEASURES D/I MT / / MINOR / NEGATI T LT NEGLIGIBLE VE Demolition & Construction
Effects on Severance Effects on Driver Delay Effects on Pedestrian Delay (including all non-motorised users) Effects on Pedestrian Amenity Effects on Fear and Intimidation Effects on Accident and Safety Effects on Hazardous Loads Effects on Severance
All Links
All Links
SIGNIFICANCE OF RESIDUAL EFFECTS RELEVANT RELEVANT MAJOR / POSITIV LEGISLATI ST / POLICY MODERATE E/ P/ ON D / I MT / / MINOR / NEGATIV T LT NEGLIGIBLE E
Negligible
N/A
T
D
MT
Negligible
N/A
T
D
MT
Negligible
N/A
T
D
MT
Negligible
N/A
T
D
MT
Negligible
N/A
T
D
MT
Negligible
N/A
T
D
MT
Negligible
N/A
T
D
MT
Negligible
N/A
T
D
Negligible
N/A
T
Negligible
N/A
T
Negligible
N/A
P
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CEMP
Town and NPPG, Country NPPF, IEMA Planning Act MT Guidelines 1990
Negligible
N/A
T
D
MT
Negligible
N/A
T
D
MT
D
MT
Negligible
N/A
T
D
MT
D
MT
Negligible
N/A
T
D
MT
Negligible
N/A
P
D
MT
D
MT
Phase 1a TP, DSMP, Car Club etc…
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Effects on Driver Delay Effects on Pedestrian Delay (including all non-motorised users) Effects on Pedestrian Amenity Effects on Fear and Intimidation Effects on Accident and Safety Effects on Hazardous Loads
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
MT
Town and NPPG, Country NPPF, IEMA Planning Act Guidelines 1990
Completed Development
Effects on Severance Effects on Driver Delay Effects on Pedestrian Delay (including all non-motorised users) Effects on Pedestrian Amenity
All Links
Minor Positive
N/A
P
D
MT
Minor Positive
N/A
P
D
LT
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
LT
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
MT
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 8 – Transport & Accessibility
TP, DSMP, Car Club
Negligible
N/A
P
D
Town and NPPG, Country NPPF, IEMA Planning Act LT Guidelines 1990
Negligible
N/A
P
D
LT
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Effects on Fear and Intimidation Effects on Accident and Safety Effects on Hazardous Loads
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
LT
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
LT
Negligible
N/A
P
D
MT
Negligible
N/A
P
D
LT
Key/Notes: Residual Effect Scale = Negligible / Minor / Moderate / Major Nature = Beneficial or Adverse D = Direct / I = Indirect P = Permanent / T = Temporary St = Short Term / Mt = Medium Term / Lt = Long Term N/A = not applicable / not assessed
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9.0 Flood Risk and Drainage 9.1
Introduction
9.1.1 This Chapter considers the potential effects of the Proposed Development on Flood Risk and Drainage matters. Where appropriate, it also identifies proposed mitigation measures to prevent, minimise or control likely the detrimental effects arising from the Proposed Development and the subsequent anticipated residual effects. 9.1.2 The effects of the Proposed Development are considered over both the demolition & construction and operational phases. 9.1.3 The main Flood Risk and Drainage issues covered in this Chapter include the following: • • • •
Impact of the Proposed Development on the risk of flooding from different sources, and in particular fluvial flood risk as the site is in the floodplain of the River Ravensbourne and River Quaggy. Sustainable urban drainage and associated impacts on the risk of flooding associated with surface water discharge, potential pollution of the water environment and impact on sewer network. Impact of increased wastewater generation and potable water demand on existing water infrastructure, and approach to reduce pressure on water resources. Impact of construction activities on local water resources.
9.1.4 This Chapter (and its associated figures and appendices) should be read together with the Introductory Chapters of this ES (Chapters 1 – 5), as well as Chapter 17: Effect Interactions. 9.1.5 This Chapter is accompanied by the following appendices prepared by Expedition: • •
Appendix 9.1: Flood Risk Assessment Appendix 9.2: Sustainable Drainage Strategy
9.1.6 This Chapter should also be read alongside the Foul and Utilities Assessment prepared by WSP and the River Impact Assessment prepared by Expedition to accompany this planning application.
Competence 9.1.7 This Chapter was prepared by Alex Garman an Associate with 11 years of experience and Jamie Skipper Reed, a Civil Engineer, with 2 years of experience in sustainable water management. The preparation of this Chapter has been supervised by Fred Labbé, the Director of the civil engineering team at Expedition. Fred Labbé has close to 25 years of experience in sustainable water management in the UK, including over 15 years of experience in writing similar chapters for Environmental Statements.
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9.2
Legislation, Planning Policy and Guidance
9.2.1 The following national, regional and local planning policy and guidance is of relevance to the assessment of the effects of the Proposed Development in relation to Flood Risk and Drainage.
Planning Policy Context Legislation Water Framework Directive, 2000 (Ref 9.1) 9.2.2 The Water Framework Directive 2000/60/EC (‘WFD’) applies to all European Union (‘EU’) water bodies and aims to make sure they are protected from further deterioration, and that improvements in water quality are made. The assessment and protection of water bodies should be undertaken irrespective of political or administrative boundaries by implementing River Basin Management Plans to be prepared within a formal series of six-year cycles, following the identification of River Basin Districts. In general terms, there is an onus on developers to protect and, if possible, enhance water bodies close to proposed developments. Following the United Kingdom’s exit from the European Union, this Directive has been converted into UK legislation. Flood Directive, 2007 (Ref 9.2) 9.2.3 The Flood Directive 2007/60/EC came into force in November 2007. This Directive requires Member States to assess whether water courses and coastlines are at risk from flooding, to map the flood extent and assets and humans at risk in these areas and to take adequate and coordinated measures to reduce this flood risk. The Directive requires Member States to carry out a preliminary assessment of flood risk by 2011, to draw up flood risk maps by 2013 and to establish flood risk management plans focused on prevention, protection, and preparedness by 2015. The Directive is to be implemented in co-ordination with the Water Framework Directive. Following the United Kingdom’s exit from the European Union, this Directive has been converted into UK legislation. Land Drainage Acts, 1991 and 1994 (Ref 9.3) 9.2.4 The Land Drainage Acts 1991 as amended by the Land Drainage Act 1994 sets out the responsibilities given to the Environment Agency (‘EA’), Internal Drainage Boards, Local Authorities (‘LAs') and riparian landowners in regard to land drainage. Under the Acts, the EA and LAs have discretionary powers of management and maintenance for ‘Main Rivers’ and ‘Ordinary Watercourses’ respectively. It is the riparian owner, i.e. the owner of the land through which the watercourse flows, who is ultimately responsible for the maintenance of the relevant section of the watercourse. It covers provision for flood risk management works, control of flow of watercourses, controls discharge rates including levies, and duties with respect to the environment and recreation.
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Water Resources Act, 1991 (Amendment) (England and Wales) Regulations, 2009 (Ref 9.4) 9.2.5 The Water Resources Act (as amended by the Water Resources Act 1991 Regulations 2009) relates to the control of the water environment. The main aspects of the Act (as amended) which are relevant to the Proposed Development include provisions concerning land drainage, flood mitigation and controlling discharges to watercourses to prevent water pollution. It also outlines the functions and responsibility of the EA in regulating the water environment. Water Industry Act, 1991 (Ref 9.5) 9.2.6 The Water Industry Act consolidates previous legislation on water supply and drainage services and covers a wide range of activities required of the privatised water companies that were created in 1989. The main relevant provisions relate to trade effluent discharges made to drain for which the privatised companies act as the regulatory authorities. The Environmental Permitting Regulations, 2010 (Ref 9.6) 9.2.7 The Environmental Permitting Regulations of 2010 replaces parts of the Water Resources Act 1991 that relate to the regulation of discharges to controlled surface waters. Water Act, 2003 (Ref 9.7) 9.2.8 The Water Act 2003 amends the Water Resources Act 1991 and the Water Industry Act 1991. The Act brings about a number of changes, including streamlining arrangements for flood defence organisation, funding and changes to the types of abstraction licences, and places a duty on water companies to conserve water and prepare for drought. It formalises the Government’s commitment to the sustainable management and use of water resources. Water Environment (Water Framework Directive) (England and Wales) Regulations, 2003 (Ref 9.8) 9.2.9 This transposes the requirements of the WFD into UK law. Eleven River Basin Districts have been identified in England and Wales. The Regulations include a requirement for water bodies (categorised as: ‘rivers’; ‘lakes’; ‘transitional waters’; ‘coastal waters’; or ‘groundwaters’) to achieve ‘good’ status with respect to ecology and water chemistry by 2015. Progress is monitored by the EA in its role as the ‘competent authority’. Flood and Water Management Act, 2010 (Ref 9.9) 9.2.10 The Flood and Water Management Act 2010 implements the recommendations from Sir Michel Pitt's Review of the floods in 2007 and places a series of responsibilities on County and Unitary Councils as Lead Local Flood Authorities (‘LLFAs’) with the intention of improving flood risk management. It sets the requirements for the development, maintenance, application and monitoring of a strategy for local flood risk management in its area. It also removes the automatic right of connection into public water drains and places the onus on LAs to adopt Sustainable Drainage Systems (‘SuDS’). The Act enables lead local authorities to delegate flood or coastal erosion functions to another risk management authority by agreement.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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Environment Act, 1995 (Ref 9.10) 9.2.11 The Environment Act 1995 (Section 57) establishes the Environment Agency and The Scottish Environment Protection Agency bodies, and provides for the transfer of functions, property, rights and liabilities to those bodies concerning general functions with respect to pollution control, provision with respect to water, environmental and recreational duties including sites of special interest, codes of practice with respect to environmental and recreational duties, and provision with respect to flooding and coastal change. It makes provisions for a risk-based framework for the identification, assessment and management of contaminated land within the UK. The provisions of the Act came into effect in April 2000 and are aimed at ensuring that actions taken with respect to contaminated land are directed by a technical assessment of risk that exists in the source / pathway / receptor scenario (pollutant linkage). This extends to preventing the contamination of controlled waters. Environment Act, 2021 (Ref 9.11) 9.2.12 The Environment Act 2021 aims to improve air and water quality, protect wildlife, increase recycling and reduce plastic waste. The Act is part of a new legal framework for environmental protection, following the exist of the UK from the European Union. Part 6 sets the requirements for protection of the water environment, including water resources and drought management plans, storm overflows, regulation of water and sewerage undertakers, groundwater abstraction, water quality and land drainage. Flood Risk Regulations, 2009 (Ref 9.12) 9.2.13 The Flood Risk Regulations 2009 implement the EU Flood Directive in England. They provide a framework for managing flood risk over a 6-year cycle, and require: • • • •
Production of a Preliminary Flood Risk Assessment (‘PFRA’); Identification of potential significant risk, referred to as flood risk areas (‘FRAs’); Mapping of flood hazard and risk; and Flood Risk Management Plans, setting out measures and actions to reduce the risk.
9.2.14 The Regulations require that each of the four elements identified above be reviewed and updated where necessary, at least every six years.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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National 9.2.15 The following national level policy and guidance documents are of relevance to the Proposed Development: National Planning Policy Framework (NPPF), 2023 (Ref 9.13) 9.2.16 The National Planning Policy Framework (‘NPPF’) sets out how local authorities should meet the challenges presented by climate change, flooding and coastal change. Chapter 14 (149) states that “Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures.” 9.2.17 Footnote 55 to the NPPF states that a site-specific flood risk assessment should be provided for all developments in Flood Zones 2 and 3, and that for Flood zone 1, an assessment should be provided for: • • • •
Sites of 1 hectare or more; Land which has been identified by the Environment Agency (EA) as having critical drainage problems; Land identified in a strategic flood risk assessment as being at increased flood risk in future; or Land that may be subject to other sources of flooding, where its development would introduce a more vulnerable use.
Planning Practice Guidance (PPG) (Ref 9.14) 9.2.18 To accompany the NPPF, the Planning Practice Guidance (‘PPG’) provides web-based advice on various topics associated with planning. For flood risk and coastal change, it “advises how to take account of and address the risks associated with flooding and coastal change in the planning stage.” 9.2.19 The NPPF sets strict tests to protect people from flooding, and the PPG states that the following steps are to be followed to assess a new development in planning: • • •
Assess flood risk; Avoid flood risk; and Manage and mitigate flood risk.
Non-statutory technical standards for sustainable drainage systems, 2015 (Ref 9.15) 9.2.20 This document details the standards for sustainable drainage systems under specific topic headings: Flood risk outside the development, Peak flow control, Volume control, Flood risk within the development, Structural integrity, Designing for maintenance considerations and, Construction.
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Regional The London Plan, March 2021 (Ref 9.16) 9.2.21 The London Plan – The Spatial Development Strategy for Greater London March 2021 is the current overall strategy plan which runs from 2019 to 2041. 9.2.22 The London Plan sets out a fully integrated economic, environmental, transport and social development framework to 2041 and includes the following policies of relevance to this chapter: 9.2.23 Policy SI 12: ‘Flood Risk Management’ requires developments to manage current and expected flood risk from all sources across London in a sustainable and cost-effective way in collaboration with the Environment Agency, the Lead Local Flood Authorities, developers, and infrastructure providers. It states that Development Plans should use the Mayor’s Regional Flood Risk Appraisal and their Strategic Flood Risk Assessment as well as Local Flood Risk Management Strategies to identify areas where flood risk issues exist and develop actions and policy approaches aimed at reducing these risks. Development Plans and proposals should contribute to the delivery of measures set out in Thames Estuary 2100 Plan. 9.2.24 Policy SI 13: ‘Sustainable Drainage’ states that development proposals should aim to achieve greenfield run-off rates and ensure that surface water run-off is managed as close to its sources as possible. There should be a preference for green over grey features, in line with the following drainage hierarchy: • • • • • •
rainwater use as a resource (for example rainwater harvesting, blue roofs for irrigation), rainwater infiltration to ground at or close to source, rainwater attenuation in green infrastructure features for gradual release (for example green roofs, rain gardens), rainwater discharge direct to a watercourse (unless not appropriate), controlled rainwater discharge to a surface water sewer or drain, controlled rainwater discharge to a combined sewer.
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9.2.25 The well-established drainage hierarchy set out in this policy helps to reduce the rate and volume of surface water run-off. Rainwater should be managed as close to the top of the hierarchy as possible. There should be a preference for green over grey features, and drainage by gravity over pumped systems. The London Sustainable Drainage Action Plan complements this policy. It contains a series of actions to make the drainage system work in a more natural way with a particular emphasis on retrofitting. 9.2.26 Policy SI 14: ‘Waterways - Strategic Role’ requires Development Plans and proposals to take account of the emerging Marine Spatial Plans prepared by the Marine Management Organisation. It also requires Development Plans to designate and ensure the maintenance of Thames Policy Areas (TPAs). 9.2.27 Policy SI 15: ‘Water Transport’ deals with the protection and enhancement of existing passenger transport piers, existing boatyard sites and wharves. It also supports development proposals to facilitate an increase in the amount of freight transported by river and states that development proposals close to navigable waterways should maximise water transport for bulk materials during demolition and construction phases. 9.2.28 Policy SI 16: ‘Waterways – Use and enjoyment’ deals with the protection and enhancement of waterway infrastructure to enable water dependent uses. It supports development proposals for the provision of recreational water activities and associated new infrastructure provided they are managed in a way that respects the character of the waterways. It encourages development proposals to improve and expand the Thames Path and towpaths as public spaces and provide better linkages to the transport network in collaboration with relevant partners such as the London boroughs, the PLA, the CRT, the EA and Natural England. 9.2.29 Policy SI 17: ‘Protecting London’s Waterways’ supports development proposals that facilitate river restoration and improve the protection of the distinct open character and heritage of waterways. It requires development proposals along London’s canal network, docks, other rivers and water space to respect their local character and environment and contribute to their accessibility and active water-related uses. 9.2.30 Section 9.14.1 explains that the network of linked waterways known as the Blue Ribbon Network, of which the River Quaggy and Ravensbourne River are a component part, ‘is of strategic importance for London’. The Plan states ‘new development should utilise the waterways for transport purposes where possible, but also for active water-based leisure, and for informal waterside recreation or access. In order to make the maximum use of London’s waterways a range of supporting infrastructure is required including jetties, moorings, slipways, steps and waterside paths (piers, wharves and boatyards are addressed in Policy SI 15 Water transport). 9.2.31 The London Plan Supplementary Planning Guidance: Sustainable Design and Construction (SPG) published in April 2014, has been revoked following publication of the London Plan 2021.
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Local London Borough of Lewisham: Core Strategy (2011) (Ref 9.17) 9.2.32 The Core Strategy sets out a vision for the future development of the borough and covers a 15-year plan period up to 2026. It also sets out the context for the other policy documents that make up Lewisham’s Local Plan. 9.2.33 Core Strategy Policy 10 aims ‘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. 9.2.34 Core Strategy Policy 11 also confirms 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. Lewisham Development Management Local Plan (2014) (Ref 9.18) 9.2.35 The Development Management Local Plan (DMLP) sets out the Council’s planning policies for management development in the LBL, including matters related to Flood Risk, and will be used to guide, assess and determine planning applications. Lewisham Town Centre Local Plan (2014) (Ref 9.19) 9.2.36 The Lewisham Town Centre Local Plan outlines the delivery of the Core Strategy through allocating land for a particular use or type of development. This identifies the Lewisham Gateway Policy Area, Site under Policy LTC2 (Sites S1 and S2) 9.2.37 This notes a key objective of the Policy Area should be to “celebrate the confluence of the rivers Quaggy and Ravensbourne”. Draft Lewisham Local Plan (Regulation 19 stage, 2023) (Ref 9.20) 9.2.38 This Local Plan sets out a borough-scale vision over the next 15 years that will support delivery of concerted action Lewisham Council’s core themes of tackling the climate crisis, fighting inequality, and creating good jobs and growth. 9.2.39 This Local Plan will set out a vision, strategic objectives and planning policies that together provide the overarching framework for the delivery of sustainable development in the borough. The plan will also support the implementation of the London Plan (2021) and its aspiration for achieving the defined objections. It also sets out the context for the other policy documents that make up Lewisham’s Local Plan. 9.2.40 Once finalised, Lewisham’s Local Plan will replace the current suite of local development plan documents, bringing the updated planning policies together into a single plan. It will provide a locally specific spatial policy framework for future planning and development of the local planning authority (excluding the OPDC area) for the period from 2024 to 2040.
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Local Strategy Guidance Documents London Borough of Lewisham Strategic Flood Risk Assessment (SFRA) (Ref 9.21 and 9.22) 9.2.41 A Level 1 SFRA has been produced to collate and analyse the most up-to-date and readily available flood risk information for all sources of flooding and provide an overview of flood risk issues across the LBL. The Level 1 SFRA provides guidance on the application of the Sequential Test, managing and mitigating flood risk and policy considerations. 9.2.42 A Level 2 SFRA has been produced using the strategic flood risk information presented within the Level 1 SFRA. LBL have undertook a Sequential Test to document the process whereby future development is steered towards areas of lowest flood risk. 9.2.43 The Proposed Development site is included in the Level 2 SFRA. The SFRA confirms the north/northwest of the site is partially located in Flood Zone 3b, the functional floodplain. London Borough of Lewisham Local Flood Risk Management Strategy (Ref 9.23) 9.2.44 London Borough of Lewisham is a Lead Local Flood Authority with responsibility under the Flood and Water Management Act 2010 to lead and co-ordinate local flood risk management in the borough; namely flood risk arising from surface water run-off, groundwater and small watercourses and ditches. 9.2.45 The Local Flood Risk Management Strategy (‘the Strategy’) is a single document which aims to provide clarity and direction around how flood risk is managed in Lewisham. 9.2.46 The Strategy’s consists of five objectives and their corresponding actions. The objectives are: • • • •
Objective 1: Understand risk and opportunity Objective 2: Reducing the risk of flooding Objective 3: Resilient planning Objective 4: Resilient communities
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9.3
Consultation
9.3.1 As discussed in Chapter 2: Approach to Assessment, the formal EIA Scoping Opinion provided by LBL and consultees have been considered in the preparation of this Chapter, as well as any additional consultation undertaken during the design developments and preparation of the planning application documents for the Proposed Development. 9.3.2 During preparation of the ES Chapter and technical appendices, the project team consulted with London Borough of Lewisham (LBL) (Local Planning Authority) through a pre-application process. 9.3.3 The development of the surface water drainage strategy has followed the approach set out in the LBL (acting as the Lead Local Flood Authority (LLFA)) guidance documents. The project team have consulted with the EA on 21st December 2023, the LLFA on 30th January 2024, and both the EA and LLFA on 29th May 2024 to agree the approaches to flood risk management and sustainable urban drainage. 9.3.4 Pre-planning enquiries and consultation have also been carried out with Thames Water with regards to foul drainage and potable water capacity, under ref DS6121055, DTS-60137. Thames Water have confirmed sufficient capacity for foul drainage.
9.4
Assessment Methodology and Significance Criteria
9.4.1 The following section outlines the methodologies applied to identify and assess the potential impacts and likely effects to result from the Proposed Development. Scope of the Assessment 9.4.2 An EIA Scoping Report was issued to LBL in January 2024 (Appendix 2.1). LBL’s formal Scoping Opinion was issued in June 2024 (Appendix 2.2). 9.4.3 The following potential effects are considered in this assessment: •
Construction phase: o Flood risk (fluvial, surface water, groundwater, reservoir, sewer) o Surface water drainage (quantity) o Surface water drainage (quality) o Impact of wastewater discharge and potable water supply on local water and wastewater infrastructure.
•
Operational phase: o Flood risk (fluvial, surface water, groundwater, reservoir, sewer) o Surface water drainage (quantity) o Surface water drainage (quality) o Impact of wastewater discharge and potable water supply on local water and wastewater infrastructure. o Impact on water resources.
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9.4.4 Potential significant effects have been assessed for both the construction and operational phases of the Proposed Development. These have been identified and evaluated in terms of impacts on identified environmental receptors. 9.4.5 Potential effects have been assessed both pre and post incorporation of any required additional mitigation measures. Extent of The Study Area 9.4.6 The redline planning boundary defining the Site for this assessment is shown on drawing 0386-SEW-ZZ-ZZ-DR-A-PL6001 and Chapter 1: Introduction, included as part of the application for the Proposed Development. 9.4.7 With regards to flood risk, this assessment covers the Site itself and surrounding areas that could be affected by the same sources of flooding that could affect the Site. 9.4.8 It considers the impact of the development onto the River Ravensbourne and the River Quaggy, and the local catchment. 9.4.9 The site does not lie within an EA Groundwater Source Protection Zone but overlies a Secondary Aquifer A associated with superficial deposits and the Principal Chalk Aquifer which will be considered. 9.4.10 This assessment considers the foul and surface water drainage networks, as well water mains on the site and in the vicinity of the site. Method of Baseline Assessment 9.4.11 The baseline has been established from the following sources of information: •
• • • • • • •
Environment Agency (EA) published ‘Open Data’ datasets available online, reproduced with OS mapping under licence to Expedition (contains Ordnance Survey data © Crown copyright and database right [2019], contains Environment Agency information © Environment Agency and database right) (Ref 9.24); EA Product 4 to 7 data (KSL 306837 RL, dated April 2023); British Geological Survey (BGS) online digital viewer (Ref 9.25); Magic map website (Ref 9.26). EA Guidance on flood risk assessments - climate change allowances (Ref 9.27) LBLC Level 1 Strategic Flood Risk Assessment (SFRA) dated October 2018 (Ref 91.21); LBLC Level 2 SFRA dated February 2020 (Ref 9.22); Thames Water Asset records on local sewers and water mains
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Method of Assessment of Impacts Demolition & Construction Phase 9.4.12 The impact of construction works on the key sensitive water resources, flood risk and water infrastructure receptors has been qualitatively assessed. This assessment has considered the construction of the key elements of the Proposed Development that may impact on these receptors, with a preliminary understanding of construction methods. Operational Phase 9.4.13 The impact of the Proposed Development during its operation on the key sensitive water resources, flood risk and water infrastructure receptors has been qualitatively assessed. The methods for assessing the operational effects are based on the engineering principles established in the FRA, Sustainable Drainage Strategy and the Foul and Utilities Assessment. 9.4.14 The FRA has been carried out in line with the requirements of NPG and NPPF and is included in Appendix. This has served as a basis to establish flood risks to the Site and potential impacts on local flooding. 9.4.15 The surface water drainage strategy has been developed in line with the requirements of NPG, NPPF, BSEN752 (Ref 9.28), and best practice SUDS design guidance (CIRIA C753, Ref 9.29) and is included in the Appendices. 9.4.16 The Foul and Utilities Assessment has been developed by WSP considering existing assets, demands associated with the Proposed Development, in consultation with Thames Water to assess capacity and develop a strategy for water supply and foul drainage.
9.5
Significance Criteria
9.5.1 The assessment of the potential effects of the Proposed Development has taken into account the Demolition and Construction Phases as well as the Operational Phase. The significance level attributed to each effect has been assessed based on the magnitude of change associated to the Proposed Development and the sensitivity of the affected receptor/receiving environmental to change, as well as a number of other factors that are outlined in more detail in Chapter 2: Approach to Assessment. 9.5.2 Potential significant effects have been identified and evaluated in terms of impacts on the following environmental receptors: • • • • • • • •
River Ravensbourne River Quaggy Local aquifers Regional water resources Site residents, working occupants and visitors. Nearby residents and businesses Local sewer infrastructure Local water mains infrastructure
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9.5.3 Effects have been identified and evaluated based on the following parameters: • • • • •
The significance of the receptor (international, national, regional and local importance); The magnitude of the effect; The duration involved; The reversibility of the effect; and The number and sensitivity of receptors affected.
9.5.4 The significance of an effect is generally determined as the combination of the ‘sensitivity and / or value’ of the affected environmental receptor and the predicted ‘extent and / or magnitude’ of the impact or change. The assessment of significance ultimately relies on professional judgement, although comparing the extent of the effect with criteria and standards specific to each topic can guide this judgement. Receptor Sensitivity 9.5.5 The sensitivity of a receptor refers to its importance, i.e. its environmental value / attributes. The terminology used to describe the sensitivity of a resource or receptor against the baseline is as follows: Very High, High, Medium or Low, and example criteria of sensitivity is in Table 9.1 below. Table 9.1 Receptor Sensitivity Sensitivity Criteria Very High
Attribute has a high quality and rarity on a regional or national scale.
Example Criteria Watercourse with Water Framework Directive (‘WFD’) Class ‘High’. Site protected/designated under EC or UK habitat legislation (Special Area of Conservation (‘SAC’), Special Protection Area (‘SPA’), Site of Special Scientific Interest (‘SSSI’), Drinking Water Protection Zone (‘DWPZ’), Ramsar site, and Freshwater Fishery/Shellfish Water) Land uses classified as ‘highly vulnerable’ to flood risk in the National Policy Guidance on Flood Risk and Climate Change (Table 2) EC Bathing Waters Directive Beach class – ‘Higher’ classification.
High
Attribute has a high quality and rarity on a local scale.
Watercourses with Water Framework Directive (WFD) Class 'Good'. Watercourse that supports species protected under EC or UK habitat legislation but is not a designated site. Groundwater currently used, or likely to be suitable for use as, public potable supplies (e.g. Principal Aquifers, Source Protection Zone for a potable groundwater supplies).
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Main river >10m wide. Land uses classified as ‘more vulnerable’ to flood risk in the National Policy Guidance on Flood Risk and Climate Change (Table 2). EC Bathing Waters Directive Beach class – ‘Minimum’ classification. Medium
Watercourses with Water Framework Directive (WFD) Attribute has a Class 'Moderate'. medium quality and rarity on local Groundwater currently used for, or likely to be suitable scale. for, providing non-potable supplies or limited domestic supplies (e.g. Secondary Aquifers for domestic supplies or industrial abstractions). Main river <10m wide. Ordinary watercourse >5m wide. Land uses classified as ‘less vulnerable’ to flood risk in the National Policy Guidance on Flood Risk and Climate Change (Table 2).
Low
Attribute has a low quality and rarity on local scale.
Groundwater that is unlikely to be suitable for providing abstractions (e.g. aquifers in areas of saline intrusion). Watercourses with Water Framework Directive (WFD) Class 'Poor'. Unclassified field drain which is therefore likely to be <5m wide. No fishery of any type. Land uses classified as ‘water compatible’ in the National Policy Guidance on Flood Risk and Climate Change (Table 2). EC Bathing Waters Directive Beach class– Fail.
9.5.6 Magnitude is determined by predicting the scale of any potential change against the baseline conditions. The terminology used to describe the magnitude of impact against the baseline is as follows: Major, Moderate, Minor or Negligible. 9.5.7 Table 9.22 summarises example descriptions of the different classes of beneficial and adverse effects in relation to Flood Risk and Drainage. Table 9.2 Impact Magnitude Impact Magnitude
Description of Criteria
Major Positive
Significant local scale and moderate to significant regional scale reduction in flood risk.
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Major improvement of groundwater quality underneath the Site and/or off-Site. Major improvement in water quality of the surface water resources. Significant permanent reduction in water demand on local / regional water resources. Moderate Positive
Moderate scale reduction in localised flood risk. Moderate improvement of groundwater quality underneath the Site and/or off-Site. Moderate improvement in water quality of the surface water resources. Permanent reduction in water demand on local / regional water resources.
Minor Positive
Minor local scale reduction in localised flood risk. Minor and local scale improvement of groundwater quality underneath the Site and/or off-Site. Minor and local scale improvement in water quality of the surface water resources. Temporary or minor reduction in water demand on local / regional water resources.
Neutral
No significant effect on flood risk. No significant effect on groundwater flow or water quality. No significant effect on surface water quality. No significant effect on reduction in demand on local / regional water resources.
Minor Negative
A minor increase in the risk of flooding and minor and local scale change in groundwater flow. Minor and local scale deterioration in groundwater quality underneath the Site and/or off-Site. Minor and local scale deterioration in water quality of the surface water resources.
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Temporary or minor increase in demand on local / regional water resources. Moderate Negative
Minor to moderate local scale increase in flood risk. Minor to moderate local scale change in flow of groundwater. Minor to moderate local scale deterioration in water quality of the groundwater underneath the Site and/or off-Site. Minor to moderate local scale deterioration in water quality of the surface water resources. Permanent increase in demand on local / regional water resources.
Major Negative
Moderate to severe increases in flood risk. Moderate to severe local scale change in flow of groundwater underneath the Site and / or modest changes in off-Site groundwater flow. Moderate to severe local scale deterioration in water quality of the groundwater underneath the Site and/or off-Site. Moderate to severe local scale deterioration in water quality of the surface water resources. Major increase in in demand on local / regional water resources, and associated requirements for new sources e.g. application of an abstraction licence.
Effect Significance 9.5.8 The significance of identified effects arising from the construction or operation of the Proposed Development have been determined via the sensitivity of the affected receptor and the magnitude of impact of the effect. The matrix in Table 9.3 identifies how magnitude of impact and sensitivity of receptor is used to determine the significance of an effect. 9.5.9 The terminology used to describe the classification of beneficial or adverse effects is as follows: Major, Moderate, Minor or Neutral. Effects are considered Significant if they are Major or Moderate and Not Significant if they are Minor or Neutral.
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Table 9.3 Significance of Effect
Sensitivity of Receptor
Magnitude of Impact
9.6
Major magnitude
Moderate magnitude
Minor magnitude
Negligible magnitude
Very High
Major
Major
Moderate
Neutral
High
Major
Moderate
Minor
Neutral
Medium
Major
Moderate
Minor
Neutral
Low
Moderate
Minor
Neutral
Neutral
Baseline Conditions
9.6.1 This section outlines the existing baseline conditions of the Site. 9.6.2 A full description of the Site and Proposed Development is provided in Chapter 4: The Proposed Development of this ES. The existing Baseline year for the purpose of the assessment is 2022. 9.6.3 Baseline conditions have been described by considering the following aspects: • • • • •
Geology and Groundwater; Topography and Hydrology Flood Risk; and, Surface water drainage. Existing sewer and water mains infrastructure
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Location and current uses 9.6.4 The Site is bound to the west and south by Molesworth St (A21), the east by Lewisham High St and the north by Rennell Street (A20). West of Molesworth St is the railway line and River Ravensbourne as well as a mix of green space, residential and commercial buildings. The Lewisham DLR and railway stations are located, respectively, approximately 170m and 240m north of the Site. Northeast of the Site is a Police Station, east of Lewisham High St which is then followed by shops and commercial premises running south beyond the southern tip of the Site. 9.6.5 The Site currently comprises the Shopping Centre, which includes a range of retail units, a multi-storey car park, the 18-storey vacant former office building - Lewisham House, the vacant leisure box and Riverdale Hall, as well as commercial properties on the High Street. 9.6.6 The Shopping Centre was built in 1977. Geology and Groundwater 9.6.7 The British Geological Survey (BGS) database shows that the majority of the site is underlain by the superficial geology of the Kempton Park Gravel Member (sand and gravel) with an area to the northern boundary underlain with Alluvium (clay, silt, sand and gravel). The bedrock formation is the Thanet Sands over Lewes Nodular Chalk. 9.6.8 A Ground Investigation Report was prepared in December 2022 by WSP following geotechnical ground investigation in 2022 by Ground Engineering Ltd. British Geological Survey maps and borehole logs have also been used to understand existing ground conditions. A summary of the geological profile from the ground investigation is shown in Table 9.4. Table 9.4 Summary of the Geological Profile on Site
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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9.6.9 Groundwater monitoring between May 2022 and August 2022 found groundwater to be present in the Thanet Sand, with average groundwater levels to be at +1.2mAOD, circa 7.5m below ground levels. Groundwater was found to be shallowest to the southeast with max levels of +2.57mAOD and lowest in the northwest with max levels of +0.27mAOD. 9.6.10 Low groundwater levels are understood to be associated with historic groundwater abstraction. 9.6.11 The site does not lie within an EA Groundwater Source Protection Zone. 9.6.12 Based on DEFRA’s online mapping service (Ref 1.26), the Chalk aquifer is classified as a principal aquifer. Principal aquifers are defined as layers of rock or drift deposits that have high intergranular and/or fracture permeability and usually provide high levels of water storage. The Thanet Sands are classified as a secondary A aquifer. Secondary A aquifers are defined as permeable layers capable of supporting water supplies at a local scale and in some cases forming an important source of base flow to rivers. The Thanet Sands and Chalk Aquifer are both deep aquifer that are hydraulically connected. The Chalk Aquifer is the most significant and for simplicity in the following both aquifers are jointly referred to as the Chalk Aquifer. 9.6.13 The Kempton Park Gravels superficial deposits are classified as a secondary A aquifer (Figures 1 and 2). Topography and Hydrology 9.6.14 A detailed topography survey was undertaken by Plowman Craven in 2021. The land around the existing Shopping Centre generally falls from south to north. Levels to the south of the existing building are typically at 10.5mAOD and at the north of the site are approximately +8.00mAOD along Rennel Street. 9.6.15 The River Ravensbourne is located to the west of the site and the railway line and flows northwards. At its closest point it is approximately 73m to the west of the site. The River Ravensbourne is culverted under the A20 for approximately 90m. 9.6.16 The River Quaggy is located east of the site, at its closest point it is approximately 23m from the site. The River Quaggy is a culverted watercourse in proximity to the site, along Lewisham Highstreet (A20) for approximately 230m, and north of the site beneath the A2211 for approximately 25m. 9.6.17 The confluence of the River Quaggy and River Ravensbourne is approximately 185m north of the site, adjacent to the Lewisham gateway development. Upon confluence, the River Ravensbourne flows generally northwards, becoming the Deptford Creek before flowing north into the River Thames. 9.6.18 The River Ravensbourne and River Quaggy are designated ‘Main Rivers’. 9.6.19 The site does not benefit from statutory fluvial flood defences.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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Fluvial Flood Risk 9.6.20 Reference should be made to the Flood Risk Assessment in Appendix 9.1 for details of flood risk. This is briefly summarised below. 9.6.21 The Environment Agency (EA) flood map shows the northern half of the site to be within Flood Zone 3. A strategic Flood risk Assessment (SFRA) has been prepared for the London Borough of Lewisham by AECOM in 2018 [Ref 1.21]. This shows that approximately a third of the site would be in Flood Zone 3b, the “functional flood plain” of the River Ravensbourne and River Quaggy. 9.6.22 Predicted flood levels received from the EA have been mapped onto the results of the detailed topographical survey of the existing shopping centre. In several places, the predicted flood levels were found to be lower than the surveyed existing ground levels within the building. This suggests that the EA flood map for planning and SFRA flood map were inaccurate in places. This is explained by the strategic flood mapping produced by the EA being based on relatively coarse LIDAR data, which is inaccurate when the site is occupied by buildings. 9.6.23 A revised flood map for the site has been produced and agreed with the EA and Lead local Flood Authority (LLFA). This shows that approximately 10% of the site area is now in Flood Zone 3, most of which is in Flood Zone 3b. The re-mapping of Flood Zone 3b has been based on the 1:30 year flood envelope, in line with latest guidance from NPPG and in consultation with the LLFA. The development proposals and their vulnerability class are compatible with that revised flood zoning. Tidal Flood Risk 9.6.24 The River Ravensbourne and River Quaggy are not tidal at the site. The Thames Tidal Upriver Breach flood maps within the SFRA does not show any risk of flooding to the site. As such there is no risk of tidal flooding to the site. Surface Water and Sewers Flood Risk 9.6.25 In urban areas, where impermeable surfaces typically drain to sewers, pluvial flooding tends to occur as a consequence of sewer surcharging or poor drainage. Pluvial and sewer flood risks have therefore been considered together in the Flood Risk Assessment (Appendix 9.1). 9.6.26 The EA and SFRA surface water flood risk map shows a high risk of flooding to the north of the site, and localised areas of medium and low risk within the rest of the site. 9.6.27 The site is located within a Critical Drainage as identified in the SFRA. Groundwater Flood Risk 9.6.28 The SFRA identifies a limited potential for groundwater flooding. According to British Geological Survey maps and borehole logs, groundwater is approximately 2.2 to 7.6m below ground level. This confirms that there is no significant risk of groundwater flooding to the site.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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Reservoir Flood Risk 9.6.29 The EA’s Long-Term Flood Risk mapping for flood risk from reservoirs confirms the northeast of the site is at risk. The reservoirs that could affect the site include the Weigall Road Flood Storage Area, the Wraysbury Reservoir, South Norwood Reservoir, and the Sutcliffe Park Flood Detention Area. 9.6.30 Overall, the risk of flooding from reservoir breach is low as these features are required to be inspected and supervised by a reservoir panel engineer, annually. River water quality and ecological status 9.6.31 The DEFRA catchment data explorer states that the Ravensbourne Operational Catchment which includes the rivers Ravensbourne and Quaggy has a ‘moderate’ ecological status and ‘fails’ the chemical status (Ref 29.30). 9.6.32 The catchment has a 2027 objective to reach ‘good’ Ecological status and a 2063 objective to reach a ‘good’ chemical status Existing drainage arrangement and sewers 9.6.33 A network of existing Thames Water surface water and combined sewers run along surrounding streets and across the existing Lewisham Shopping Centre. This system also includes private secondary networks within the site connecting to the Thames Water network. At present most of the site is impermeable, with no noticeable soft landscape area. All stormwater is discharged to the sewer network. There are no known methods of stormwater attenuation on the site. 9.6.34 A 229mm diameter surface water sewer runs across the north of the site and discharges into the River Quaggy. It is understood that this takes surface water drainage flows from Lewisham House and from the ramped access to the Shopping Centre. 9.6.35 A network of combined sewers runs through the Shopping Centre meeting the 686mm x 610mm sewer running from west to east and joining the trunk sewer along Lewisham High Street to the east of the site. Existing water supply arrangement and water mains 9.6.36 Thames Water potable water mains are located in all roads surrounding the site and provide connection points to existing buildings within the Site.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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9.7
Future Baseline
9.7.1 This section outlines the future baseline conditions of the Site. The future baseline, based upon continued current site usage, is not considered to differ significantly from the existing baseline. The condition of the groundwater and surface water receptors would be unchanged from current.
9.8
Sensitivity of Receptors
9.8.1 The following environmental receptors have been identified. They are listed in Table 9.5 alongside their corresponding perceived sensitivity.
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Table 9.5 Receptor Sensitivity Receptor
Sensitivity
Justification
Existing communities and buildings within River Ravensbourne and Quaggy floodplain
Low to High
Depending on land use vulnerability to flooding in line with the National Policy Guidance on Flood Risk and Climate Change (Table 2).
Occupants of Proposed Development – local flooding
Medium to High
Land use classified as “less vulnerable” (nonresidential uses) and “more vulnerable to flooding” (residential uses) to flooding in line with the National Policy Guidance on Flood Risk and Climate Change (Table 2)
River Ravensbourne and Quaggy – water quality
Medium to High
EA ecological status classification maps indicate that the classification of the River Ravensbourne/Quaggy is moderate.
Local superficial aquifer – groundwater quality
Medium
Vulnerability to groundwater pollution maps identify superficial aquifer as having a medium sensitivity (Ref 9.25)
Local superficial aquifer – abstraction and recharge
Low
the shallow aquifer is not a strategic water resources
Chalk aquifer – groundwater quality
High
Chalk aquifer is a regional resource for potable water supply
Chalk aquifer – abstraction and recharge
High
The Chalk Aquifer is a strategic water resource of regional importance.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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Local drainage infrastructure - capacity
Low
Thames Water have confirmed capacity.
Local water mains capacity
Low
Awaited response from Thames Water anticipated to confirm capacity.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
Plowman Craven 46730 October 2024
9.9
Assessment of Effects, Mitigation and Residual Effects Embedded Mitigation
9.9.1 This section of the chapter describes the measures and environmental enhancements which will be incorporated within the design of the Proposed Development. These design and management measures will avoid, prevent, reduce, or offset potential environmental impacts. Sustainable Drainage 9.9.2 A surface water drainage strategy has been developed (Appendix 9.2) for the Proposed Development using the following principles:
• • • • • • • •
•
Adopting the most sustainable disposal route for surface water drainage flows, in line with the 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 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. Smart harvesting of rainwater for irrigation of the podium landscape planting . Pollution to the water environment will be controlled with a multi-stage SUDS treatment system following best practice from the SUDS Manual (CIRIA c753). The surface drainage system will be designed for: o No surface water flooding for all events up to 1 in 30-year return period, in line with BS EN 752; and o No flooding of the buildings for extreme events up to the 1 in 100-year return period including, in line with NPPF and NPPG. Climate change allowances have been considered, in line with NPPG and latest DEFRA mapping of climate change allowances for the London Management Catchment: o +35% increase in rainfall intensities on the 1:30 year rainfall event (Upper End allowance to 2070s horizon). This also includes o +40% increase in rainfall intensities on the 1:100 year rainfall event (Upper End allowance to 2070s horizon); and,
Flood Risk Management 9.9.3 As detailed in the Flood Risk Assessment (Appendix 9.1) Several flood risk mitigation measures have been adopted to protect the Proposed Development from flooding. This includes:
•
No residential dwellings are proposed on the ground floor of any buildings. The lowest residential dwellings will be one storey above ground levels. As such, proposed
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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•
• • •
residential FFLs are well above good practice requirements of 600mm above the 1 in 100 year + 20% fluvial flood level. Most ground floor FFLs within the shopping centre and proposed buildings will be above the fluvial flood levels for the design 1:100 year + 20% event except some of the ground floor commercial units, residential lobbies, utility areas and plantrooms within buildings to the north of the site. The proposals have been developed to raise ground floor levels where possible above the 1 in 30 year flood level, to minimise the frequency of flooding. Temporary flood protection will be provided at doors to ground floor units at risk (demountable defences) to protect against events greater than 1 in 30 year and up to 1 in 100 year +20%. Flood resilience measures will also be implemented on these buildings, including consideration on finishes, and setting power sockets, services and sensitive plants above design flood levels. A strategy has been developed to ensure occupants can safely egress and emergency services can effectively access the buildings during a 1:100 year + 20% fluvial flood event. Most residential buildings will have access to the two-level podium public park, which is connected to Lewisham High Street and the southern part of Molesworth Street that will not be flooded. Residents and occupants from buildings to the north of the site will also have access to dry areas within the Northern Square. This will connect to the podium and surrounding streets that are not flooded.
9.9.4 As detailed in the Flood Risk Assessment (Appendix 9.1) Several flood risk mitigation measures have also been adopted to ensure that the Proposed Development does not result in an increase of flood risk elsewhere. This includes:
•
•
Any loss of floodplain storage volume has been compensated on a level-by-level and volume-by-volume basis. 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. Consideration of fluvial overland flow routes and ensuring that the Proposed Development does not detrimentally impact them increasing flood risk to adjacent land.
Reduction of Water Use and Connection with Drainage Infrastructure 9.9.5 Water demands within buildings will be reduced at source with the use of efficient water fittings, metering and leak detection to achieve the water use targets of the London Plan as detailed in the Sustainability Statement. This will reduce both demands on water mains and discharge to foul sewers. 9.9.6 Irrigation requirements for the podium landscape planting will be minimised with the use of appropriate planting as detailed in the Landscape Strategy. Efficient irrigation systems will minimise demand for planted areas.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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9.9.7 Rainwater will be harvested from the stormwater attenuation systems for irrigation of the podium landscape. This technology is based on real-time management of the drainage attenuation capacity. The system takes a feed from the weather forecast and controls in realtime the retention of water in dry periods for irrigation use or its release in anticipation of a storm to free up the surface water storage capacity. This smart technology removes the need for a dedicated rainwater harvesting tank and allows harvesting rainwater in a material, carbon and cost-efficient way. It has been successfully implemented in the US and mainland Europe for over a decade and is being applied in the UK to a growing number of projects. 9.9.8 This approach will reduce irrigation water demands for the Proposed Development, meeting all podium landscape irrigation requirements in an average year and almost 70% of demand on a drought year, offsetting the amount of water required to be supplied from the local mains network.
Potential Effects Demolition & Construction Phase 9.9.9 This section identifies and assesses the scale and nature of the main effects arising from the Proposed Development during the construction phase. Geology and Groundwater 9.9.10 Due to the historical uses of the Site and the proposed demolition of existing buildings, some sub-surface obstructions will require removal prior to the construction of the Proposed Development. Removal of redundant foundations and other ground obstructions, and the installation of new piles could impact the groundwater quality or local water level regime of the superficial aquifer. The impact on the aquifer would be of moderate adverse magnitude. The superficial aquifer is considered to have a medium sensitivity to pollution and change in water level regime. This would therefore result in a temporary medium term Moderate Negative direct effect, considered Significant. 9.9.11 The proposed buildings will be on piled foundations. Construction of any deep pile foundations could create a pollution pathway and impact the quality of the Chalk aquifer if unmitigated. The Chalk aquifer is noted as having a high sensitivity given its regional significance for water supply, and impact magnitude of moderate adverse if unmitigated. The effect on groundwater quality would therefore be temporary medium term Moderate Negative, considered Significant. 9.9.12 Construction of any foundations below the water table will require dewatering. This will be localised and dewatering volumes will be limited by adopting best practice and creating effective groundwater cut-offs. The impact on the aquifer would be of minor adverse magnitude. The superficial aquifer is considered to have a medium sensitivity to change in water level regime. The effect on groundwater level regime of the superficial aquifer is therefore Minor Negative, considered Not significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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9.9.13 The presence at the construction site of fuels, chemicals, construction materials (e.g. cement), high level of silts and construction waste could lead to releases of pollutants to shallow groundwater which unmitigated could have an impact on groundwater quality. The impact on the aquifers would be of minor to moderate adverse magnitude. The shallow aquifer is considered to have a medium sensitivity to pollution. The Chalk aquifer is considered to have a high sensitivity to pollution. This would therefore result in a temporary medium term Moderate Negative effect on groundwater quality, considered Significant. Flood Risk 9.9.14 During the construction phase there could be a potential risk of local flooding on the Site, due to the increase in runoff from the Site during construction works. With the temporary construction drainage arrangements proposed as part of the embedded mitigations this impact will be largely mitigated. The magnitude of the impact would be negligible to minor. The sensitivity of the construction site to flooding is considered low. This would therefore result in a Neutral effect, considered Not Significant. 9.9.15 The northern part of the site is at risk from fluvial flooding and surface water flooding from the wider local sewer catchment. This could affect construction workers and equipment. The magnitude of the impact would be minor to moderate. The sensitivity of the construction site to fluvial or deep surface water flooding is generally low but could temporarily be medium for example during excavation works or when sensitive equipment could be affected. This would therefore result in a Minor to short term Moderate Negative effect, potentially Significant. Surface Water 9.9.16 There is a potential risk of surface water pollution, through the construction of the drainage system or accidental runoff or spillage, by sediments, fuels, chemicals and construction materials. Without mitigation the impact on the aquifers would be of minor to moderate adverse magnitude. The River Ravensbourne and Quaggy are considered to have a high sensitivity to pollution. This would therefore result in a temporary medium term Moderate Negative effect, considered to be Significant. Water and drainage infrastructure 9.9.17 Foul drainage flows from the site compounds will be discharged to the foul sewer. These flows will be relatively small in comparison with operational foul flows, and the local sewers are understood to have capacity to handle these flows. The magnitude of the impact would be minor. The sensitivity of the local sewers to increased flow is considered to be low. This would therefore result in a temporary Minor Negative effect, considered Not Significant. 9.9.18 Water will be supplied to the site compounds and construction activities from the local water mains. These flows will be relatively small in comparison with operational water demands, and the local water mains are understood to have capacity to handle these flows. The magnitude of the impact would be minor. The sensitivity of the local water mains to increased demand is considered to be low. This would therefore result in a temporary Minor Negative effect, considered Not Significant.
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Operational Phase 9.9.19 This section identifies and assesses the scale and nature of the main effects arising from the Proposed Development during the operational phase. Geology and Groundwater 9.9.20 In line with the sustainable drainage hierarchy and London Plan Policy SI13, stormwater drainage flows will be infiltrated to ground where possible through porous pavement systems. This will be subject to infiltration and ground contamination testing and groundwater monitoring. These tests and investigations will be carried out post demolition of existing buildings. If infiltration drainage is found feasible the risk of mobilisation of any ground contamination would have been assessed to not be significant. Diffuse urban pollutants will be intercepted by the porous pavement system. As such, any impact on groundwater qualiy would be negligible. The superficial aquifer is considered to have a medium sensitivity to pollution. This would therefore result in a Neutral effect on groundwater quality, considered Not Significant. 9.9.21 At present, the site is mostly impermeable with no infiltration to ground. Promoting infiltration as described above will promote groundwater recharge of the shallow aquifer and potentially the underlying Chalk aquifer. Considering the scale of the development this will result in a minor to moderate beneficial effect on the shallow aquifer and minor effect on the Chalk aquifer. The superficial aquifer is considered to have a low sensitivity to abstraction and recharge, and the Chalk aquifer is considered to have a high sensitivity to abtraction and recharge. This would therefore result in a Minor Positive effect on groundwater resources, considered Not Significant. Flood Risk 9.9.22 The Flood Risk Asessment (Appendix 9.1) has been developed to mitgate the risks of flooding to the occupants and residents of the proposed development, and ensuring that flood risk is not incrased elsewhere. Residual risks have also been mitigated. Surface water discharge will be limited to greenfield runoff rates. This will contribute to locally reducing flood risk. Considering the scale of the development this will result in a minor to moderate beneficial effect. The sensitivity of the local residents and businesses to flooding is low to high depending on land use. Reducing runoff rates will provide a reduction of local flooding, overall resulting in a Minor to Moderate Positive effect, considered Not Significant. Surface Water 9.9.23 The surface water drainage strategy will implement a multi-stage pollution control approach, with source control SUDS and new ponds prior to discharge of surface water runoff to the River Quaggy and local sewers. The existing surface water drainage system does not include extensive pollution control features. The Proposed Development would have a minor beneficial impact on surface water quality. The River Quaggy is considered to have a medium sensitivity to pollution. Any effects are therefore Minor Positive and considered Not Significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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Water and drainage infrastructure 9.9.24 Water demand will be minimised through water efficient fittings, metering, leak detection, drought resistant planting and efficient irrigation practice for the podium planting. Rainwater will be harvested to irrigate the podium planting. This approach is in line with best practice and will achieve local planning requirements. However, the Proposed Development will result in an increase in water demand against the current baseline. This will have a minor negative effect on local water resources. Local water resources are scarce and sensitivity is high. This would therefore result in a Minor Negative effect, considered Not Significant. 9.9.25 Foul drainage flows from the Proposed Development will be discharged to the local foul and combined sewers. Thames Water will make any necessary upgrade to the local sewers and wastewater treatment infrastructure so that it can accommodate the proposed peak discharge from the development, considering its phasing. The magnitude of the impact of the additional discharge would therefore be minor. The sensitivity of the local sewers to increased flow is considered to be low. This would therefore result in a Minor Negative effect, considered Not Significant. 9.9.26 Water will be supplied to the proposed buildings from the local water mains. Thames Water will make any necessary upgrade to the local water mains and water supply infrastructure so that it can accommodate the demands of the development, considering its phasing. The magnitude of the impact would be minor. The sensitivity of the local water mains to increased demand is considered to be low. This would therefore result in a Minor Negative effect, considered Not Significant. In-combination climate change impacts 9.9.27 In-combination climate change effects have been considered. Climate change predictions have been considered when assessing the risk of flooding and for the design of the surface water drainage system. Climate change effects will not affect the significance of the other potential impacts that have been considered within this chapter.
Mitigation and monitoring 9.9.28 The following sections highlight additional mitigation measures required to mitigate the significant effects identified in the previous section for both the construction and operation phases.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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Demolition & Construction Phase Construction Environmental Management Plan 9.9.29 Prior to commencement of any construction activities, a Construction Environmental Management Plan (‘CEMP’) will be developed and agreed with the Local Planning Authority. This will seek to manage and where practical minimise the impact of the construction of the Proposed Development upon the Site and surrounding area. The full list of measures that are assumed for inclusion in the CEMP is provided in Chapter 5 of this ES, and those of relevance to the water environment are summarised below. 9.9.30 Measures set out in the CEMP will be developed following best guidance of pollution control from construction sites (CIRIA C753, Chapter 31) and Pollution Prevention Guidelines 5 & 6. They will include:
•
• •
•
• • •
•
A temporary surface water drainage system will be provided for the construction period until a permanent system installed and operational. The feasibility of discharging construction runoff to ground or the River Quaggy will be assessed at the different stages during construction. The necessary consents will be obtained from the EA, and the water treatment facilities necessary to meet water quality requirements will be provided, for example for pollution control and silt interception. Wherever possible, any mixing and handling of concrete done on site, together with any washing down and cleaning of equipment used for concrete handling, will be undertaken in a designated contained area. Storage of plant, machinery fuel, or material (including stockpiles) should be avoided alongside watercourses. Appropriate storage areas to be provided. Plants and machinery will include drip trays wherever possible. All water runoff from designated refuelling areas will be channelled to an oil separator or an alternative treatment system prior to discharge. An emergency response plan to be followed in the event of a pollution incident will be developed in consultation with the EA. The plan will include the provision of appropriate emergency response equipment on-site and staff training in emergency procedures. Spill kits will be held on site with a variety of absorbent materials to be used in the event of a spill of fuel, oil or chemicals Contained wheel-washing facilities, silt traps, and cut-off ditches and/or silt fences to be installed around excavations, exposed ground, and stockpiles to prevent uncontrolled release of suspended solids. Operations will be appropriately contained to ensure that the risk of surface water flooding to neighbouring sites does not increase during construction. Any dewatering associated with construction of foundations and substructures will be limited by adopting best practice and creating an effective groundwater cut-off around the work area. Dewatering flows will be managed, removing any pollutants before disposal by infiltration. Water demand will be reduced with the use of water efficient fittings wherever possible in the site compounds and the use of non-potable water for suitable water uses.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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Geology and Groundwater 9.9.31 A robust demolition method statement and risk assessment will be prepared to support the demolition of existing buildings and remove existing ground obstructions to mitigate against creating pathways that could contaminate the groundwater. 9.9.32 A robust piling method statement and risk assessment will be developed to mitigate against creating pathways that could contaminate the groundwater. 9.9.33 The development and implementation of Measures set out in the CEMP will mitigate the risk of pollution of aquifers and watercourses during the construction period. Flood Risk 9.9.34 The tendering process will ensure that construction site managers and workers are aware of the risks of flooding, sign up to the EA flood warning service and have an emergency plan to adequately protect workers, equipment and ongoing works. Surface Water 9.9.35 No significant effects on surface water during the construction period have been identified. Therefore, no further mitigation measures are required. Water and drainage infrastructure 9.9.36 No significant effects on Water and drainage infrastructure associated with the construction period have been identified. Therefore, no further mitigation measures are required. During Operation Geology and Groundwater 9.9.37 No significant effects on groundwater associated with the operational phase of the Proposed Development have been identified and therefore no further mitigation measures are required. Flood Risk 9.9.38 No significant adverse effects on flood risk associated with the operational phase of the proposed Development have been identified and therefore no further mitigation measures are required. Surface Water 9.9.39 No significant adverse effects on surface water associated with the operational phase of the Proposed Development have been identified and therefore no further mitigation measures are required. Water and drainage infrastructure 9.9.40 No significant effects on Water and drainage infrastructure associated with the operational phase have been identified and therefore no further mitigation measures are required.
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Residual Effects 9.9.41 The following sections highlight any residual effects following implementation of the proposed additional mitigation measures, for both the construction and operation phases. During Construction 9.9.42 Potential contamination of the superficial aquifer associated with demolition will be fully mitigated by the implementation of the demolition and construction methods statements. Any residual impact would therefore be of negligible to minor adverse magnitude. This would therefore result in a Neutral to Minor Negative residual effect, considered Not Significant. 9.9.43 Potential contamination of the chalk aquifer during piling will be fully mitigated by the implementation of a robust piling method statement. Any residual impact would therefore be of negligible to minor adverse magnitude. This would therefore result in a Neutral to Minor Negative residual effect, considered Not Significant. 9.9.44 Potential contamination of the superficial and chalk aquifers by accidental spillage and release of contaminants stored within the site (fuels, chemicals, construction materials (e.g. cement)), sediments and construction will be mitigated by the implementation of measures set out in the CEMP. Any residual impact would therefore be of negligible to minor adverse magnitude. This would therefore result in a Neutral to Minor Negative residual effect, considered Not Significant. 9.9.45 Potential fluvial and surface water flooding to the northern part of the site will be fully mitigated by ensuring site manager’s and worker’s awareness, signing up to the EA flood warning service and having an emergency plan. Any residual impact would therefore be of negligible to minor adverse magnitude. This would therefore result in a Neutral to Minor Negative residual effect, considered Not Significant. 9.9.46 No additional mitigation measures are required with respect to water and drainage infrastructure. During Operation 9.9.47 No mitigation measures are required with respect to flood risk, surface water, and water and drainage infrastructure resources during the operational phase of the proposed Development. The residual effects as the same as before the implementation of any mitigation measures.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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9.10 Cumulative Effects 9.10.1 This section considers the likely cumulative effects that could arise from the Proposed Development when considered alongside other committed development schemes in proximity to the Site. It identifies whether effects from several developments which individually may be insignificant could, when considered together, cause significant cumulative effects requiring mitigation. 9.10.2 A number of committed developments have been identified as being relevant to this assessment. These were identified through a review of London Borough of Lewisham planning portal and have been agreed with LBL. 9.10.3 The assessment is based on the best available information and draws on the assessments included in the Environment Statement and Planning Application Reports that accompany the development applications, where available. Demolition and Construction Phase Assessment 9.10.4 There is a potential cumulative risk that removal of redundant piles, other obstructions, and installation of new piles on multiple developments could impact the groundwater quality or local water level regime of the superficial aquifer. This will be mitigated by demolition and construction method statements and risk assessments, as is standard practice on construction sites. Varied construction phasing will also mean that developments are not all demolishing concurrently so will not all affect the aquifer at the same time if pollution pathways were created. The impact on the aquifer would therefore be of negligible to minor adverse magnitude. The superficial aquifer is considered to have a medium sensitivity to pollution and change in water level regime. This would therefore result in a Neutral to Minor Negative cumulative residual effect, considered Not Significant. 9.10.5 Construction of deep pile foundations could create a pollution pathway and impact the quality of the Chalk aquifer if unmitigated. This will be mitigated by piling method statements and risk assessments, as are standard practice. Varied construction phasing will also mean that developments are not all piling concurrently so will not all affect the aquifer at the same time if pollution pathways were created. The Chalk aquifer is noted as having a high sensitivity given its regional significance for water supply, and impact magnitude of moderate adverse if unmitigated. This would therefore result in a Neutral to Minor Negative cumulative residual effect, considered Not Significant
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9.10.6 The presence at multiple development construction site of fuels, chemicals and construction materials (e.g. cement) and construction waste could lead to releases of pollutants to shallow groundwater which unmitigated could have an impact on groundwater quality. However, these potential impacts will be controlled by the measures taken as part of the CEMP and good site management, specific method statements and risk assessments for the works, and any impact would be negligible. Such measures are standard across construction sites. The impact on the aquifers or watercourse would be of negligible to minor adverse magnitude. The shallow aquifer is considered to have a medium sensitivity to pollution. This would therefore result in a temporary Neutral cumulative effect on groundwater quality, considered Not Significant. 9.10.7 There is a potential risk of surface water pollution from multiple developments, through the construction of drainage systems or accidental runoff or spillage, by sediments, fuels, chemicals and construction materials. However, these potential impacts will be controlled by the measures taken as part of the CEMP (including chemical storage and construction drainage management plan), and any impact would be negligible to minor, depending on nature and extent of pollution incident. Varied construction phasing will also mean that developments are not under construction concurrently. The River Ravensbourne and Quaggy are considered to have a high sensitivity to pollution. This would therefore result in a temporary Minor Negative cumulative effect, considered to be Not Significant. 9.10.8 Construction foul drainage flows will be discharged to the foul sewer from the different being delivered. These flows will be relatively small in comparison with operational foul flows, and Thames Water will be responsible for ensuring that the wastewater drainage infrastructure has capacity to handle the operational flows. As such the magnitude of the cumulative impact would be minor. The sensitivity of the local sewers to increased flow is considered to be medium. This would therefore result in a temporary Minor Negative cumulative effect, considered Not Significant. 9.10.9 Water will be supplied to the multiple sites being delivered from the local water mains. These flows will be relatively small in comparison with operational water demands. Thames Water will be responsible for ensuring that the water supply infrastructure has capacity to handle the operational flows. The magnitude of the impact would be minor. The sensitivity of the local water mains to increased demand is considered to be medium. This would therefore result in a temporary Minor Negative cumulative effect, considered Not Significant. Mitigation, Monitoring and Residual Effects 9.10.10 No significant cumulative effects during the construction period have been identified. Therefore, no further mitigation measures are required.
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Operational Phase Assessment 9.10.11 The London Plan Policy SI13 and SUDS best practice guidance promotes infiltration of stormwater drainage flows to ground. This is subject to infiltration and ground contamination testing and groundwater monitoring. Infiltration drainage features are also generally designed to intercept diffuse urban pollutants. As such, any cumulative impact on groundwater quality would be negligible. The superficial aquifer is considered to have a medium sensitivity to pollution. This would therefore result in a Neutral cumulative effect on groundwater quality, considered Not Significant. 9.10.12 There are minor beneficial effects for surface water and flood risk for the site. In combination with other sites in operation likely to have similar SUDs drainage systems in accordance with local policy, this will result over time in a cumulative minor to moderate beneficial effect. The sensitivity of the local residents and businesses to flooding is low to high depending on land use. Reducing runoff rates will provide a reduction of local flooding, overall resulting in a Minor to Moderate Positive cumulative effect, which in time will be Significant. 9.10.13 The Proposed Development will result in an increase in water demand against the current baseline as will other committed developments. Local water resources are scarce and sensitivity is high. The combination of many minor adverse effects on water resources will accumulate, however Thames Water will have been consulted on all major proposed developments and will ensure through their Water Resources management Plan that the demand can be met. This would therefore result in a Minor Negative cumulative effect, considered to be Not Significant. 9.10.14 Foul drainage flows from multiple developments will be discharged to the local foul and combined sewers. Thames Water will have been consulted on all major proposed developments and will implement strategic measures to accommodate the proposed peak discharge from the developments, considering their phasing. The cumulative impact would be managed and its magnitude would therefore be minor. The sensitivity of the local sewers to increased flow is considered to be low. This would therefore result in a Minor Negative cumulative effect, considered Not Significant. 9.10.15 Water will be supplied to the proposed multiples developments from the local water mains. Thames Water will have been consulted on all major proposed developments and will implement strategic measures to ensure that the water supply infrastructure can accommodate the demands of the developments, considering their phasing. The cumulative impact would be managed and its magnitude would therefore be minor. The sensitivity of the local water mains to increased demand is considered to be low. This would therefore result in a Minor Negative cumulative effect, considered Not Significant.
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Mitigation, Monitoring and Residual Effects 9.10.16 No additional mitigation measures are required during the demolition and construction phases or operational phase.
9.11 Summary 9.12
This Chapter assesses the likely significant effects of the Proposed Development on the water environment, flood risk and the water and drainage infrastructure in line with current national, regional, and local policy and legislative requirements for the construction and operational phases of the Development. It is supported by a Flood Risk Assessment (FRA) and a Drainage Strategy (Appendices 9.1 and 9.2).
9.13
A summary of the significant effects, proposed mitigation measures and residual effects has been captured in Table 9.6.
9.13.1 The Proposed Development will not result in any significant detrimental effects that cannot be mitigated. 9.13.2 The Proposed Development with result in minor beneficial effects for surface water and flood risk for the site.
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Table 9.6: Summary of Effects DESCRIPTION RECEPTOR SIGNIFICANCE OF EFFECTS OF SIGNIFICANT MAJOR / POSITIVE / P / D / ST / EFFECTS
MODERATE / NEGATIVE T MINOR / NEGLIGIBLE
I
MT / LT
Pollution caused Shallow by demolition aquifer works and removal of subsurface obstructions. Pollution caused Chalk by piled aquifer foundations
Moderate
Negative
T
D
MT
Moderate
Negative
T
D
MT
Potential Shallow contamination aquifer by spillage and release of contaminants from construction site Potential Chalk contamination aquifer by spillage and release of contaminants
Moderate
Negative
T
D
ST
Moderate
Negative
T
D
ST
SUMMARY OF MITIGATION / ENHANCEMENT MEASURES
SIGNIFICANCE OF RESIDUAL EFFECTS
RELEVANT RELEVANT LEGISLATIO N
MAJOR / POSITIVE / P / D / ST / POLICY MODERATE / NEGATIVE T I MT / MINOR / LT NEGLIGIBLE
Demolition & Construction
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Submission and approval Negligible to Negative of demolition method minor statement and risk assessment to control risk of groundwater pollution Submission and approval Negligible to Negative of piling method minor statement and risk assessment to be undertaken to mitigate against creating pathways that could contaminate the groundwater Construction Negligible to Negative Environmental minor management Plan
T D
MT
NPPF Water PPG Environment Lewisham Regulations Local Plan Environment Act
T D
MT
NPPF Water PPG Environment Lewisham Regulations Local Plan Environment Act
T D
ST
NPPF Water PPG Environment Lewisham Regulations Local Plan Environment Act
Construction Environmental management Plan
T D
ST
NPPF Water PPG Environment Lewisham Regulations Local Plan Environment Act
Negligible to Negative minor
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from construction site Risk of fluvial Site Minor to and surface workers moderate water flooding to and the northern equipment part of the site from the wider local sewer catchment.
Operational Geology and groundwater Flood Risk Surface Water
Water and Drainage
Drainage Neutral flows Aquifer Minor Future Minor / occupants Moderate River Minor quaggy and local sewers Water Minor demand
Negative
T
D
ST
The tendering process Negligible to Negative will ensure that minor construction site managers and workers are aware of the risks of flooding, sign up to the EA flood warning service and have an emergency plan to adequately protect workers, equipment and ongoing works.
T D
ST
P
D
LT
None required
Neutral
PD
LT
Positive Positive
P P
D D
LT LT
None required None required
Positive Positive
PD PD
LT LT
Positive
P
D
LT
None required
Minor Minor / Moderate Minor
Positive
PD
LT
Negative
P
D
LT
None required
Minor
Negative
PD
LT
Foul
Minor
Negative
P
D
LT
None required
Minor
Negative
PD
LT
Water supply
Minor
Negative
P
D
LT
None required
Minor
Negative
PD
LT
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NPPF Water PPG Environment Lewisham Regulations Local Plan Environment Act
Key: • •
•
P/T: Permanent / Temporary D/I: Direct / Indirect ST/MT/LT: Short Term / Medium Term / Long Term
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10.0 References Ref 9.1 European Parliament. (2000). EU Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community action in the field of water policy Ref 9.2 European Parliament. (2007). EU Directive 2007/60/EC of the European Parliament and of the Council of 23 October 2007 on the assessment and management of flood risks Ref 9.3 HMSO. (1991, 1994). Land Drainage Act 1991 and Land Drainage Act 1994 Ref 9.4 HMSO. (1991). Water Resources Act 1991 Ref 9.5 HMSO. (1991). Water Industry Act 1991 Ref 9.6 TSO. (2010). Environmental Permitting (England and Wales) Regulations Ref 9.7 HMSO. (2003). Water Act 2003 Ref 9.8 HMSO. (2003). The Water Environment (Water Framework Directive) (England and Wales) Regulations 2003 Ref 9.9 HMSO. (2010). Flood and Water Management Act Ref 9.10 HMSO. (1995). Environment Act 1995 Ref 9.11 HMSO. (2021). Environment Act 2021 Ref 9.12 Secretary of State. (2009). Flood Risk Regulations Ref 9.13 Ministry of Housing, Communities and Local Government. (2023). National Planning Policy Framework (NPPF). https://www.gov.uk/government/publications/national-planning-policyframework--2 Ref 9.14 Ministry of Housing, Communities and Local Government. (2023). Planning Practice Guide. http://planningguidance.planningportal.gov.uk Ref 9.15 DEFRA. (2015). Sustainable Drainage Systems Non-statutory technical standards for sustainable drainage systems Ref 9.16 Greater London Assembly (GLA). (2021), The London Plan Ref 9.17 London Borough of Lewisham. (2011). Core Strategy Ref 9.18 London Borough of Lewisham. (2014). Lewisham Development Management Local Plan Ref 9.19 London Borough of Lewisham. (2014). Lewisham Town Centre Local Plan Ref 9.20 London Borough of Lewisham. (2023). Lewisham Local Plan (Regulation 19 Stage) Ref 9.21 AECOM. (2018). London Borough of Lewisham Strategic Flood Risk Assessment Level 1 Report Ref 9.22 AECOM. (2020). London Borough of Lewisham Strategic Flood Risk Assessment Level 2 Report Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 9: Flood Risk and Drainage
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Ref 9.23 London Borough of Lewisham. (2022). Lewisham’s Local Flood Risk Management Strategy 2022-2027 Ref 9.24 Access environmental data. (2023). https://www.gov.uk/guidance/downloadenvironmental-data. Ref 9.25 British Geological Survey. (2024). BGS Geology Viewer - British Geological Survey. https://www.bgs.ac.uk/map-viewers/bgs-geology-viewer/. Ref 9.26 Magic Map Home. (2024). https://magic.defra.gov.uk/home.htm (Accessed: August 20, 2024). Ref 9.27 Flood risk assessments: climate change allowances. (2022). https://www.gov.uk/guidance/flood-risk-assessments-climate-change-allowances. Ref 9.28 BSI. (2022), BS EN 752:2017 Ref 9.29 CIRIA. (2015). The SuDS Manual (C753) Ref 9.30 Ravensbourne Operational Catchment | Catchment Data Explorer. (2024). https://environment.data.gov.uk/catchment-planning/OperationalCatchment/3369/print.
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10.0 Ground Conditions and Contamination 10.1 Introduction 10.1.1 This Chapter reports the likely significant effects of the Proposed Development on the Site and the surrounding area in terms of Ground Conditions and Contamination matters. Where appropriate, it also identifies proposed mitigation measures to prevent, minimise or control likely negative effects arising from the Proposed Development and the subsequent anticipated residual effects. 10.1.2 The effects of the Proposed Development are considered over the demolition and construction phase. Operational phases have been scoped out of assessment within this Chapter. 10.1.3 The main Ground Conditions and Contamination issues covered in this Chapter include the following: • • •
Potential effect on construction workers from pre-existing contamination underlying the Site; Potential effect on adjacent sensitive site users from pre-existing contamination underlying the Site; and, Potential effect on Controlled Waters receptors from pre-existing contamination.
10.1.4 This Chapter (and its associated figures and appendices) should be read together with the Introductory Chapters of this ES (Chapters 1 – 5), as well as Chapter 17: Effect Interactions. 10.1.5 This Chapter is accompanied by the following appendices: • • •
WSP, Lewisham Shopping Centre – Geo-Environmental Preliminary Risk Assessment, dated October 2024. Report Reference: LSC-WSP-XX-XX-AS-EN000004 (Ref 1.1) (Appendix 10.1); WSP, Lewisham Shopping Centre – Phase 1 Generic Quantitative Risk Assessment, dated December 2022. Report Reference: LSC-WSP-XX-XX-RP-GW-001 (Ref 1.2) (Appendix 10.2); and, WSP, Lewisham Shopping Centre – Phase 2 Generic Quantitative Risk Assessment, dated December 2022. Report Reference: LSC-WSP-XX-XX-RP-GW-002 (Ref 1.3) (Appendix 10.3).
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Competence 10.1.6 This assessment has been undertaken by Adam Yusaf and Roisin Lindsay. Adam Yusaf is a Principal Environmental Consultant specialising in ground conditions and contamination with 9 years of experience in land quality assessments to support planning applications for commercial, industrial and residential developments. Adam is a Chartered Environmentalist with the Institute of Environmental Sciences (IES), as well as a registered risk assessor (human health and controlled waters) with the Society of Brownfield Risk Assessment (SoBRA). 10.1.7 Roisin is a Chartered Environmentalist with 13 years’ experience within all aspects of hydrogeology, contaminated land and regeneration throughout the UK, Europe and Middle East. Her experience covers a range of sectors including Environmental Impact Assessments, energy, rail, infrastructure, utilities and, commercial and industrial sectors. Roisin has wide ranging expertise involving leading ground conditions inputs for EIAs, soil assessments, comprehensive site investigations and monitoring programmes, groundwater contaminant fate and transport, human health risk assessment projects, and surface water quality appraisals.
10.2 Legislation, Planning Policy and Guidance 10.2.1 The following national, regional and local planning policy and guidance is of relevance to the assessment of the effects of the Proposed Development in relation to Ground Conditions and Contamination.
Planning Policy Context National 10.2.2 The following national level policy and guidance documents are of relevance to the Proposed Development: National Planning Policy Framework (2023) (Ref 1.4) 10.2.3 Chapter 15 of the National Planning Policy Framework (NPPF) (Ministry of Housing, Communities and Local Government, 2021) (last updated 20 December 2023) sets out the provisions for planning decisions in relation to ground conditions and pollution issues as follows: 10.2.4 Paragraph 180 states that: “Planning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan)
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b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland. e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans. f)
remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.”
10.2.5 Paragraph 189 states that: “Planning policies and decisions should ensure that: a) a site is suitable for its proposed use taking account of ground conditions and any risks arising from land instability and contamination. This includes risks arising from natural hazards or former activities such as mining, and any proposals for mitigation including land remediation (as well as potential impacts on the natural environment arising from that remediation) b) after remediation, as a minimum, land should not be capable of being determined as contaminated land under Part IIA of the Environmental Protection Act 1990; and c) adequate site investigation information, prepared by a competent person, is available to inform these assessments.”;
10.2.6 Paragraph 190 states that: “Where a site is affected by contamination or land stability issues, responsibility for securing a safe development rest with the developer and/or landowner.”
10.2.7 Paragraph 191 states that “Planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development.”
10.2.8 In addition, under Chapter 11 “Making effective use of land”, paragraph 124 states “Planning policies and decisions should:… c) give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated and unstable land”.
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Environmental Protection Act (1990) Part 2A, Section 78A (Ref 1.5) 10.2.9 Part 2A of the Environmental Protection Act (EPA) 1990 (as amended) deals with contaminated land which is defined as: “any land which appears to the local authority in whose area it is situated to be in such a condition, by reason of substance in, on or under the land that; a) Significant harm is being caused or there is significant possibility of such harm being caused; or b) Significant pollution to controlled waters is being caused, or there is a significant possibility of such pollution being caused”.
The Contaminated Land (England) (Amendment) Regulations 2012 (Ref 1.6) 10.2.10 The Regulations provide a definition of what constitutes ‘contaminated land’ and set out the responsibilities of the local authority and the Environment Agency (EA) in the identification and management of contaminated land. Government objectives with respect to land contamination policy and the Part 2A regime of the EPA 1990 are set out in the Department for Environment Food and Rural Affairs (Defra) Contaminated Land Statutory Guidance 2012 (Ref 13.3) as: • • •
“Identify and remove unacceptable risks to human health and the environment; Seek to ensure that contaminated land is made suitable for its current use; and Ensure that the burdens faced by individuals, companies and society as a whole are proportionate, manageable and compatible with the principles of sustainable development.” 10.2.11 These three objectives underlie the ‘suitable for use’ approach to the assessment and remediation of 'land contamination’. This approach recognises that the risks presented by any given level of land contamination will vary greatly according to the use of the land and a wide range of other factors, such as the sensitivity of the underlying geology and the receptors which may be affected. The ‘suitable for use’ approach consists of three elements: • • •
Ensuring that land is suitable for its current use; Ensuring that land is made suitable for any new use; and Limiting requirements for remediation to the work necessary to prevent unacceptable risks to human health or the environment in relation to the current use or future use of the land.
The Water Environment (Water Framework Directive) (England and Wales) Regulations 2017 (Ref 1.7) 10.2.12 The overall objective of the Water Framework Directive (WFD) is to bring about the effective co-ordination of water environment policy and regulation across Europe. The main aims of the legislation are as follows: • •
Ensure, where feasible, that all surface water and groundwater bodies reach ‘good’ status (in terms of ecological and chemical quality and water quantity, as appropriate); Proposed projects do not compromise measures identified to reach improved / good status;
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•
Prevent water body deterioration, promote sustainable water use, reduce pollution and contribute to the mitigation of flood and droughts.
Groundwater Directive (2006/118/EC) (Ref 1.8) 10.2.13 The Groundwater Directive aims to set groundwater quality standards and introduce measures to prevent or limit pollution of groundwater, including those listed with the ‘List of Priority Substances’. The Directive has been developed in response to the requirements of Article 17 of the WFD, specifically the assessment of chemical status of groundwater and objectives to achieve ‘good’ status. Construction (Design and Management) (CDM) Regulations 2015 (Ref 1.9) 10.2.14 This requires clients (those persons who are instructing contractors) to use their influence to ensure that the arrangements made by other duty holders are sufficient to safeguard the health and safety of those working or those affected by that work. Environment Act, 2021 (Ref 1.10) 10.2.15 The Environment Act 2021 provides a framework for improving environmental management across a wide spectrum of issues including water quality, nature and biodiversity. It aims to deliver long-term targets to improve environmental conditions and reduce pollution. Dangerous Substances Directive 2006/11/EC (Ref 1.11) 10.2.16 The Directive focuses on pollution caused by certain substances discharged into the water environment and aims to reduce pollution of surface waters by these dangerous substances, which have been selected mainly on the basis of how toxic or persistent they are, including how much they may accumulate in organisms. Control of Asbestos Regulations 2012 (Ref 1.12) 10.2.17 The Control of Asbestos Regulations provide a framework for the management of asbestos / asbestos containing materials (ACMs) in existing non-domestic premises and during any work activity involving asbestos. Duty holders must make sure anyone who carries out any work in non-domestic premises and any occupants of the premises are not exposed to asbestos from ACMs that may be present. Contaminated Land (England) Regulations 2006 (Ref 1.13) 10.2.18 These Regulations make provision for the identification and remediation of contaminated land under Part 2A of the EPA 1990. The Regulations make provision for an additional description of contaminated land that is required to be designated as a special site. Environmental Damage (Prevention and Remediation) Regulations 2015 (Ref 1.14) 10.2.19 These Regulations oblige those who create environmental damage, whether by water pollution, adversely affecting protected species or sites of special scientific interest (SSSIs), or by land pollution that causes risks to human health, to not only cease the damage, but also to implement a wide variety of remedial measures to restore affected areas.
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Water Resources Act (England and Wales) 1991 (Ref 1.15) 10.2.20 Section 104 of the Water Resources Act 1991 provides a definition of Controlled Waters which includes territorial waters within the 3 nautical mile limit, coastal waters extending inland, inland waters and groundwater any waters contained in underground strata. A Green Future: Our 25 Year Plan to improve the Environment (Ref 1.16) 10.2.21 This sets out the Government’s 25-year plan to improve the health of the environment by using natural resources more sustainably and efficiently. The plan details plans on reducing pollution which includes “minimising the chemical contamination of our water”. Regional London Plan 2021 (Ref 1.17) 10.2.22 The Spatial Development Strategy for Greater London setting out a framework for how London will develop over the next 20-25 years and the Mayor’s vision for Good Growth. Relevant policies are: Policy G9: Geodiversity and Policy SI17: Protecting and Enhancing London’s Waterways are the key policies specific to ground conditions and soils. Policy G9: Geodiversity: “In Development Plans, boroughs should:…Establish clear goals for the management of identified sites to promote public access, appreciation and interpretation of geodiversity…Development proposals should…make a positive contribution to the protection and enhancement of geodiversity”. Policy SI17: Protecting and Enhancing London’s Waterways: “Development plans should support river restoration and biodiversity improvements… Development proposals should support and improve the protection of the distinct open character and heritage of waterways and their settings… Development proposals along London’s canal network, docks, other rivers and water space (such as reservoirs, lakes and ponds) should respect their local character, environment and biodiversity and should contribute to their accessibility and active water-related uses. Development Plans should identify opportunities for increasing local distinctiveness and recognise these water spaces as environmental, social and economic assets”. Sustainable Design and Construction Supplementary Planning Guidance (2014) (Ref 1.18) 10.2.23 Section 4.2 of the guidance covers land contamination providing guidance outlining who is responsible for dealing with contamination and encouraging the use of bioremediation where appropriate. Local London Borough of Lewisham: Core Strategy (2011) (Ref 1.19) 10.2.24 The Core Strategy sets out the vision, objectives, strategy and policies to manage development and regeneration within the London Borough of Lewisham. The strategy outlines the plan for development of brownfield land and regenerating existing urban areas, by placing emphasis on the environmental quality of green space and the public realm.
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Lewisham Development Management Local Plan (2014) (Ref 1.20) 10.2.25 DM Policy 28 outlines the approach to the management of contaminated land risks, including the approach to the assessment of risks. Lewisham Town Centre Local Plan (2014) (Ref 1.21) 10.2.26 The Twon Centre Local Plan outlines details of the Area Action Plan within the context of the planning policy to assist with the future development of Lewisham town centre. Draft Lewisham Local Plan (Regulation 19 stage) (2023) (Ref 1.22) 10.2.27 SD11 Ground Conditions outlines the requirements for development proposals to demonstrate that contaminated sites will be returned to beneficial use. Guidance National Planning Practice Guidance (2021) (Ref 1.23) 10.2.28 Sets out the Government’s planning policies for England and how these should be applied. The relevant policies under ‘Making effective use of land’, ‘Conserving and enhancing the natural environment’ and, ‘Facilitating the sustainable use of minerals’ are set out in the following Chapters:
• • •
Chapter 11 – Making Effective Use of Land, Paragraphs 119 to 120; Chapter 15 – Conserving and Enhancing the Natural Environment, Paragraphs 174 to 185; and Chapter 17 – Facilitating the Sustainable Use of Minerals, Paragraphs 210 to 216. C552 Contaminated Land Risk Assessment: A Guide to Good Practice 2001 (Ref 1.24)
10.2.29 Guidance to assist those who carry out contaminated land risk assessments. Includes the overall risk management process involving identifying risks and assessing their significance. C532 Control of Water Pollution from Construction Sites: Guidance for Consultants and Contractors 2001 (Ref 1.25) 10.2.30 Provides guidance on environmental good practice for the control of water pollution arising from construction activities. The document focuses on the potential sources of water pollution from within construction sites and the effective methods of preventing its occurrence. C733 Asbestos in Soil and Made Ground: A Guide to Understanding and Managing Risks 2014 (Ref 1.26) 10.2.31 Guidance to improve the process of risk assessment and risk management on sites that contain soils or made ground potentially contaminated by asbestos.
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Land Contamination Risk Management (LCRM) 2023 (Ref 1.27) 10.2.32 Technical guidance to be followed by all parties engaged in and responsible for land contamination. To understand the management of contamination issues, the LCRM recommends the use of a Conceptual Site Model (CSM), comprising three elements: a source; a pathway; and a receptor. The CSM will be used to identify and assess the potential effects on the identified sensitive receptors (including human health, controlled waters, buildings and services) and to outline mitigation measures to manage the risks identified in the assessment. Guidance on Assessing Risk to Controlled Waters from UK Land Contamination Under Conditions of Future Climate Change 2022 (Ref 1.28) 10.2.33 Presents clear practical guidance on how to include the potential effects of climate change in controlled waters risk assessment for land contamination. Groundwater Protection Technical Guidance 2017 (Ref 1.29) 10.2.34 Guidance on managing and protecting groundwater through consideration of the impact on existing or potential uses of ground resources; hydraulic properties of the rock strata; the quality of any receiving groundwater; and any likely changes in circumstances over the time in which groundwater may be impacted. DMRB LA109 Geology and Soils (Ref 1.30) 10.2.35 Guidance on assessing and managing the effects associated with geology and soils resulting in:
• • •
effects on bedrock geology and superficial deposits, including geological designations and sensitive / valuable non-designated features; effects on soil resources; and effects from contamination on human health, surface water and groundwater.
10.3 Consultation 10.3.1 As discussed in Chapter 2: Approach to Assessment, consideration has been given to the formal EIA Scoping Opinion provided by LBL and consultees and any additional consultation that may have occurred during the design period of the Proposed Development. Table 10.1 Consultation Feedback Consultee
Comment
Where is this addressed?
Lewisham Council Scoping Opinion (Temple Consultants)
Temple noted that although the baseline conditions in the scoping report presented a reasonably detailed Preliminary Conceptual Site Model, the Preliminary Risk Assessment (PRA) was not included.
The Preliminary Risk Assessment document is included with the planning submission as Appendix 10.1 and has been used to inform the baseline conditions in Section 10.6.
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Consultee
Comment
Where is this addressed?
LBL and Temple generally agreed with the assessment methodology, and elements scoped in and out of assessment within the scoping report.
This chapter is in line with the scoping report.
Environmental Health Officer (EHO) at Lewisham Council (consulted as part of the PRA).
The EHO was contacted as part of the PRA requesting information pertinent to contaminated land and the Ground Conditions chapter. The EHO was not aware of any environmental issues associated with the Site and indicated that the Site was not designated as contaminated land under Part 2a of the Environmental Protection Act. In addition, potentially contaminative historical land uses at the Site were identified by the EHO to include a garage, laundry, works and electrical substation.
Information from the EHO is presented within the baseline section of the Ground Conditions chapter, as well as within the Preliminary Risk Assessment (Appendix 10.1).
Customer Engagement Officer at Environment Agency (EA) (consulted as part of the PRA).
The EA was contacted as part of the PRA requesting information pertinent to contaminated land and the Ground Conditions chapter. The EA was not aware of any sites determined as Contaminated Land or Special Sites under S78 of the Environmental Protection Act, and was also not aware of any historical landfills located in the Study Area.
Information from the EA is presented within the baseline section of the Ground Conditions and Contamination chapter, as well as within the Preliminary Risk Assessment (Appendix 10.1).
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10.4 Assessment Methodology and Significance Criteria 10.4.1 The following section outlines the methodologies applied to identify and assess the potential impacts and likely effects to result from the Proposed Development. Scope of the Assessment 10.4.2 An EIA Scoping Report was issued to LBL in January 2024 (Appendix 2.1). LBL’s formal Scoping Opinion was issued in June 2024 (Appendix 2.2). 10.4.3 The following potential effects were scoped into the assessment: Demolition and Construction Phase • • •
Potential effect on construction workers from pre-existing contamination within the underlying soils and groundwater including potential effects from unexploded ordnance (UXO); Potential effect on adjacent sensitive site users from contamination within underling soils and groundwater; and, Potential effect on controlled waters during construction activities.
10.4.4 The following potential effects were scoped out of the assessment: •
Potential effect to future site users, maintenance workers, adjacent sensitive site users, and controlled waters from potential contamination within the underlying soils and groundwater. 10.4.5 It is anticipated that any contaminants identified during the construction stages will be remediated in line with the proposed uses. 10.4.6 This negates the requirement for consideration of potential impacts to future Site users, maintenance workers, adjacent sensitive site users, controlled waters and services / infrastructure during the operational stages of the Proposed Development. Therefore, the operational phases of the Proposed Development have been scoped out of further assessment. This approach was agreed with the Local Planning Authority in their scoping opinion (Appendix 2.1). Extent of The Study Area 10.4.7 The study area considered for the purpose of this assessment consists of the Site itself, as well as identified receptors within 500m from the Site and extending up to 1km from the Site in relation to sensitive controlled water receptors only. This is in line with best practice guidance.
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Method of Baseline Collection 10.4.8 Data for the baseline conditions at the Site was taken from the Preliminary Risk Assessment (PRA) (Appendix 10.1). Based on professional judgement and knowledge, it is understood that there have been no significant changes at the Site since the production of the PRA and therefore the data remains accurate. The report includes a Groundsure report, which is presented in Appendix E of the PRA (Appendix 10.1). 10.4.9 A Site walkover was carried out on 13 August 2021 for the purposes of informing the PRA. 10.4.10 A ground investigation was undertaken at the Site in 2022 and was reporting in two separate phases. The information from the investigations has been used to inform the baseline conditions at the Site. The Generic Quantitative Risk Assessment reports are provided in Appendix 10.2 and 10.3. Method of Assessment Demolition & Construction Phase 10.4.11 The EA’s guidance LCRM (2023) (Ref 1.27) advocates the use of a conceptual risk assessment model (Conceptual Site Model). The basis of this approach comprises three elements: a source, a pathway and a receptor. Without each of these there can be no contamination risk. Therefore, the presence of measurable concentrations of contaminants within the ground and subsurface environment does not automatically imply that a contamination risk exists, since the contamination must be defined in terms of pollutant linkages and unacceptable risk of harm. The nature and importance of both pathways and receptors, which are relevant to a particular Site, would vary according to the intended use of the Site, its characteristics and its surroundings. The potential for harm to occur requires three conditions to be satisfied: • • •
The presence of substances (potential contaminants) that may cause harm (the ‘Source’ of contamination); The presence of a receptor that may be harmed, (e.g. the water environment or humans, buildings, fauna and flora) (the ‘Receptor’); and, The existence of a linkage between the source and the receptor (the ‘Pathway’).
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10.4.12 The LCRM guidance is to be used as a technical framework in the understanding of how contamination issues that may arise on the Site could be managed. 10.4.13 The Conceptual Site Model is to be used to identify and assess the potential effects on the identified sensitive receptors (including human health, controlled waters, buildings and services) and outline mitigation measures to manage the risks identified in the assessment. 10.4.14 The potential effect of the Proposed Development on ground conditions and contamination, and/or the effect of ground conditions and contamination on the Proposed Development, is to be assessed during the construction stages. The significance level attributed to each effect is to be assessed based on the magnitude of change due to the Proposed Development and the importance/sensitivity of the affected receptor / receiving environment to change. Operational phases of the Proposed Development have been scoped out of further assessment. 10.4.15 This ES chapter sets out the assessment of the potential effects from chemical contamination on Human Health and Controlled Waters receptors. Potential effects relating to physical contamination (i.e. sediment) and changes to groundwater recharge and flow are considered within Chapter 9: Flood Risk and Drainage. Operational Phase 10.4.16 The assessment of effects relating to Ground Conditions and Contamination during the operational stages of the Proposed Development have been scoped out of assessment.
10.5 Significance Criteria 10.5.1 The assessment of the potential impacts and likely effects as a result of the Proposed Development has taken into account both the Demolition and Construction Phases. The significance level attributed to each effect has been assessed based on the magnitude of change due to the Proposed Development and the sensitivity of the affected receptor/receiving environmental to change, as well as a number of other factors that are outlined in more detail in Chapter 2: Approach to Assessment. 10.5.2 The sensitivity of the affected receptor is assessed on a scale of very high, high, medium, low and negligible, and the magnitude of impact is assessed on a scale of major, moderate, minor, negligible and no change (as defined by DMRB guidance). 10.5.3 Assessment of receptor sensitivity for Ground Conditions and Contamination follows the procedure described in Table 10.2 which is set out in the DMRB Sustainability and Environmental Appraisal, LA 109 Geology and Soils (Table 3.11 and 3.12) (Ref 1.30). Negligible sensitivity has been removed, as it is deemed irrelevant as no receptor (in terms of Ground Conditions and Contamination) is classed as negligible. 10.5.4 Factors that may affect the sensitivity of the likely receptor include: • •
Human receptors: age, weight, sex, duration on-site and distance from the Site; and Controlled waters receptors: distance from the Site and resource potential.
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Table 10.2 – Classification of Sensitivity of Resources Receptor Sensitivity
Criteria
Attribute
Typical Examples
Very High
Very rare and of international importance with no potential for replacement.
Geology
UNESCO World Heritage Sites, UNESCO, Global Geoparks, SSSI and Geological Conservation; and
Geology meeting international designation citation criteria which is not designated as such.
Review sites where citations indicate features of international importance.
Human health: very high sensitivity land use.
Contamination
Residential or allotments.
Nationally significant attribute of high importance.
Surface Water
Watercourse having a Water Framework Directive (WFD) classification shown in a RBMP and Q95 ≥ 1. 0 m3/s; and Site protected/designated under EC or UK legislation SAC, SPA, Site of Special Scientific Interest (SSSI), Ramsar site, salmonid water)/Species protected by EC legislation LA 108.
Nationally significant attribute of high importance.
Groundwater
Principal Aquifer providing a regionally important resource and / or supporting a site protected under European Commission (EC) and UK legislation Ecology and Nature Conservation; and Groundwater locally supports Groundwater dependent terrestrial ecosystem (GWDTE) or Source Protection Zones (SPZ) 1.
High
Rare and of national importance with little potential for replacement.
Geology
Geological SSSI, National Nature Reserves (NNR).
Contamination
Construction and maintenance workers (where extensive earthworks, and demolition of buildings are proposed); and
Geology meeting national designation citation criteria which is not designated as such. Human Health: high sensitivity land use.
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Receptor Sensitivity
Criteria
Attribute
Typical Examples
Locally significant attribute of high importance
Surface Water
Watercourse having a WFD classification shown in a RBMP and Q95 <1.0m3/s; and Species protected under EC or UK legislation LA 108.
Locally significant attribute of high importance.
Groundwater
Principal aquifer providing locally important resource or supporting a river ecosystem; and Groundwater supports a GWDTE or SPZ2.
Medium
Of regional importance with limited potential for replacement. Geology meeting regional designation citation criteria which is not designated as such.
Geology
RIGS.
Human Health: medium sensitivity land use.
Contamination
Construction workers (where limited earthworks, are proposed); and Commercial or Industrial.
Of moderate quality and rarity
Surface Water
Watercourses not having a WFD classification shown in a RBMP and Q95 >0.001m3/s.
Of moderate quality and rarity
Groundwater
Aquifer providing water for agricultural or industrial use with limited connection to surface water; and SPZ3.
Low
Of local importance / interest with potential for replacement
Geology
Non designated geological exposures, former quarries / mining sites.
Low sensitivity land use
Contamination
Construction and maintenance workers (Minimal disturbance of ground); and Infrastructure (roads, bridges, railways, buildings).
Lower quality
Surface Water
Watercourses not having a WFD classification shown in a RBMP and Q95 ≤0.001m3/s.
Lower quality
Groundwater
Unproductive strata.
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10.5.5 The expected magnitude of impact to each identified attribute and receptor has been assigned in accordance with the principles established in DMRB LA 109 (Table 3.12) DMRB LA 113 (Table 3.70) (Ref 1.31) and DMRB LA 104 (Table 3.4N) (Ref 1.32), along with professional judgement. The terms used to describe magnitude of impact are defined in Table 10.3. Table 10.3 – Classification of Magnitude of Impact Magnitude of Impact
Definition
No Change
Negligible
No loss or alteration of characteristics features or elements; no observable impact in either direction. Adverse
Very minor loss or detrimental alteration to one or more characteristics, features or elements. E.g. Very limited mass of contamination mobilised – just detectable, very limited barely discernible change to groundwater regime.
Beneficial
Very minor benefit to or positive addition of one or more characteristics, features or elements. E.g. Very limited removal of mass of contamination – just detectable.
Minor
Adverse
Some measurable change in attributes, quality or vulnerability; minor loss of, or alteration to, one (maybe more) key characteristics, features or elements. E.g. Measurable but relatively small-scale increase in an area of contaminated land or ground gas regime, but insufficient to alter end land use. Worsening of groundwater conditions that are insufficient to change status or potential use of the water body.
Beneficial
Minor benefit to, or addition of, one (maybe more) key characteristics, features or elements; some beneficial impact on attribute or a reduced risk of negative impact occurring. E.g. Measurable but relatively small-scale decrease in an area of contaminated land or ground gas regime, but insufficient to alter end land use. Improvement of groundwater conditions that are insufficient to change status or potential use of the water body.
Moderate
Adverse
Loss of resource, but not adversely affecting the integrity; partial loss of/damage to key characteristics, features or elements. E.g. Worsening of soil quality or ground gas regime for a portion of the Site to a degree sufficient to alter land to a less sensitive end-use in those portions or to a degree requiring a change in management / mitigation measures for Site use. Change in groundwater conditions that may be sufficient to change local groundwater regime and potential aquifer uses (e.g. localised contaminant impact, localised change in groundwater levels).
Beneficial
Benefit to, or addition of, key characteristics, features or elements; improvement of attribute quality. E.g. Improvement in soil quality or ground gas regime for a portion of the Site to a degree sufficient to alter land to a more sensitive end-use in those
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Magnitude of Impact
Definition
portions. Change in groundwater conditions that may be sufficient to change local groundwater regime and potential aquifer uses (e.g. removal of localised contaminant impact, localised change in groundwater levels). Major
Adverse
Loss of resource and/or quality and integrity of resource; severe damage to key characteristics, features or elements E.g. Change in soil quality or ground gas regime for an area of land greater than the site area, sufficient to alter land use (i.e. become unsuitable for residential use). Change in groundwater conditions sufficient to change aquifer use (e.g. contamination that prevents abstraction for potable supplies, or remediation of impacted aquifer sufficient to enable potable abstractions). Generation of large volumes of non-inert waste materials for disposal off-site to landfill.
Beneficial
Large scale or major improvement of resource quality; extensive restoration; major improvement of attribute quality. E.g. Change in soil quality or ground gas regime for an area of land greater than the site area, sufficient to alter land use (e.g. remediation of 20ha of industrial land sufficient to enable mixed residential / commercial use). Change in groundwater conditions sufficient to change aquifer use (e.g. contamination that prevents abstraction for potable supplies, or remediation of impacted aquifer sufficient to enable potable abstractions). Generation of large volumes of non-inert waste materials for disposal off-site to landfill.
Overall Significance Criteria 10.5.6 Once the sensitivity of the affected receptor / receiving environment to change and the magnitude of change have been established, the matrix presented in Table 10.4, which is based on Table 3.8.1 in DMRB LA 104 Environment Assessment and Monitoring (Ref 1.32), will be used to determine the significance of effect ranging from ‘negligible’ to ‘major’. The likely duration of the effect and likelihood of the effect occurring is also considered when assessing each effect. 10.5.7 Where a range has been provided, e.g. Moderate or Large, professional judgement has been used to define the significance. The effects are described as adverse and beneficial. An effect would be considered to be significant if assessed as moderate or above. Table 10.4 – Classification of Magnitude of Impact Environmental Value Sensitivity Magnitude of Impact
Very High
High
Medium
Low
Major
Major
Major
Moderate
Negligible
Moderate
Major
Moderate
Minor to Moderate
Negligible
Minor
Moderate
Minor to Moderate
Minor
Negligible
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Environmental Value Sensitivity Negligible
Negligible
Negligible
Negligible
Negligible
Effect Significance 10.5.8 The following terms have been used to define the significance of effects identified:
•
Major positive or negative effect – where the Proposed Development would cause a large improvement (or deterioration) to the existing environment; Moderate positive or negative effect – where the Proposed Development would cause a noticeable improvement (or deterioration) to the existing environment; Minor positive or negative effect – where the Proposed Development would cause a small improvement (or deterioration) to the existing environment; and Negligible – no discernible improvement or deterioration to the existing environment as a result of the development will occur.
• • •
10.6 Existing Baseline Conditions Site Description and Current Use 10.6.1 Table 10.5 provides a detailed summary of the Site and information obtained from a Site walkover, completed by a representative of WSP on 13 August 2021. Applicable photographs from the Site walkover presented in Appendix D of the PRA (Appendix 10.1). 10.6.2 A review of Ordnance Survey (OS) mapping, online aerial photography and relevant regulatory information obtained from the Groundsure report is also summarised below, where applicable. The Groundsure report is included as Appendix E of the PRA (Appendix 10.1). Table 10.5 – Summary of Site Details Detail
Comment
Name and Address of Site
Lewisham Shopping Centre and adjacent land, Lewisham, London, SE13 7HB
Location and Access
The Site is located on Molesworth Street, in the London Borough of Lewisham. The area is set within a commercial and residential dominated area with construction sites to the north for new tower structures. The Site is accessed by car from Rennell Street to the north via a ramp which gives access to the customer car park and also the elevated service deck. Vehicles can exit the Site via another ramp in the south of the Site exiting onto Molesworth Street. Ground level pedestrian access can be found from Rennell Street in the north of Site and from Lewisham High Street in the north west. Pedestrian access is also found from the centre with east and west access routes from Lewisham High Street and Molesworth Road. The
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Detail
Comment southernmost pedestrian access points were via Engate Street and Molesworth Street.
National Grid Reference (NGR)
538222, 175531
Site Description and Current Use
The Site currently comprises the Shopping Centre, which includes a range of retail units, a multi-storey car park, the 18-storey vacant former office building - Lewisham House, the vacant leisure box and Riverdale Hall, as well as commercial properties on the High Street. The ground floor shopping centre has several access points around the perimeter of the Site which feed into a main central shopping mall which extends north to south. The shopping centre is occupied by a range of retail and food outlets. The shopping mall area is paved, and no areas of landscaping were noted. The Site has associated utilities rooms and plant rooms which are split between the upper deck and ground floor. The upper deck has three air conditioning pump rooms, and the ground floor has two decommissioned ASTs, a generator room, electricity switchboard rooms and an electricity transformer room. External in the north of the Site running north to south from Rennell Street is a vehicle ramp leading to the upper deck. Beneath the ramp is an oil tank room. Also adjacent to the ramp to the east is an additional generator room associated with the former Citi Bank unit. The upper service deck gives vehicular and site staff access to service ports for each unit. This upper deck hardstanding was of concrete and asphalt and appeared to be in good condition.
Area
The Site is an elongated irregular in shape which trends north to south and is approximately 6.93 hectares (Ha) in area.
Site Setting and Surrounding Area
The Site is bound to the west and south by Molesworth St, the east by Lewisham High St and the north by Rennell Street (A20). West of Molesworth St is the railway line and Ravensbourne River as well as a mix of green space, residential and commercial buildings. The London Underground DLR and Lewisham railway line are located, respectively, approximately 170m and 240m north of the Site. North east of the Site is a Police Station, east of Lewisham High St which is then followed by shops and commercial premises running south beyond the southern tip of the Site.
Topography and Ground Cover
The Site is generally flat with hardstanding covering the entirety of the Site. No significant level changes were noted on Site, however some of the access routes did slightly slope towards Molesworth Street.
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Detail
Comment Surrounding the shopping centre are block paved public footpaths with occasional planted trees.
Asbestos
Lewisham Shopping Centre was constructed prior to 1999, and as detailed within the asbestos register, asbestos is present within multiple locations throughout the building. The presence of asbestos containing materials within the soil underlying the Site also cannot be discounted due to the historical redevelopment.
Bulk Storage of Chemicals / Fuels
During the Site visit three above ground storage tanks (ASTs) were observed, one was on the upper service deck and the other two were present within the ground floor plant rooms in the northern end of the Site. In addition, occasional discarded small (25L) plastic oil canisters and a 45-gallon oil drum were recorded. Locations of the potential contamination sources on Site can be found outlined within Figures 3a and 3b presented within Appendix A of the PRA (Appendix 10.1). On the upper deck adjacent to Plant Room 3 was a plastic AST with a 2,375 litre capacity containing gas oil. The AST was surrounded by poorly constructed bunding and had a mild smell of hydrocarbons emitting from the tank. No spillages were noted and the tank condition was good. A cage next to Plant Room 3 also had a small 20 L container of oil used for petrol engine equipment. Other discarded containers of engine oil were found scattered around the upper service deck. On the ground floor in the areas behind Units 41-46 located along ‘Borough Mall’ in the north east section of the site are various plant rooms which are accessed via service corridors. Above the entrance to this area via the ‘Bor Office’ see Figure 3a is a small overhead decommissioned oil storage tank in good condition, showing no signs of leakages. A generator room is present behind Units 41/43 on the ground floor. Within the generator room is an oil powered generator which was said to be in use by the site contact, this was seen to have leaked oil beneath. Sand and spill kit sheets had been used to control the extent of the spill. The generator was sat upon concrete which was generally in good condition. Also, within the generator room was a small adjoining room which had a 45-gallon gas oil drum, with no leaks observed. Across the corridor from the generator room was a tank room which ran north to south behind Units 41, 43 and 45. Within this tank room was a very large tank which occupied most of the space of the room, associated with the tank was pipework in the northern end of the room. The tank is said to have been decommissioned, and no odours were noted in the room. The tank room had small bunding by the entrance and was standing upon stilts which in turn rested upon hardstanding. This was in good condition. In the outside area behind Unit 41 was a further generator room which had been housed in a brick structure added onto the site presumably at a later date. In addition to this, underneath the vehicle access ramp in the north west corner of Site is a tank room and a battery room. Access to these was not
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Detail
Comment granted during the Site walkover. The battery room, generator room and tank room were previously used by the Citibank. On the upper deck there were large recycling bins and commercial waste bins placed sporadically on the eastern corridor running north to south. In the central part of the upper deck there was a cardboard compactor.
Waste Storage
No significant waste storage was observed on Site and no fly tipped material was seen. Invasive Species
No invasive species were observed during the walkover.
Electrical Features
An electricity transformer (11,000 V) was present within the plant area in the north west area of Site behind Unit 43. There were also two electricity substation rooms operated by UKPN present beneath the northern vehicle access ramp. These were located from the western side of said ramp on Molesworth Street.
Historical Maps 10.6.3 Historical maps were obtained as part of the Groundsure report (Appendix E of the PRA (Appendix 10.1)) and were reviewed to identify potentially contaminative former uses on Site and within a 500 m radius of the Site boundary. 10.6.4 A summary of on-Site and off-Site features relevant to contaminative land are presented in Table 10.6. Table 10.6 – Summary of the History of the Site and Surrounding Area Historical Map (Scale and Date)
On-Site Feature(s)
Off-Site Feature(s)
1863 (1:10,560) 1864 – 1865 (1:2,500) 1870 – 1872 (1:2,500) 1872 (1:10,560) 1882 (1:10,560)
The Site is made up of multiple land uses. With residential properties and a chapel making up most of the central south and north of Site. Woodland and an orchard are present in the central north section of Site. Various larger buildings, with potentially industrial uses, are present in the north and south of the Site. A pump is labelled to the north of the residential houses.
Lewisham Road runs from north to south directly to the east of the Site. Molesworth street lies directly to the west of Site in the north. Railway sidings within an embankment run from north to south adjacent to the west of the Site. Corn mills are situated 40 m to the south west and 105 m to the north west of Site. The mill in the south has an associated mill pond which runs from an unnamed river to the west of Site. Additional sidings within an embankment run from west to east, 140 m to the south west of Site. A brewery is located 240 m to the North of Site.
The Site is dissected by Avenue Road, with John’s Terrace running from it. Rennel Street runs west to east across the northern boundary of the Site while Molesworth Street runs north to south along the western boundary of the Site until
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Historical Map (Scale and Date)
On-Site Feature(s)
Off-Site Feature(s)
it reaches Avenue Road. Lewisham Road runs north to south along the north east boundary of the Site.
A train station connecting the south eastern railway to the Kent line is located 280 m to the north west of Site. A brick field is located 450 m to the west, with Loamhill Pottery at 500 m from Site. There is an unnamed river (in the location of the Ravensbourne River) approximately 50m to the west of Site (at its closest point). The river splits around residential properties and re-joins the original course.
1894 (1:10,560) 1896 (1:2,500) 1898 (1:10,560)
Additional residential properties are located in the north of Site. Several of the larger buildings in the south are no longer present, however an additional large building has been constructed in the south. A building crossing the Site boundary in the south is now labelled as River Dale. The orchard and woodland are no longer present, with various unspecified buildings being constructed in the similar area. John’s Terrace is now labelled as Engate Street, with Romer Place running from it. Quaggy River is shown to be present across the north east of the Site.
Residential development has occurred in the general area. The road directly to the east of Site, is now called Lewisham High Street and a tramway extends along it. The Corn Mill in the south is renamed Riverdale mill. The Corn Mill in the north has increased in size. The Board of Works depot is located approximately 100 m to the west. The river to the west of site, is split around residential properties and re-joins the original course via a weir located 150 m from Site. The train station is now labelled as Lewisham Junction. A silk mill is situated 480 m to the north west. A weir is present approximately 150 m west of the Site associated with the Ravensbourne River.
1916 (1:2,500) 1920 (1:10,560)
Further residential development has occurred in the north of Site. A garage and sorting office are now located in the central north and east of Site.
1938 (1:10,560)
Rhyme Road now runs from Avenue Road to the north and curves round to exit Site in the west, joining Molesworth Street.
Further residential development has occurred in the general area. A timber yard is located 95 m to the north west of Site. The Board of Works depot is now labelled as the Borough Council depot, with tanks and a chimney located 90 m and 110 m west, respectively. 200 m to the west of Site lies a miniature rifle range. A laundry is located 350 m to the east of Site. The silk mill is no longer labelled.
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Historical Map (Scale and Date)
On-Site Feature(s)
Off-Site Feature(s)
1948 (1:10,560) 1949 (1:2,500) 1949 (1:1,250)
An electricity substation is located in the north east. The garage is no longer labelled. A laundry is located off Rhyme Road in the centre of the Site. A citadel is located in the southern central area of Site. Lewisham model market is located in the south of Site
Riverdale Mill has increased in size. The river to the west of Site is now labelled as Ravensbourne river. An electricity substation is located 60 m to the east of Site. The timber yard is no longer present. The Borough Council depot has increased in size and changed configuration. The tanks are no longer labelled but seem to still be present. An electrical works is located approximately 190 m to the north west. A laundry is located 260 m to the north west of Site. An electricity substation is located 260 m to the north, associated with Anchor brewery 280 m to the north.
Avenue Road is now called Romer Avenue. A bank is located on the eastern boundary within the north of Site. River Dale in the south is now labelled as the Palace Social Club. Multiple residential properties in the south on the eastern boundary, have been replaced with a large unspecified building. Several of the buildings located on the Site are labelled as ‘ruins’. 1955 (1:10,560) 1955 – 1959 (1:1,250)
The electricity substation is no longer present. An unspecified works is located within the north of Site.
Commercial properties are constructed directly to the east of Site adjacent to Lewisham High Street. An unspecified works is located 110 m to the east and 125 m to the north west.
1959 (1:1,250)
A builder’s yard and a garage are located 160 m and 210 m to the north of Site, respectively. The breweries to the north west and north are labelled as bottling stores.
1963 (1:1,250) 1967 – 1968 (1:10,560) 1968 – 1970 (1:1,250) 1969 – 1974 (1:1,250)
The social club in the south is no longer present. Electricity substations are present in the north and the south of the Site. Multiple residential properties are presumed demolished in the north of Site. Molesworth street directly to the west of site is extended to the south connecting to Romer Avenue. Romer Place is extended to the south of Site, then changes to Engate Street where it links up with Romer Avenue.
Further commercial properties are constructed directly to the east of Site on Lewisham High Street. Electricity substations are present 40 m to the west, 110 m and 200 m to the south, 240 m to the north and, 50 m and 120 m to the north west. The Riverdale mill is now labelled as a bakery, with a tank located at 50 m to the west of Site. An unspecified works is located 110 m to the south west. An unspecified depot is located 175 m to the south west with an associated tank.
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Historical Map (Scale and Date)
On-Site Feature(s)
Off-Site Feature(s)
The laundry to the north west is now labelled as an engineering works. 1973 – 1974 (1:10,560)
The Site changes in configuration and is almost completely demolished, apart from buildings on the east of Site running along Lewisham High Street.
Ravensbourne river to the west of Site changes configuration, with the properties in the surrounding area no longer shown on mapping and assumed to have been demolished. The silk mill to the north west is now labelled as an unspecified mill.
1979 (1:10,560) 1982 (1:1,250) 1982 – 1986 (1:1,250) 1985 – 1989 (1:10,560) 1989 – 1991 (1:1,250)
The Lewisham Centre is built, which completely covers the Site. The centre has a multi-storey car park. A market area is located in the south. With Lewisham house and Riverdale Hall in the north. The electricity substation in the north is no longer present. Molesworth Street has been extended to the south to run alongside the western Site boundary.
The bakery is demolished and replaced by “The Riverdale” with associated pond. An unspecified works is located 90 m to the east of Site. An electricity substation is located 100 m to the east of Site. 180 m to the north east lies a coal yard. The garage 210 m north of the Site has been replaced by a petrol station. A fire station is located 300 m to the south of Site. The unspecified mill to the north west is now labelled as unspecified works.
1991 (1:1,250) 1992 – 1994 (1:1,250) 1994 (1:1,250)
No significant changes have occurred.
A roundabout is constructed adjacent to the south of Site, connecting Molesworth Street to the High Street. A roundabout is constructed to the north of Site from 60 m, replacing roads and residential properties, connecting to Molesworth Street.
1994 (1:10,000)
The bottling stores to the north is no longer present. 2001 (1:10,000)
No significant changes have occurred.
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Further residential development occurred to the west of Site.
has
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Historical Map (Scale and Date)
On-Site Feature(s)
Off-Site Feature(s)
A police headquarters is located adjacent to the north east of Site.
2003 (1:1,250) 2010 (1:10,000)
The market is no longer labelled in the south of Site.
The unspecified works to the north west is no longer present.
2021 (1:10,000)
A post office is labelled in the central north of Site.
A sports leisure centre has been constructed approximately 50 m to the north west of Site, associated with an education facility. Two petrol stations are located 428 and 461 m north west of Site.
2021 (Aerial Photos)
Published Geology 10.6.5 The British Geological Survey (BGS) Map No. 270 (South London, 1: 50,000 series) (Ref 1.33) indicates the geology within the study area to comprise superficial deposits of Kempton Park Gravels. Alluvial deposits encroach into the far north and west of Site associated with Ravensbourne River. The bedrock geology comprises Thanet Formation underlain by the Chalk Group. 10.6.6 Given the Site location and development history, man-made soils (Made Ground) are expected near the surface across the Site. These soils are likely to exhibit a certain degree of heterogeneity. The nature of the material can be expected to vary substantially in both composition and thickness over short distances. Buried obstructions from the former structures occupying the Site are also anticipated. 10.6.7 BGS historical exploratory boreholes on Site were reviewed. The sequence of the geological strata encountered in six on-site boreholes (TQ37NE946, TQ37NE942, TQ37NE1935, TQ37NE944, TQ37NE1936 and TQ37NE945) are set out in Table 10.7. The BGS borehole logs for the summary below is provided in Appendix F of the PRA (Appendix 10.1). Table 10.7 – BGS Borehole Ground Profile with Material Description Strata
Depth Encountered (m bgl)
Thickness (m)
Strata Description
Made Ground / Topsoil
0.00
0.68 – 1.98
Rubble, bricks, mortar and soil / Tarmac / Concrete / Topsoil and stones
Kempton Park Gravel
0.68 – 1.98
0.45 – 6.24
Brown and black gravel and pebbles and some stones / Gravel and pebbles with some sand & some clay / Gravel and sand / Gravel and sandstone
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Strata
Depth Encountered (m bgl)
Thickness (m)
Strata Description
Thanet Formation
2.43 – 7.31
2.66* – 9.75*
Fine grey sand / Fine grey sand with some gravel / Grey/brown sand
Chalk
9.75
2.43*
Sand, gravel, flints and chalk
* Unit not proven
Hydrogeology 10.6.8 The superficial deposits of Alluvium and Kempton Park Gravels are classified by the Environment Agency (EA) as a Secondary A Aquifers. The superficial deposits were underlaid by the Secondary A Aquifers of the Thanet Sand. The underlying Chalk Group is classified as a Principal Aquifer. 10.6.9 There are no groundwater abstractions recorded within 500 m. The closest license is 870 m north west of the Site at Deptford Pumping Station by Thames Water Utilities Ltd for direct potable water supply. 10.6.10 The Site is located within a Groundwater Source Protection Zone (SPZ) one, inner catchment for public water supply. Hydrology 10.6.11 There are no surface water abstraction points within 500 m of the Site. The closest is a historical abstraction located 951 m north west of Site, located at Brooksmill Park abstracted from the Ravensbourne River and served as make-up or top-up water. 10.6.12 The nearest surface water feature to the Site is the Quaggy River, located on the north east boundary of the Site. The Ravensbourne River is located 50 m to the west of Site. The River Thames is located 2.25 km to the north of Site. 10.6.13 The UK Government’s Long-Term Flood Risk website (Ref 1.34) shows large areas of localised flooding with a high (1 in a 30-year possibility) chance of flooding from surface water. The majority of the Site is also considered to have a moderate risk of groundwater flooding. 10.6.14 The Site is considered a medium risk (less than 1 in 30 but greater than or equal to 1 in 100 possibility) of flooding from rivers and the sea. The EA’s ‘flood map for planning’ (Ref 1.35) indicates that the Site is located partly within Flood Zone 3; “a river flood with a 1% chance of happening each year, or a flood from the sea with a 0.5% chance of happening each year”. A small section in the south west is located within Flood Zone 2.
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Future Climate Change Under a RCP8.5 Scenario Sea Level Rise / Flood Risk 10.6.15 The Quaggy River and Ravensbourne River are located adjacent in the north east of the Site and 50 m west of the Site, respectively. In addition, the River Thames is located 2.25 km north of the Site. The Site is located at an elevation of approximately 12 m AOD. Under RCP8.5 sea level along the coast in proximity to the Site is projected to rise by 1.15 m by 2100 which could bring the River Thames to 1.8 km from the Site during spring tides of storm surges. However, it should be noted that this is a conservative estimate as London benefits from the Thames Barrier, which may act to mitigate the effect of spring tides or storm surges. Based on the project distance of the River Thames from the Site, it is not considered that the Site will be significantly impacted due to rising sea levels. 10.6.16 The Site is currently partly located in Flood Zone 2 and 3, however it should be noted that climate change may result in changes to the frequency of extreme weather events and associated flooding. Projected Changes to Groundwater Level 10.6.17 The Site is located within the Greenwich Tertiaries and Chalk Groundwater Body and the eFLaG project far-future (2050-2079) projections for groundwater recharge projects a 0.0 mm/day change to groundwater recharge for all seasons. It should be noted that the eFLaG project only provides information on groundwater recharge in bedrock aquifers. Future changes to the frequency and intensity of rainfall events could influence superficial aquifer recharge, and therefore groundwater levels within the vicinity of the Site. Ground Stability 10.6.18 The ground stability hazards summarised in Table 10.8 were outlined as part of the Groundsure Report (ultimately sourced from the BGS). Table 10.8 – Summary of Ground Stability Hazards Hazard
Potential
Potential for Collapsible Ground
Negligible to Very Low
Compressible Ground Stability
Negligible to Moderate
Ground Dissolution
Low
Landslide
Very Low
Running Sands
Very Low to Low
Shrinking or Swelling of Clay
Negligible to Very Low
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Radon 10.6.19 According to UK Health Security Agency (UKHSA) (Ref 1.36), the Site is in an area where 1 and 3 % of homes are estimated to be at or above the Action Level. Monitoring may be required to determine whether radon protection measures are required. Unexploded Ordnance (UXO) 10.6.20 A review of Zetica online bomb mapping (Ref 1.37) indicates that there is a high risk from UXO. It also indicates there was a Luftwaffe target located approximately 1 km north west. The map is included as Appendix H of the PRA (Appendix 10.1). 10.6.21 A detailed UXO assessment was completed as part of the ground investigations completed and is presented in Appendix 10.2. The detailed assessment confirmed the high risk given extensive bombing and bomb damage of the Site and surrounding area. The assessment recommended UXO engineer watching briefs, intrusive magnetometer surveys and UXO response plans are employed during intrusive works. Previous Ground Investigations 10.6.22 A ground investigation was completed at the Site in 2022 which was subsequently reported in two phases: Phase 1 in the east, and Phase 2 in the north (Ref 1.38). It is noted that the western and southern portions of the Site were not investigated due to access restrictions. 10.6.23 The investigation comprised ten cable percussive boreholes to a maximum depth of 19 meters below ground level (m bgl), one rotary borehole to 50m bgl, six trial pits to a maximum depth of 1.7m bgl, and 22 windowless sampling boreholes to a maximum depth of 6m bgl. Selected exploratory holes were installed with groundwater and gas monitoring standpipes. 10.6.24
Encountered ground conditions are presented in Table 10.9.
Table 10.9 – Summary of Geology Encountered in 2022 Ground Investigation Stratum
Depth to Top of Stratum (m bgl)
Depth to Base of Stratum (m bgl)
Thickness (m)
Typical Description
Surfacing
0.00
0.05 - >1.90
0.05 – 0.66
Concrete / Asphalt / Brick Block Paving Reinforced Concrete / Tile & Wooden Flooring
Made Ground
0.05 – 0.41
1.50 – 3.80
1.35 – 3.40
Highly variable, but predominantly granular with inclusions of brick, concrete, flint, ash, clinker, charcoal, mortar, sandstone, porcelain, breeze blocks, wood fragments, quartz, quartzite, chalk, limestone, pottery, slate, plastic and metal.
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Stratum
Depth to Top of Stratum (m bgl)
Depth to Base of Stratum (m bgl)
Thickness (m)
Typical Description
Cohesive deposits encountered generally comprised clay with varying granular inclusions. Alluvium
1.70 – 3.30
2.80 – 3.80
0.50 – 1.60
Cohesive deposits generally of gravelly, sandy, silty, organic clay.
Kempton Park Gravel Member
1.50 – 3.80
3.10 – 8.50
0.60 – 6.50
Granular deposits in varying proportions with inclusions of flint, quartz and quartzite. Some inclusions of silt and clay.
Thanet Formation
2.80 – 8.50
12.00 – 16.70
6.00 – 12.20
Grey silty fine sand with occasional inclusions of clay and gravel of flint.
Bullhead Beds
12.60 – 14.90
12.80 – 15.70
0.20 – 0.80
Granular of clayey silty gravelly sand or sandy gravel of flint.
Chalk Group
12.00 – 16.70
Unproven
Unproven
Recovered as structureless chalk composed of either gravelly silt or silty gravel. Inclusions of flint and brown clay
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10.6.25 A faint hydrocarbon odour was noted between 0.25 – 0.45m bgl within RH1 (located in the northwest of the Site). 10.6.26 Groundwater strikes were not noted during the intrusive investigation. Subsequent monitoring of installations within the Kempton Park Gravels did not identify groundwater within the unit during any of the monitoring rounds. Groundwater levels within installations within the Thanet Formation and Chalk Group identified groundwater levels between 6.90m and 10.33m below ground level (m bgl) (between 2.49 meters above ordnance datum (m AOD) and -1.39m AOD). Groundwater levels within the Chalk group were observed to be similar to those measured in the Thanet Formation, therefore the groundwater within the units was considered likely to be in hydraulic continuity. 10.6.27 Thirty-one soil samples were submitted for chemical analysis, which included asbestos screen, metals, total petroleum hydrocarbons (TPH), polychlorinated biphenyls (PCBs), benzene, toluene, ethylbenzene and xylenes (BTEX), inorganics, volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOC). 10.6.28 In addition, sixteen soil samples were submitted for leachate analysis for a similar chemical testing suite as above. 10.6.29 Soil samples were screened against Generic Assessment Criteria (GAC) and Category 4 Screening Levels (C4SL) assuming a residential without plant uptake land use. Exceedances of the criteria were encountered with respect to lead, benzo(a)pyrene, naphthalene, TPH and 1,2,4 -trimethylbenzene. In addition, asbestos was positively identified within five soil samples as chrysotile cement and amosite board. 10.6.30 Soil leachate results were screened against Drinking Water Standards (DWS) which are protective of aquifers. Exceedances of DWS criteria were encountered with respect to arsenic, nickel and TPH. 10.6.31 As groundwater was not encountered within the install boreholes, groundwater samples could not be retrieved for chemical analysis. 10.6.32 Ground gas monitoring was undertaken at installed boreholes on nine occasions. Based on the results and the observed Site conditions, a Characteristic Situation 1 (CS1) classification was considered to be appropriate for the Site.
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Hydrogeological Model 10.6.33 Made Ground has been identified as being present on the Site as a result of the previous uses. Groundwater may be present at perched isolated pockets associated with permeable lenses within the Made Ground that are recharged by surface water infiltration. 10.6.34 Groundwater has been identified to be present within the Thanet Formation. No groundwater has been encountered within the overlying Alluvium or Kempton Park Gravel Member, although they are considered likely to be in hydraulic continuity. In addition, groundwater within the Thanet Formation is considered to be in hydraulic continuity with the underlying permeable geology (Bullhead Beds and Chalk). 10.6.35 The Quaggy and Ravensbourne rivers are anticipated to be lined within the vicinity of the Site and therefore hydraulically isolated from groundwater underlying the Site. Based on the groundwater conditions, groundwater within the Thanet Formation is considered to flow broadly towards the south west / west, towards the Ravensbourne River. However, given the distance, any contaminants are likely to undergo natural attenuation prior to reaching the river. The river is also anticipated to be fully lined.
10.7 Future Baseline 10.7.1 This section outlines the future baseline conditions of the Site. 10.7.2 In the absence of the Proposed Development, it is likely that the Site conditions will remain as they are reported within this Chapter, no significant change to the current baseline would be predicted. Any potentially polluting activities that are currently occurring would be likely to continue, however the identified contamination sources are historical, off-site or inactive, so there should be a low increment of increased contamination levels on-site. However, assuming no remediation takes place it is possible that the concentration and accumulation of contaminants could occur, which will increase the effect to receptors.
10.8 Sensitive Receptors 10.8.1 The following are the sensitive receptors which will be considered in the following assessment: Human Health • •
Demolition and Construction workers (High sensitivity); and, Adjacent Site users (including residents and workers) and Future Site Users (of earlier phases of the development) (Very High sensitivity).
Controlled Waters • • •
Groundwater within the Secondary A Aquifers within the Alluvium, Kempton Park Gravel Member and Thanet Formation (High sensitivity); Groundwater within the Principal aquifer within the Chalk Group (Very High sensitivity); and, Surface waters within the Quaggy River and Ravensbourne River (High sensitivity).
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10.9 Assessment of Effects, Mitigation and Residual Effects Demolition & Construction Phase 10.9.1 This section identifies and assesses the scale and nature of the main effects arising from the Proposed Development during the construction phase. Potential Effect on Demolition and Construction Workers 10.9.2 Potential sources of contamination have been identified on the Site in the PRA (Appendix 10.1) which include electricity substations and a transformer, various tanks, oil powered generators and historical land uses including a garage, works and laundry. Previous ground investigations undertaken at the Site have identified hydrocarbon odours within Made Ground deposits in the northwest of the Site. Elevated concentrations of metals, PAH and TPH have been identified within soil samples. Soil leachate results have also indicated elevated concentrations of metals and TPH above DWS criteria. 10.9.3 Demolition and construction workers could be exposed to contaminants that are present in the Made Ground, or that are present in the ground after migrating from the identified contaminant sources, during any earthworks or piling activities that include disturbing or clearing the Made Ground. There is the potential for exposure to asbestos or other contaminants during the disturbance of Made Ground. Demolition and construction workers may be affected by the inhalation of dusts, gases or vapours, dermal contact with soils or groundwater; and the ingestion of soil or dust. However, the length of exposure would be limited to the duration of the site works in which the workers are directly involved, and thus the effect would be short-term. Any health effects from potentially contaminated soils and groundwater could have a medium to long-term effect. 10.9.4 In addition, demolition and construction workers could be exposed to unexploded ordnance (UXO) during ground investigations, demolition, excavation, or piling activities. If a device was activated, it could have both short- and long-term, as well as temporary and permanent effects. The UXO assessment identified the Site as being located within an area with a High risk from UXO. 10.9.5 The sensitivity of demolition construction workers is considered to be high, and the magnitude of impact, prior to mitigation is major. Therefore, there is likely to be a direct, permanent, medium to long-term major negative effect (significant) on construction workers prior to the implementation of mitigation measures.
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Mitigation 10.9.6 Further ground investigation would be undertaken at the Site, targeting areas not previously investigated, to confirm the ground conditions and the presence of contamination and allow an assessment of potential contaminant linkages in line with LCRM guidance in line with the detailed design, which will be secured by way of planning conditions. 10.9.7 Should the ground investigation identify unacceptable contaminant linkages, a Remediation Options Appraisal and Remediation Strategy would be produced to specify protective measures for the construction stage of the Proposed Development. The Remediation Options Appraisal would consider the available options for each identified unacceptable contaminant linkage and would establish the most effective and sustainable approach. The Remediation Strategy would set out measures to break the identified unacceptable contaminant linkages. The measures could include the removal of contaminated soil or the placement of a barrier between the contaminant source and the receptor, amongst others. In addition, the Remediation Strategy would include any ongoing maintenance requirements of remedial measures (if identified as being required) which would be discussed through consultation with the Local Authority and Environment Agency. These works are also anticipated to be secured by way of planning conditions. 10.9.8 In the event that a Remediation Strategy is required, validation of remedial measures would be required, and would be reported in a Verification Report. 10.9.9 It has been assumed that the following good practice measures would be adhered to during the demolition and the subsequent construction phases. These measures are proposed as part of the Construction Environmental Management Plan (CEMP) to be prepared and implemented by the Principal Contractor. • • • • • • • • • • •
Use of appropriate Personal Protective Equipment at all times during the construction works; Provision of adequate hygiene facilities for washing and changing; Excavated soils would be appropriately managed; Implementation of an appropriate temporary drainage system would be required in order to minimise the potential risks of contamination or excess sediment reaching drains or surface water receptors; Any contaminated material encountered on-site, the handling, storage and removal would be subject to current waste management legislation and guidance; The presence of contaminants and the associated risks would be explained to ground workers before they begin work; Fuel storage on-site to be carried out under best practice i.e. integrally bunded containers; Plant refuelling to be carried out using best practice techniques and any spills to be controlled with spill kit; Dust suppression measures (e.g. damping down) would be implemented to minimise the potential for dust generation; Wheel washing of Site vehicles would be carried out in order to minimise the potential for dust generation; and Appropriate covering of on-site stockpiled materials and during transport to/from the Site to prevent dust generation.
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10.9.10 A specialist Detailed Unexploded Ordnance Threat Assessment (Appendix 10.2) recommended mitigation measures (including UXO engineer watching briefs, intrusive magnetometer surveys and UXO response plans) which will be employed during intrusive works. Residual Effect 10.9.1 The sensitivity of construction workers is high, and the magnitude of impact, following implementation of mitigation measures is negligible. Therefore, there is likely to be a direct, permanent, medium to long term negligible residual effect (not significant) on construction workers. Potential Effect on Adjacent Site Users and Future Site Users 10.9.2 As discussed in the sections above, potential sources of contamination have been identified within the PRA report (Appendix 10.1) and previous ground investigations. Excavation of potentially contaminated soils could pose a health risk to the general public (including residents and workers) in the immediate vicinity of the Site, as well as future site users (within earlier completed phases of the development). There is the potential for the inhalation of contaminated dusts and particulate matter generated by excavation, piling activities or site clearance that includes disturbing or clearing the Made Ground. In addition, potential UXO could also pose a human health risk to the public within the vicinity of the Site and future Site users (during the phased development). 10.9.3 The potential risk to adjacent site users (including workers, residents, commuters, members of the public surrounding the Proposed Development) would be dependent on the type and nature of contamination, which will be confirmed during future ground investigations, and the characteristics of receptor and duration of exposure. If these receptors are exposed to contaminants above threshold concentrations, there is potential for both temporary and permanent health problems to arise. Exposure may be direct or indirect. 10.9.4 In addition, adjacent site users and future site users (within earlier phases of the development) could be exposed to UXO during ground investigations, excavation or piling activities. If a device was activated it could have both short- and long-term as well as temporary and permanent effects. 10.9.5 The sensitivity of adjacent site users and future site users (within earlier phases of the development) is considered to be very high, and the magnitude of change, prior to mitigation is major. Therefore, there is likely to be a direct, permanent, medium to long-term major negative effect (significant) on adjacent site users prior to the implementation of mitigation measures.
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Mitigation 10.9.6 As discussed above, further ground investigations and assessment of potential contaminant linkages will be completed at the Site, targeting areas which have not previously been investigated, which will be secured by way of planning conditions. Should the ground investigations identify unacceptable contaminant linkages with pose a risk to identified sensitive receptors, a Remediation Options Appraisal, Remediation Strategy and subsequent Verification Report would be produced. These would be secured by way of planning conditions. 10.9.7 In addition, during construction, the risks to adjacent site users should be managed via CEMP, as outlined above. 10.9.8 A specialist Detailed Unexploded Ordnance Threat Assessment (Appendix 10.2) recommended mitigation measures (including UXO engineer watching briefs, intrusive magnetometer surveys and UXO response plans) which will be employed during intrusive works. Residual Effect 10.9.9 The sensitivity of adjacent site users is very high, and the magnitude of impact, following mitigation, is negligible. Therefore, there is likely to be a direct, temporary, medium to longterm negligible residual effect (not significant) on adjacent site users and future Site users. Potential Effect on Controlled Waters 10.9.10 Removal of surface cover (e.g. hardstanding) has the potential to increase the rate of infiltration of rainfall and therefore increase leaching of contaminants from shallow soils. 10.9.11 Piled foundations are likely to be utilised as part of the Proposed Development. Due to the depth and diameter of piles there is the potential for the generation of preferential contaminant pathways which could degrade the quality of controlled waters through the introduction of the piles to the Secondary A Aquifers (within the Alluvium, Kempton Park Gravel Member, Thanet Formation) and Principal Aquifer (within the Chalk Group). 10.9.12 The use of machinery and plant associated with demolition and construction activities (including the establishment of the construction compounds and storage of chemicals or fuels) could give rise to localised contamination that may represent a risk to groundwater through accidental fuel / oil and chemical spills and leaks. There could also be a risk of contaminated runoff, including hydrocarbon contamination, associated with the operation of vehicles. There is the potential for contaminants to be mobilised which could migrate to nearby surface water receptors (Quaggy River and River Ravensbourne). 10.9.13 The sensitivity of controlled waters is considered to be high to very high, and the magnitude of impact, prior to mitigation is major. Therefore, there is likely to be a direct, temporary, long-term major negative effect (significant) on controlled waters prior to the implementation of mitigation measures.
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Mitigation 10.9.14 As discussed above, further ground investigations and assessment of potential contaminant linkages will be completed at the Site, which will be secured by way of planning conditions. Should the ground investigations identify contaminant linkages, a Remediation Options Appraisal, Remediation Strategy and subsequent Verification Reporting would be produced. These would be secured by way of planning conditions. 10.9.15 In addition, during construction, the risks to controlled waters receptors should be managed via a CEMP, as outlined above. 10.9.16 A Piling Risk Assessment should be carried out prior to the works to assess the risks to the aquifers underling the Site and give recommendations to protect of controlled waters, which should be incorporated into the construction method statement. Residual Effect 10.9.17 The sensitivity of controlled waters is high to very high, and the magnitude of impact, following mitigation, is negligible. Therefore, there is likely to be a direct, temporary, long-term negligible residual effect (not significant) on controlled waters. Operational Phase 10.9.18 The operational phases of the Proposed Development have been scoped out of the assessment. In-combination Climate Impact Assessment 10.9.19 Anticipated changes due to climate change are presented in Section 10.6, and indicates that the Site is not anticipated to be significantly impacted by rising sea levels by 2100. The Site is noted to be located within the Greenwich Tertiaries and Chalk Groundwater catchment, which is not anticipated to have significant changes in groundwater recharge based on far-future projections (2050-2079). However, it is noted that there is not information available for superficial aquifers underlying the Site. 10.9.20 Potential future increases in precipitation could affect shallow groundwater (and consequently surface water) quality (controlled waters receptors) as potential contaminants currently in the unsaturated zone could be mobilised to groundwater should levels rise. 10.9.21 Mitigation measures outlined within this chapter include a ground investigation, which will include groundwater monitoring to provide an understanding of seasonal variability in groundwater levels and risk assessment. No further mitigation is considered to be required and potential effects are negligible.
10.10 Limitation and Assumptions 10.10.1 To ensure transparency within the EIA process, the following limitations and assumptions have been identified: •
The work undertaken to provide the basis of this assessment comprised a study of available documented information from a variety of sources and discussions with relevant authorities and other interested parties.
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• •
•
Any risks identified in this Chapter are perceived risks based on the information reviewed. Actual risks can only be assessed following further surveys and intrusive investigation at the Site. Ground investigations have been completed in the north and east of the Site. However, the south and west of the Site have not been investigated due to access constraints. It is anticipated that further ground investigation will be completed postdetermination, targeting previously uninvestigated parts of the Site. Although the works of third parties have been used to inform this Chapter, WSP cannot warrant the work of third parties.
10.11 Cumulative Effects 10.11.1 This section considers the likely cumulative effects that could arise from the Proposed Development when considered alongside other committed development schemes proximate to the Site. It identifies whether effects from several developments which individually may be insignificant could, when considered together, cause significant cumulative effects requiring mitigation. 10.11.2 A number of committed developments have been identified as being relevant to this assessment. These were identified through a review of LBL’s planning portal and have been agreed with LBL. 10.11.3 An assessment of cumulative effects for Ground Conditions and Contamination has been scoped out. There are not considered to be any significant cumulative effects on Ground Conditions and Contamination from the Proposed Development and other committed developments within the 500m and 1km study areas. A number of committed developments have been identified within the immediate vicinity of the Proposed Development, however, these are not considered likely to affect soil and groundwater contamination at the Site as it is considered that off-site soil and groundwater contamination will be identified under planning conditions for off-site committed developments and will be appropriately remediated in line with primary legislation and best practice. Therefore, no significant cumulative effects are anticipated associated with this phase of works in relation to Ground Conditions and Contamination.
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Table 10.10: Summary of Effects DESCRIPTION RECEPTOR SIGNIFICANCE OF EFFECTS OF SIGNIFICANT MAJOR / POSITIV P / D / I ST / EFFECTS MODERAT E / T MT / E / MINOR NEGATIV LT / E NEGLIGIBL E Demolition & Construction Effect of Demolition Major Negative P D MT / contamination and LT on Demolition Construction and Workers Construction Workers
SUMMARY OF MITIGATION / ENHANCEMENT MEASURES
Further Ground Negligible Investigation and Assessment Remediation Options Appraisal, Remediation Strategy and Verification Reporting Construction Environment Management Plan (CEMP) UXO engineer watching briefs, intrusive magnetometer surveys and UXO response plans outlined within the detailed UXO risk assessment (Appendix 10.2)
Negative P
D
MT / Defined in LT Section 1.2
Defined in Section 1.2
Effect of Adjacent Site Major contamination Users and on Adjacent Site Future Site Users and Users Future Site
Further Ground Investigation and Assessment Remediation Options Appraisal, Remediation
Negative P
D
MT / Defined in LT Section 1.2
Defined in Section 1.2
Negative P
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D
MT / LT
SIGNIFICANCE OF RESIDUAL RELEVANT RELEVANT EFFECTS POLICY LEGISLATIO N MAJOR / POSITIV P / D / I ST / MODERATE E / T MT / / MINOR / NEGATIV LT NEGLIGIBLE E
Negligible
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DESCRIPTION RECEPTOR SIGNIFICANCE OF EFFECTS OF SIGNIFICANT MAJOR / POSITIV P / D / I ST / EFFECTS MODERAT E / T MT / E / MINOR NEGATIV LT / E NEGLIGIBL E Users (within earlier completed phases of the development)
SUMMARY OF MITIGATION / ENHANCEMENT MEASURES
Effect of contamination on Controlled Waters receptors
Further Ground Negligible Investigation and Assessment Remediation Options Appraisal, Remediation Strategy and Verification Reporting Construction Environment Management Plan (CEMP) Piling Risk Assessment
Controlled Major Waters (Groundwate r underlying the Site and Surface Water features)
Negative T
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D
LT
SIGNIFICANCE OF RESIDUAL RELEVANT RELEVANT LEGISLATIO EFFECTS POLICY N MAJOR / POSITIV P / D / I ST / MODERATE E / T MT / / MINOR / NEGATIV LT NEGLIGIBLE E
Strategy and Verification Reporting Construction Environment Management Plan (CEMP) UXO engineer watching briefs, intrusive magnetometer surveys and UXO response plans outlined within the detailed UXO risk assessment (Appendix 10.2)
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Negative T
D
LT
Defined in Section 1.2
Defined in Section 1.2
11.0 References Ref 1.1 WSP, July 2024. Lewisham Shopping Centre – Geo-Environmental Preliminary Risk Assessment. Report Reference: LSC-WSP-XX-XX-AS-EN-000004. Ref 1.2 WSP, December 2022. Lewisham Shopping Centre – Phase 1 Generic Quantitative Risk Assessment. Report Reference: LSC-WSP-XX-XX-RP-GW-001. Ref 1.3 WSP, December 2022. Lewisham Shopping Centre – Phase 2 Generic Quantitative Risk Assessment. Report Reference: LSC-WSP-XX-XX-RP-GW-002. Ref 1.4 Ministry of Housing, Communities and Local Government, 2023. National Planning Policy Framework. Ref 1.5 Secretary of State, 1990. Environmental Protection Act. Ref 1.6 Secretary of State, 2012. The Contaminated Land (England) (Amendment) Regulations. Ref 1.7 Secretary of State, 2017. The Water Environment (Water Framework Directive) (England and Wales) Regulations. Ref 1.8 Secretary of State, 2006. Groundwater Directive (2006/118/EC). Ref 1.9 Health and Safety Executive, 2015. Construction (Design and Management) (CDM) Regulations. Ref 1.10 Secretary of State, 2021. Environment Act. Ref 1.11 Secretary of State, 2006. Dangerous Substances Directive 2006/11/EC. Ref 1.12 Secretary of State, 2012. Control of Asbestos Regulations. Ref 1.13 Secretary of State, 2006. Contaminated Land (England) Regulations. Ref 1.14 Secretary of State, 2015. Environmental Damage (Prevention and Remediation) Regulations. Ref 1.15 Secretary of State, 1991. Water Resources Act (England and Wales). Ref 1.16 Secretary of State, 2018. A Green Future: Our 25 Year Plan to improve the Environment. Ref 1.17 Greater London Authority, 2021. London Plan. Ref 1.18 Greater London Authority, 2014. Sustainable Design and Construction Supplementary Planning Guidance. Ref 1.19 London Borough of Lewisham, 2011. Core Strategy. Ref 1.20 London Borough of Lewisham, 2014. Development Management Local Plan. Ref 1.21 London Borough of Lewisham, 2014. Lewisham Town Centre Local Plan. Ref 1.22 London Borough of Lewisham, 2023. Draft Lewisham Local Plan (Regulation 19 stage). Ref 1.23 Department for Levelling Up, Housing and Communities, 2021. Planning Practice Guidance. Land Affected by Contamination. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 10: Ground Conditions
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Ref 1.24 Rudland, D. Lancefield, R. Mayell, P, 2001. CIRIA C552 Contaminated Land Risk Assessment: A guide to good practice. Ref 1.25 Construction Industry Research and Information Association, 2001. C532 Control of Water Pollution from Construction Sites: Guidance for Consultants and Contractors. Ref 1.26 Construction Industry Research and Information Association, 2014. C733 Asbestos in Soil and Made Ground: A Guide to Understanding and Managing Risks. Ref 1.27 Environment Agency, 2023. Land Contamination Risk Management (LCRM). Ref 1.28 Society of Brownfield Risk Assessment (SoBRA), 2022. Guidance on Assessing Risk to Controlled Waters from UK Land Contamination Under Conditions of Future Climate Change. Ref 1.29 Environment Agency, 2017. Groundwater Protection Technical Guidance. Ref 1.30 Design Manual for Roads and Bridges, 2019. LA109 Geology and Soils. Ref 1.31 Design Manual for Roads and Bridges, 2020. LA113 Road Drainage and the Water Environment. Ref 1.32 Design Manual for Roads and Bridges, 2020. LA104 Environment Assessment and Monitoring. Ref 1.33 British Geological Survey, 1998. Map No. 270 South London, 1: 50,000 series. Ref 1.34 GOV UK. The UK Government’s Long-Term Flood Risk website, accessed at https://www.gov.uk/check-long-term-flood-risk. Ref 1.35 GOV UK. Flood Map for Planning website, accessed at https://www.gov.uk/check-longterm-flood-risk. Ref 1.36 UK Health Security Agency. UK Maps of Radon website, accessed at https://www.ukradon.org/information/ukmaps. Ref 1.37 Zetica UXO. UXO Risk Maps, accessed at https://zeticauxo.com/guidance/risk-maps/. Ref 1.38 Ground Engineering Limited, 2022. Phases 1 and 2 Ground Investigation Report, Lewisham Shopping Centre, London, SE13 (Factual). Report Reference: C15522.
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11.0 Archaeology 11. 1 Introduction 11.1.1 This Chapter reports the likely significant effects of the Proposed Development on the Site and the surrounding area in terms of archaeological matters. Where appropriate, it also identifies proposed measures to prevent, minimise, control or offset likely negative effects arising from the Proposed Development and the subsequent anticipated residual effects. 11.1.2 The effects of the Proposed Development are considered over the demolition & construction phase. 11.1.3 The main archaeological issues covered in this Chapter include the following: • •
Likely significant effects of the Development on Archaeology (buried heritage assets); and Likely measures of mitigation.
11.1.4 This Chapter (and its associated figures and appendices) should be read together with the Introductory Chapters of this ES (Chapters 1 – 5), as well as Chapter 17: Effect Interactions. 11.1.5 This Chapter is accompanied by the following appendices: •
Appendix 11.1: Archaeological Desk Based Assessment.
Competence 11.2 This assessment has been undertaken by Paul Riggott, BA (Hons) Archaeology, MSc Archaeological Computing and a Member of the Chartered Institute for Archaeologists (CIfA). Paul has 13 years’ experience working in an archaeological setting, with 12 years’ experience preparing Archaeological Desk Based Assessments, Impact Assessments and EIAs.
11.3 Legislation, Planning Policy and Guidance 11.3.1 The following national, regional and local planning policy and guidance is of relevance to the assessment of the effects of the Proposed Development in relation to buried heritage assets.
Planning Policy Context National 11.3.2 The following national level policy and guidance documents are of relevance to the Proposed Development:
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National Planning Policy Framework (2023) 11.3.3 National Planning Policy Framework (NPPF, 2023). Section 16 of the NPPF, “Conserving and enhancing the historic environment” states how the significance of heritage assets (both statutorily designated, and non-designated), and the impacts of development proposals on their significance should be considered in the planning process. Planning Practice Guidance (NPPG) (2019) 11.3.4 The Department of Communities and Local Government (2014) Conserving and Enhancing the Historic Environment: Planning Practice Guidance (PPG) Regional London Plan 2021 11.3.5 Greater London Authority: London Plan (2021). Policy HC1 “Heritage conservation and growth” of the London Plan relates to London’s historic environment. Sustainable Design and Construction Supplementary Planning Guidance (2014) 11.3.6 Section 2.2.23 and 2.2.24 in the Sustainable Design and Construction SPG deals with Heritage Assets and Archaeology. Local London Borough of Lewisham Core Strategy (2011) 11.3.7 Policy 16 of the Lewisham Core Strategy (2011) covers the Historic Environment. other heritage assets and non-designated heritage assets. Development Management Local Plan (2014) 11.3.8 Policy 37 of the Development Management Local Plan (2014) covers non-designated heritage assets. 11.3.9 The relevant sections of the planning policies are provided in full in Appendix 11.1. Guidance 11.3.10 The Chartered Institute for Archaeologists (2020) Standards and guidance for historic environment desk-based assessment. 11.3.11 The Institute of Environmental Management and Assessment (2021) Principles of Cultural Heritage Impact Assessment in the UK. 11.3.12
Historic England (2019) Piling and Archaeology: Guidance and Good practice.
11.4 Consultation 11.4.1 As discussed in Chapter 2: Approach to Assessment, consideration has been given to the formal EIA Scoping Opinion provided by LBL and consultees and any additional consultation that may have occurred during the design period of the Proposed Development. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 11: Archaeology
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11.4.2 Consultation has been undertaken with Mark Stevenson, GLAAS, as shown in Table 11.1. Table 11.1: Consultation Feedback Consultee
Comment
Where is this addressed?
GLAAS
Agreed that there is no requirement for predetermination archaeological evaluation. Discussed during site visit of 29/04/2024
Impacts and Recommendations within Appendix 11.1
SI works need to be incorporated into DBA. Discussed during TEAMS call on 18/01/2024 Agreement on the size of the study area.
11.5 Assessment Methodology and Significance Criteria 11.5.1 The following section outlines the methodologies applied to identify and assess the potential impacts and likely effects to result from the Proposed Development. Scope of the Assessment 11.5.2 An EIA Scoping Report was issued to LBL in January 2024 (Appendix 2.1). LBL’s formal Scoping Opinion was issued in June 2024 (Appendix 2.2). 11.5.3 The following potential effects were scoped into the assessment: Likely Significant Effects Demolition and Construction Phase • • •
Groundworks during preliminary site set up, demolition and levelling. Piled foundations. Utilities trenches.
•
Landscaping.
Extent of The Study Area 11.5.4 Details of known historic environment finds and features within a study area extending 500m from the centre of the Site, were obtained from the primary repositories of such information within Greater London: the Greater London Historic Environment Record (GLHER); and the Museum of London Archaeological Archive (MoL Archaeological Archive); the locations of these are shown on Figure 2 within Appendix 11.1. This information provides archaeological and historical context and informs the baseline characterisation of the Site. The study area was discussed with the GLAAS as adviser on archaeological matters to the LBL and was agreed as appropriate and sufficient to reflect the likely archaeological character of the Site. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 11: Archaeology
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Method of Baseline Collection 11.5.5 The methodology and sources consulted to establish the baseline conditions are set out in detail in Appendix 11.1. In summary, this entailed:
• Collating information on known historic environment finds and features in the study •
area (and if appropriate beyond it), in order to set the Site into its archaeological and historic context; and Consultation of a broad range of relevant documentary and cartographic sources, including published histories and journals, British Geological Survey data, available geotechnical data and historic maps.
Method of Assessment Demolition & Construction Phase 11.5.6 Impacts on archaeological remains occur during the demolition and construction phase where ground disturbance takes place. They are limited to the area of the physical impact and are permanent. Such impacts and their resulting effects are assessed below. 11.5.7 The impact assessment has been undertaken in accordance with the standards specified by the Chartered Institute for Archaeologists (CIfA), and the Greater London Archaeological Advisory Service (GLAAS). The methodology used to determine the significance (i.e., sensitivity) of buried heritage assets (i.e., archaeological remains), the severity of any impacts upon them and the resulting significance of environmental effect is based on that typically used in EIA. Following the characterisation of the baseline conditions, the methodology used to characterise the potential effects on likely archaeological buried heritage assets on the Site include:
• Prediction of the magnitude of likely impacts upon the known or potential significance •
•
of buried heritage assets. Consideration of any embedded mitigation and/or offsetting measures that have been included with the Proposed Development, and any additional mitigation that might be required in the design and construction of the Proposed Development in order to reduce or eliminate any significant negative effects upon heritage assets; and Quantification of residual effects (those that might remain after mitigation).
11.5.8 The identification of physical impacts on buried heritage assets within a site takes into account any activity which would entail ground disturbance, for example site set up works, remediation, landscaping and the construction of new basements and foundations. 11.5.9 No embedded mitigation measures are proposed in relation to the enabling and construction impacts on archaeological remains. Mitigation will be secured through measures set out under a planning condition.
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Completed Development 11.5.10 Any potential impacts and effects on buried heritage assets will occur as a result of ground disturbance during demolition and construction works. No impacts or effects will occur on buried heritage assets on completion of the Proposed Development since no further ground disturbance will occur. Therefore, it is not considered necessary to further consider the completed Proposed Development in respect of buried heritage assets within this ES chapter. Temple Group Ltd. (on behalf of London Borough of Lewisham) have considered this approach acceptable in their Review of the Scoping Report (June 2024).
11.6 Significance Criteria 11.6.1 The assessment of the potential impacts and likely effects as a result of the Proposed Development has taken into account the Demolition and Construction Phases. Receptors and Receptor Sensitivity 11.6.2 In line with NPPF, for the purposes of this ES Chapter, archaeological ‘resources’ or ‘receptors’ are referred to as ‘buried heritage assets’, and heritage ‘significance’ is used in place of ‘sensitivity’. The use of heritage ‘significance’ and ‘significance of (environmental) effect’ are clearly differentiated throughout. All archaeological remains are highly sensitive to physical change because their heritage significance is derived from their physical form and location. 11.6.3 Table 11.2 describes the significance of designated and non-designated buried heritage assets as applied in this assessment. Table 11.2: Significance (Sensitivity) of Buried Heritage Assets Asset Significance Very High
Buried Heritage Asset World Heritage Sites; Scheduled Monuments; Grade I and II* Registered parks and gardens; and Non-designated sites, settlements and landscapes of equivalent – international/national – value or interest (exceptional heritage value).
High
Burial grounds; Grade II Registered parks and gardens; Designated battlefields; and Non-designated sites, settlements and landscapes of equivalent – regional/county – value or interest (rare and well-preserved examples).
Medium
Non-designated sites, settlements and landscapes with a district/borough value or interest for education or cultural appreciation (good preservation, sufficient for comparative study and educational/cultural appreciation).
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Low
Heritage assets with a local e.g. parish value or interest for education or cultural appreciation.
Negligible
Insignificant and/or badly damaged resources of little appreciable value or interest.
Uncertain
Resources that have a clear potential, but for which current knowledge is insufficient to allow significance to be determined.
Magnitude of Impact 11.6.4 Determination of magnitude of impact (i.e. change) upon the significance of known or potential heritage assets is based on the severity of the potential physical impact (e.g. any activity that would entail ground disturbance, from piling, ground reduction, etc.). Table 11.3 describes the criteria used in this assessment to determine the magnitude of change. Table 11.3: Magnitude of Impact Criteria Magnitude
Criteria
High
Complete removal of asset. Change to asset significance resulting in a fundamental change in our ability to understand and appreciate the resource and its historical context, character and setting. The transformation of an asset’s setting in a way that fundamentally compromises its ability to be understood or appreciated. The scale of change would be such that it could result in a designated asset being undesignated or having its level of designation lowered.
Medium
Change to asset significance resulting in a considerable change in our ability to understand and appreciate the asset and its historical context, character and setting. Notable alterations to the setting of an asset that affect our appreciation of it and its significance.
Low
Change to asset significance resulting in a small change in our ability to understand and appreciate the asset and its historical context, character and setting.
Negligible
Negligible change or no material change to asset significance. No real change in our ability to understand and appreciate the asset and its historical context, character and setting.
Uncertain
Level of survival/condition of resource in specific locations is not known: magnitude of change is therefore not known.
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Effect Significance 11.6.5 The scale of the potential environmental effect is determined by comparing the significance value of the baseline heritage asset with the magnitude of impact (change) upon that asset as a result of the Proposed Development and are initially presented without mitigation. The potential effects may be either adverse (negative) or beneficial (positive). The matrix for determining the scale of this effect is presented in Table 11.4. Where information is insufficient to quantify the asset significance or magnitude of change, the scale of the effect is given as ‘uncertain’. 11.6.6 ‘Significant’ environmental effects are those that are Moderate or Major in scale. Effects that are ‘Not Significant’ are Minor or Negligible in scale. Table 11.4: Effect Scale Magnitude of Impact
Heritage Asset Significance Very high
High
Medium
Low
Negligible
Uncertain
High
Major
Major
Major
Moderate
Minor
Uncertain
Medium
Major
Major
Moderate
Minor
Minor
Uncertain
Low
Moderate
Moderate
Minor
Minor
Negligible
Uncertain
Negligible
Minor
Minor/Negligible
Negligible
Negligible
Negligible
Uncertain
Uncertain
Uncertain
Uncertain
Uncertain
Uncertain
Uncertain
Uncertain
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Mitigation Measures and Residual Effects 11.6.7 Buried heritage assets are finite and, non-renewable, and irreplaceable once disturbed. The understanding of the significance of any individual heritage asset or group of assets often relies on a physical relationship to other heritage assets adjacent, or an associative relationship to assets nearby or in the wider environment. For this reason, once damaged or removed from their context, heritage assets cannot be meaningfully replicated or replaced and their significance is likely to be reduced or lost. Effects arising from their disturbance or removal are therefore usually adverse. 11.6.8 An appropriate mitigation strategy would aim to eliminate or reduce physical disturbance. Measures to mitigate adverse effects on archaeology would normally consist of design adjustments, to allow significant resources to be protected and retained (preservation in situ). Where preservation in situ is not proportionate or feasible, adverse effects may be offset through measures such as archaeological investigation and recording before and during development. Archaeological excavation is by its nature also destructive, but it can facilitate social benefit through the knowledge-gain of investigation and dissemination of the results at an appropriate level to ensure that the social benefit arising from the archaeological process is realised. 11.6.9 Based upon the information presented within Appendix 11.1, appropriate mitigation / offsetting measure are identified, and the resulting residual environmental effect is reassessed using Table 11.5. 11.6.10 Where archaeological remains are removed rather than preserved in situ, the magnitude of impact on that asset is unchanged by offsetting. It is, however, considered appropriate on the basis of professional judgement to assess the offsetting strategy as reducing the resulting adverse effects by one ‘level’ of severity when presenting residual effects, since it is considered an improved outcome than archaeological remains being removed by development without investigation and recording. 11.6.11 As heritage assets are an irreplaceable resource it is generally considered as standard practice within the planning system to implement measures in order to offset any level of adverse effect on a heritage asset, including minor adverse. This is to ensure that finite remains are not removed/lost without record. The measures proposed are, in each case, proportionate to the significance of the asset being affected and are based on professional judgement.
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Table 11.5: Description of Effect Scale and Nature of Effect
Description
Major negative
Substantial harm to, or loss of, significance of an asset of very high, high or medium heritage significance, as a result of changes to its physical form or setting.
Moderate negative
Less than substantial harm to the significance of an asset of very high, high or medium heritage significance, as a result of changes to its physical form or setting.
Minor negative
Limited harm to the significance of an asset of very high, high or medium heritage significance, as a result of changes to its physical form or setting, or substantial harm to, or the loss of, significance of an asset of low or very low heritage significance.
Negligible
No appreciable change to an asset’s significance.
Uncertain
Significance of effect uncertain due to lack of information on buried heritage asset significance.
Minor positive
Limited enhancement of an asset’s significance as a result of changes to its physical form or setting.
Moderate positive
Notable enhancement of an asset’s significance as a result of changes to its physical form or setting.
11.7 Baseline Conditions 11.7.1 Historic England’s National Heritage List does not include any nationally designated heritage assets within or adjacent to the Site. The Site is within the locally designated Tier 2 Lewisham Riverside Settlements Archaeological Priority Area (APA). The Site is not within a locally designated conservation area. 11.7.2 The underlying geology comprises Thames gravels of the Kempton Park group with alluvium associated with the junction of the River Ravensbourne and the River Quaggy. The local drift geology consists of Pleistocene river terrace gravels (the Ravensbourne Gravels), sealed by Holocene alluvium.
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11.7.3 The Site lies within the valley formed by the confluence of the Ravensbourne and Quaggy rivers, c 250m north of the Site. Ground levels across the study area reflect this, dropping from highs to the west and east to the centre of the Site. There is also a noticeable slope down to the north. A topographical survey of the Site undertaken in 2018 indicates that ground levels within the Site very much mirror that of the surrounding landscape. Ground level is at 10.4m above Ordnance Datum (OD) in the southern corner of the Site dropping to 7.8m OD immediately north-east of the Site on Lewisham High Street. 11.7.4 The site has a moderate, localised potential for palaeoenvironmental remains within alluvial deposits, of low or medium significance derived from their evidential value for past environments. 11.7.5 Although the resources of the river and marshy floodplain, such as water, fish, game, reeds, could have attracted activity, prehistoric evidence in the area is limited to a few chance finds of isolated flint artefacts. No in situ remains have been found despite a number of investigations. Much of the prehistoric land surface has been buried by reclamation of the floodplain or removed by late-19th century and later suburban development. 11.7.6 There is little archaeological evidence of Roman and medieval activity in the study area. During this period the Site lay on the banks of the Ravensbourne, at some distance from known roads or settlements, probably in a rural landscape of fields and occasional scattered farms. 11.7.7 Although no medieval remains have been recorded within the study area other than two possible medieval gravel pits 40m west of the Site, the APA has been designated for its potential to contain remains of medieval settlements that developed next to the Ravensbourne. The Corn Mill noted 20m to the west of the Site is known to have medieval origins and early modern mapping suggests the Site was on the roadside, either just outside or on the periphery of the medieval settlement. Given the development of the shopping centre it is likely that there is a low potential for remains of later-medieval settlement, rural features and activity associated with the riverside within the main area of the shopping centre, but a moderate potential along the lines of the roads. Such remains would be of medium significance derived from their evidential and historical value. Fragmented and poorly preserved remains would be of low significance. 11.7.8 Cartographic sources confirm the Site was occupied from at least the 18th century with roadside gardens and cultivation areas. By the 19th century the Site was developed with a mix of industrial and domestic structures as well as large villa gardens. Archaeological evidence of these would be of low heritage significance. The Site is considered likely to have a high potential to contain fragmented archaeological remains dating from the early-19th century of low significance derived from their evidential and historical value. Any surviving remains would be encountered immediately below levels of modern truncation, and possibly between modern foundations or other intrusions.
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11.8 Future Baseline 11.8.1 The evolution of the baseline is not relevant to the assessment of archaeology, as there would be no change expected to the below ground conditions on the Site prior to the Proposed Development commencing, and therefore any archaeological remains would remain as the existing baseline condition. 11.8.2 In relation to the wider understanding of archaeology in the area, should new information come to light in the course of archaeological works associated with the cumulative schemes, this may enhance the understanding of the baseline conditions at the Site.
11.9 Heritage Assets 11.9.1 The following are the buried heritage assets which will be considered in the following assessment: • •
•
Palaeoenvironmental remains of low significance for general alluvial remains and medium significance for datable timbers or deposits of organic material such as peat; Later medieval settlement remains which would be of low significance for fragmentary remains to medium significance for more substantial remains; and Post-medieval structural remains of low significance.
11.10 Assessment of Effects, Mitigation Demolition & Construction Phase 11.10.1 This section identifies and assesses the scale and nature of the main effects arising from the Proposed Development during the construction phase. Effects, prior to mitigation Site preparation 11.10.2 Works carried out as part of the initial site set up, including preliminary site stripping and demolition, the installation of site fencing and welfare facilities, is assumed for the purposes of this assessment to cause ground disturbance to a maximum depth of 0.5m below ground level (bgl). this would extend into modern made ground only and have no archaeological impact. Piled foundations 11.10.3 Any archaeological remains within the footprint of each pile would be removed as the pile is driven downwards. Secant (interlocking) piles would impact on any preserved remains along the line of their insertion into the ground. This would have a high magnitude of impact resulting in a permanent:
• •
Moderate negative effect on general palaeoenvironmental remains of low significance for general alluvial remains; Major negative effect for thick deposits of organic material such as peat of medium significance;
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• • •
Moderate negative effect on fragmentary later medieval settlement remains of low significance Major negative effect on substantial later medieval settlement remains of medium significance; Moderate negative effect on post-medieval structural remains of low significance.
11.10.4 Pile caps and connecting beams typically extend down 1.5mbgl, removing archaeological remains where they extend below the modern made ground. This would have a low magnitude of impact resulting in a permanent:
• • • • •
Minor negative effect on general palaeoenvironmental remains of low significance for general alluvial remains; Minor negative effect for thick deposits of organic material such as peat of medium significance; Minor negative effect on fragmentary later medieval settlement remains of low significance Minor negative effect on substantial later medieval settlement remains of medium significance; Minor negative effect on post-medieval structural remains of low significance.
Services/utilities trenches/drains/tree-planting 11.10.5 The proposed excavation of new service trenches and drains and the ground intrusion from tree planting and subsequent root action would extend to a depth of 1.0–1.5mbgl. removing archaeological remains where they extend below the modern made ground. This would have a low magnitude of impact resulting in a permanent:
• • • • •
Minor negative effect on general palaeoenvironmental remains of low significance; Minor negative effect for thick deposits of organic material such as peat of medium significance; Minor negative effect on fragmentary later medieval settlement remains of low significance Minor negative effect on substantial later medieval settlement remains of medium significance; Minor negative effect on post-medieval structural remains of low significance.
Mitigation / offsetting 11.11 Archaeological evaluation of the Site will be required. The most appropriate investigation strategy is likely to entail archaeological trenches, which would confirm the presence, nature and significance of any archaeological remains in the areas of proposed impact. The results of the evaluation would allow an informed decision to be made regarding an appropriate strategy to offset the impacts on buried heritage assets. This might comprise targeted archaeological excavation in advance of construction, and/or a watching brief during groundworks. This would ensure that significant archaeological assets are not removed without record and the opportunity to ensure public benefit from the archaeological process. Such work could be undertaken under the terms of a standard archaeological planning condition set out with the grant of planning consent, in accordance with a Written Scheme of Investigation (WSI) approved by GLAAS. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 11: Archaeology
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Residual Effect 11.11.1 As a result of the proposed offsetting the resulting residual effect would be reduced as follows. Piles
• • • • •
Minor negative effect (Not Significant) on general palaeoenvironmental remains of low significance; Moderate negative effect (Significant) for thick deposits of organic material such as peat of medium significance; Minor negative effect (Not Significant) on fragmentary later medieval settlement remains of low significance; Moderate negative effect (Significant) on substantial later medieval settlement remains of medium significance; Minor negative effect (Not Significant) on post-medieval structural remains of low significance.
Pile caps and connecting beams
• • • • •
Negligible negative effect (Not Significant) on general palaeoenvironmental remains of low significance; Negligible negative effect (Not Significant) thick deposits of organic material such as peat of medium significance; Negligible negative effect (Not Significant) on fragmentary later medieval settlement remains of low significance; Negligible negative effect (Not Significant) on substantial later medieval settlement remains of medium significance; Negligible negative effect (Not Significant) on post-medieval structural remains of low significance.
Services/utilities trenches/drains/tree-planting
• • • • •
Negligible negative effect (Not Significant) on general palaeoenvironmental remains of low significance; Negligible negative effect (Not Significant) for thick deposits of organic material such as peat of medium significance; Negligible negative effect (Not Significant) on fragmentary later medieval settlement remains of low significance Negligible negative effect (Not Significant) on substantial later medieval settlement remains of medium significance; Negligible negative effect (Not Significant) on post-medieval structural remains of low significance.
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Operational Phase 11.12 An assessment of operational phase effects has been scoped out on the basis that once the Proposed Development has been completed, no further ground disturbance would occur and consequently there would be no additional impacts or resulting environmental effects upon buried heritage assets.
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11.13 Limitation and Assumptions 11.13.1 The assessment relies on available data, and reasonable endeavours have been made to ensure that the data is accurate and up to date. It is assumed that information on the GLHER database is accurate. Whilst compiling the baseline a process of review and validation of the GLHER data has taken place (for example ensuring assets are correctly located, and undertaking further research, where appropriate, into GLHER entries with little information). 11.13.2 The main limitation to the assessment is the nature of the archaeological resource – i.e. buried and not visible – which means it can be difficult to predict accurately the presence and likely significance of archaeological assets, and consequently the impact upon them, using primarily desk-based sources. Nevertheless, the results of the process outlined above, along with appropriate consultation and background research, are considered sufficient to inform the archaeological baseline of the Site. 11.13.3 Notwithstanding these limitations, the methodology is considered robust, utilising reasonably available information, and conforms to the requirements of local and national guidance and planning policy. Typically, appropriate standard archaeological prospection and evaluation techniques are utilised to reduce the uncertainties inherent in any desk-based assessment, as part of an overall EIA mitigation strategy.
11.14 Cumulative Effects 11.14.1 An assessment of cumulative effects has been scoped out. Cumulative effects are ‘elevated’ effects which occur where the combined effect of the Proposed Development with other proposed schemes in the vicinity, on a discrete and significant shared asset/resource, is more severe than that reported at the Proposed Development site. This is on the basis that for intangible and deeply buried heritage assets it is not feasible to quantify accurately the nature of the resource across the assessment study area, which would enable the identification of a cumulative impact and potential elevated effect.
11.15 Summary 11.15.1 An archaeology desk based assessment has been undertaken which examines the potential impacts and likely effects of the development on buried heritage assets (archaeological remains) within the Site. These are parts of the historic environment which are considered to be significant because of their historic, evidential, aesthetic and/or communal interest. The assessment considers the magnitude of change (impact) of the Development upon the significance of known or potential buried heritage assets and the resulting environmental effects. 11.15.2 Due to the construction of the existing shopping centre, archaeological survival is expected to be very limited and localised. Buried heritage assets that may be affected by the Development comprise: • •
Palaeoenvironmental remains which would be of low significance for general alluvial remains and medium significance for thick deposits of organic material such as peat; Later medieval settlement remains which would be of low significance for fragmentary remains to medium significance for more substantial remains; and
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•
Post-medieval structural remains of low significance.
11.15.3 Archaeological evaluation of the Site will be required. The most appropriate investigation strategy is likely to entail archaeological trenches, to confirm the presence, nature and significance of any archaeological remains in the areas of proposed impact. The results of the evaluation would allow an informed decision to be made regarding an appropriate strategy to offset the removal of any significant archaeological assets. This might comprise targeted archaeological excavation in advance of construction, and/or a watching brief during groundworks. This would ensure that significant archaeological assets are not removed without record and the opportunity to ensure public benefit from the archaeological process. Such work could be undertaken under the terms of a standard archaeological planning condition set out with the grant of planning consent in accordance with a Written Scheme of Investigation (WSI) approved by GLAAS.
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Table 11.6: Summary of Effects DESCRIPTION BURIED HERITAGE SIGNIFICANCE OF EFFECTS SUMMARY OF SIGNIFICANCE OF RESIDUAL RELEVANT RELEVANT OF ASSET MITIGATION / EFFECTS POLICY LEGISLATION SIGNIFICANT MAJOR / POSITIVE P D ST ENHANCEMENT MAJOR / POSITIVE P D ST EFFECTS MODERATE / / / / MEASURES MODERATE / / / / / MINOR / NEGATIVE T I MT / MINOR / NEGATIVE T I MT NEGLIGIBLE / NEGLIGIBLE / LT LT Demolition & Construction Site preparation
Piles
Background Negligible Palaeoenvironmental remains Extensive organic Negligible layers (e.g. Peat) Fragmentary later Negligible medieval remains of settlement Substantial remains Negligible of later medieval settlement Post-medieval Negligible remains Background Moderate Palaeoenvironmental remains Extensive organic Major layers (e.g. Peat) Fragmentary later Moderate medieval remains of settlement Substantial remains Major of later medieval settlement Post-medieval Moderate remains
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Negative
P D LT Archaeological Negligible evaluation of the Site will be required. The Negligible most appropriate investigation Negligible strategy is likely to entail archaeological Negligible trenches to confirm the presence, nature Negligible and significance P D LT of any Minor archaeological remains in the areas of Moderate proposed impact. The results would Minor allow an informed decision to be made regarding Moderate an appropriate mitigation strategy for any Minor significant
Negative
P D LT
Negative
P D LT
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Pile caps and Background Minor connecting Palaeoenvironmental ground beams remains Extensive organic Minor layers (e.g. Peat) Fragmentary later Minor medieval remains of settlement Substantial remains Minor of later medieval settlement Post-medieval Minor remains Utilities Background Minor trenches/tree Palaeoenvironmental planting remains Extensive organic Minor layers (e.g. Peat) Fragmentary later Minor medieval remains of settlement Substantial remains Minor of later medieval settlement Post-medieval Minor remains D = Direct / I = Indirect P = Permanent / T = Temporary St = Short Term / Mt = Medium Term / Lt = Long Term
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P D LT archaeological Negligible assets. This might comprise targeted Negligible archaeological excavation in Negligible advance of construction, and/or a watching Negligible brief during ground works. Negligible
Negative
P D LT
P D LT
Negative
P D LT
Negligible
Negligible Negligible
Negligible
Negligible
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Abbreviations • ES: Environmental Statement • EIA: Environmental Impact Assessment • GLAAS: Greater London Archaeological Advisory Service of Historic England • GLHER: Greater London Historic Environment Record • WCC: Westminster City Council • MOLA: Museum of London Archaeology • NPPF: National Planning Policy Framework • OD: Ordnance Datum Glossary
• Alluvium: Sediment laid down by a river. Can range from sands and gravels deposited by fast • • • • • • •
• • •
• • •
flowing water and clays that settle out of suspension during overbank flooding. Other deposits found on a valley floor are usually included in the term alluvium (e.g. peat). Archaeological Priority Area/Zone: Areas of archaeological priority, significance, potential or other title, often designated by the local authority. Built heritage: Upstanding structure of historic interest. Cut feature: Archaeological feature such as a pit, ditch or well, which has been cut into the thenexisting ground surface. Desk-based Assessment: A written document whose purpose is to determine, as far as is reasonably possible from existing records, the nature of the historic environment resource/heritage assets within a specified area. Early medieval: AD 410–1066. Also referred to as the Saxon period. Evaluation (archaeological): A limited programme of non–intrusive and/or intrusive fieldwork which determines the presence or absence, and significance of archaeological features, structures, deposits, artefacts or ecofacts within a specified area. Excavation (archaeological): A programme of controlled, intrusive fieldwork with defined research objectives which examines, records and interprets archaeological remains, retrieves artefacts, ecofacts and other remains within a specified area. The records made and objects gathered are studied and the results published in detail appropriate to the project design. Findspot: Chance find/antiquarian discovery of artefact. The artefact has no known context, is either residual or indicates an area of archaeological activity. Geotechnical: Ground investigation, typically in the form of boreholes and/or trial/test pits, carried out for engineering purposes to determine the nature of the subsurface deposits. Heritage asset: A building, monument, site, place, area or landscape positively identified as having a degree of significance meriting consideration in planning decisions. Heritage assets are the valued components of the historic environment. They include designated heritage assets and assets identified by the local planning authority (including local listing). Historic Environment Record (HER): Archaeological and built heritage database held and maintained by the County authority. Previously known as the Sites and Monuments Record. Iron Age: 600 BC–AD 43. Later medieval: AD 1066 – 1500. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 11: Archaeology
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• Locally listed building: A structure of local architectural and/or historical interest. These are • • • • • • • • • • • • • • • • •
structures that are not included in the Secretary of State’s Listing but are considered by the local authority to have architectural and/or historical merit. Listed building: A structure of architectural and/or historical interest. These are included on the Secretary of State's list, which affords statutory protection. These are subdivided into Grades I, II* and II (in descending importance). Made Ground: Artificial deposit. An archaeologist would differentiate between modern made ground, containing identifiably modern inclusion such as concrete (but not brick or tile), and undated made ground, which may potentially contain deposits of archaeological interest. Mesolithic: 12,000 – 4,000 BC. Neolithic: 4,000 – 2,000 BC. Ordnance Datum (OD): A vertical datum used by Ordnance Survey as the basis for deriving altitudes on maps. Palaeolithic: 700,000–12,000 BC. Post-medieval: AD 1500–present. Preservation by record: Archaeological mitigation strategy where archaeological remains are fully excavated and recorded archaeologically, and the results published. For remains of lesser significance, preservation by record might comprise an archaeological watching brief. Preservation in situ: Archaeological mitigation strategy where nationally important (whether Scheduled or not) archaeological remains are preserved in situ for future generations, typically through modifications to design proposals to avoid damage or destruction of such remains. Registered Historic Parks and Gardens: A site may lie within or contain a registered historic park or garden. The register of these in England is compiled and maintained by Historic England. Residual: When used to describe archaeological artefacts, this means not in situ, i.e. found outside the context in which it was originally deposited. Roman: AD 43–410. Scheduled Monument: An ancient monument or archaeological deposits designated by the Secretary of State as a ‘Scheduled Ancient Monument’ and protected under the Ancient Monuments Act. Site: The area of proposed Development. Study area: Defined area surrounding a site in which archaeological data is collected and analysed in order to set a site into its archaeological and historical context. Truncate: Partially or wholly remove. In archaeological terms remains may have been truncated by previous construction activity. Watching brief (archaeological): A formal programme of observation and investigation conducted during any operation carried out for non-archaeological reasons.
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References Ref 11.3.1 Ministry of Housing, Communities and Local Government, 2023. National Planning Policy Framework Ref 11.3.2 Department of Communities and Local Government, March 2014 Conserving and Enhancing the Historic Environment: Planning Practice Guide Ref 11.3.3 Greater London Authority, 2021. The London Plan: The Spatial Development Strategy for Greater London formally published 2nd March 2021 Ref 11.3.4 Greater London Authority, 2014. Sustainable Design and Construction Supplementary Planning Guidance Ref 11.3.5 London Borough of Lewisham, 2011, Core Strategy Ref 11.3.6 London Borough of Lewisham, 2014, Development Management Local Plan Ref 11.3.7 Chartered Institute for Archaeologists, 2020, Standards and guidance for historic environment desk-based assessment, Published December 2014, updated January 2017 and October 2020 Ref 11.3.8 The Institute of Environmental Management and Assessment (2021) Principles of Cultural Heritage Impact Assessment in the UK Ref 11.3.9 Historic England (2019) Piling and Archaeology: Guidance and Good practice
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12.0 Daylight, Sunlight, Overshadowing, Light Pollution and Solar Glare 12.1 Executive Non-Technical Summary 12.1.1 The Lewisham Shopping Centre site represents a significant regeneration opportunity for the London Borough of Lewisham, within a town centre that is currently undergoing considerable redevelopment in line with the aspirations of the Local Plan. 12.1.2 The current site is comprised of a large series of relatively low-medium rise commercial buildings and as such, where residential buildings are located in nearby proximity to the site and relevant for assessment, 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. 12.1.3 It is therefore inevitable, particularly in major regeneration and opportunity areas, that if redevelopment proposals are to deliver in accordance with local planning policy aspirations and make efficient use of land in line with the National Planning Policy Framework, a noticeable degree of change in daylight and sunlight levels will naturally be experienced. 12.1.4 Notwithstanding this, the detailed technical assessments for the Operational Phase of the development (for both the Outline Maximum Parameters and Detailed Blocks N1 and N2) undertaken and set out within this Chapter, demonstrate that the compliance levels when measured against the BRE Guidelines (2022) recommendations are very good for an urban town-centre location. 12.1.5 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 Daylight Distribution criteria. For sunlight, 94% of all southerly orientated habitable rooms will exceed the BRE recommendations for Annual Probable Sunlight Hours. This demonstrates that a high proportion of the sensitive receptors around the site will experience daylight and sunlight effects of negligible significance. 12.1.6 From a sun on ground (overshadowing perspective) whilst there will naturally be some gardens/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 experience a negligible effect. 12.1.7 It is, however, also important to note that the Illustrative Masterplan for the Site has also been assessed, which complies with the maximum parameter plans and represents a more ‘realistic’ future development proposal for the Outline element of the site. The technical assessments indicate a further reduced daylight and sunlight effect upon the sensitive receptors by comparison to the Maximum Parameter massing, 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 Element of the Masterplan can be positively reduced, mitigated and, in many cases, designed out at future detailed reserved matters stage, by adopting the principles defined by the Illustrative Masterplan. 12.1.8 Finally, there will be no significant effects upon both light pollution and solar glare effects of the detailed elements of the Operational Phase of the Development.
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12.2 Introduction 12.2.1 This Chapter reports the likely significant effects of the Proposed Development on the Site and the surrounding area in terms of daylight, sunlight, overshadowing, solar glare and light pollution matters. Where appropriate, it also identifies proposed mitigation measures to prevent, minimise or control likely negative effects arising from the Proposed Development and the subsequent anticipated residual effects. 12.2.2 Effects in relation to daylight, sunlight and overshadowing will vary throughout the demolition and construction phase. There will be no notable anticipated effect whilst the existing buildings on the Site are demolished. There will also be no anticipated effect following the completion of the demolition of the buildings. During the construction of the Proposed Development, 12.2.3 the effects would be no worse than those of the completed Development as set out below. For those residents, who would be living in the initial phases of the Development (completed blocks of the Detailed Proposals of the Development), during the construction of the Outline Proposals, they would enjoy higher levels of daylight/sunlight. 12.2.4 This Chapter of the ES therefore identifies and discusses the effects of the completed Development on the following:
• • • •
Daylight and sunlight amenity within the surrounding residential properties; Overshadowing to the surrounding gardens, amenity areas and open spaces; Solar glare to the approaching motorists; and Light Pollution emitted from the detailed (block N1 & N2) commercial elements of the masterplan to the surrounding residential receptors.
12.2.5 This Chapter is accompanied by the following appendices: • • • • • • • •
Appendix 12.1 – Drawings Appendix 12.2 – Tabulated Results: Main Assessment Appendix 12.3 – Tabulated Results: Cumulative Assessment Appendix 12.4 – Sun Hours on Ground Appendix 12.5 – Solar Glare Appendix 12.6 – Light Pollution Appendix 12.7 – NSL Contour Plots Appendix 12.8 – Window Maps
12.2.6 Internal Daylight and Sunlight levels within the detailed proposals of the Development, as well as sun on ground levels within the Development, are not considered within this Chapter. They are instead dealt within in a separate standalone Daylight, Sunlight and Overshadowing Report that is submitted in support of the application.
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12.3 Competence 12.3.1 This assessment has been undertaken by Elliot Smith who is an Associate Director at Point 2. Point 2 specialise in daylight, sunlight, overshadowing, solar glare and light pollution matters. Point 2 was founded in 2014 and is considered one of the market leading companies providing daylight, sunlight, overshadowing and light pollution advice. 12.3.2 Elliot specialises in advising on daylight, sunlight, overshadowing and light pollution matters for planning purposes and has an extensive and broad range of experience in this area.
12.4 Legislation, Planning Policy and Guidance 12.4.1 There is no specific legislation relating to the issues of daylight, sunlight and overshadowing as considered in the context of this assessment and Chapter, however, the following national, regional and local planning policy and guidance is of relevance to the assessment of the effects of the Proposed Development. National Planning Policy 12.4.2 The following national level policy and guidance documents are of relevance to the Proposed Development: National Planning Policy Framework (NPPF), September 2023 12.4.3 There 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.” Under the subheading “Achieving appropriate densities” it states at paragraph 123: 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). Regional Planning Policy Lewisham Local Plan: An Open Lewisham as part of an Open London, January 2023 12.4.4 Policy QD7 Amenity and Agent of Change states: “Development proposals must use the design-led approach to protect and wherever possible enhance amenity whilst ensuring no unacceptable adverse impact on amenity, both for users of the development and those properties likely to be affected by the development by ensuring:
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…c) Adequate levels of ventilation, daylight, sunlight and open aspects including provision of private amenity space where appropriate” 12.4.5 Policy HD8 High Quality Housing Design states: “…E) Development proposals for housing must be designed to protect and enhance amenity of building occupants, as well as that of adjoining site users and uses, in line with Policy QD7. They must ensure adequate provision of natural light with reference to the latest Building Research Establishment (BRE) good practice guidance, currently BRE209: Site layout for daylight and sunlight, or suitable equivalent.” Local Planning Policy 12.4.6 The Proposed Development is located within the London Borough of Lewisham and the potential effects have therefore been considered against their current planning policy. Guidance Building Research Establishment Guidelines: Site Layout Planning for Daylight and Sunlight: A Guide to Good Practice, Third Edition (2022)
12.4.7 The BRE Guidelines provides “advice on site layout planning to achieve good daylighting and sunlighting, within buildings and in the open spaces between them.” It is intended for building designers, developers, consultants and Local Planning Authorities (LPAs). It is intended to be used in conjunction with the Chartered Institute of Building Services Engineers (CIBSE) publication Lighting guide: daylighting and window design. 12.4.8 The advice it gives is not mandatory and should not be used as an instrument of planning policy. Of particular relevance, it states within the opening summary: “This guide is a comprehensive revision of the 2011 edition of Site Layout Planning for Daylight and Sunlight: A Guide to Good Practice. It is purely advisory and the numerical target values within it may be varied to meet the needs of the development and its location.” 12.4.9 In addition, paragraph 1.6 states: …its aim is to help rather than constrain the designer. Although it gives numerical guidelines, these should be interpreted flexibly since natural lighting is only one of many factors in site layout design (see Section 5). In special circumstances, the developer or the planning authority may wish to use different target values. For example, in a historic city centre, or in an area with modern high-rise buildings, a higher degree of obstruction may be unavoidable if new developments are to match the height and proportions of existing buildings.”
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12.4.10 The BRE Guidelines1 makes the following statement regarding the potential for reflected solar glare on a development: Glare or solar dazzle can occur when sunlight is reflected from a glazed façade or area of metal cladding. This can affect road users outside and the occupants of adjoining buildings. The problem can occur either when there are large areas of reflective tinted glass or cladding on the façade, or when there are areas of glass or cladding, which slope back so that high altitude sunlight can be reflected along the ground. Thus, solar dazzle is only a long-term problem for some heavily glazed (or mirror clad) buildings. Photovoltaic panels tend to dazzle because they are designed to absorb light. Commission Internationale de L’Eclairage (CIE) 146:2002 & CIE 147:2002 Collection on glare (2002) 12.4.11
The guidance2 states that: disability glare is glare that impairs vision. It is caused by scattering of light inside the eye…The veiling luminance of scattered light will have a significant effect on visibility when intense light sources are present in the peripheral visual field and contract of objects is seen to be low. Disability glare is most often of importance at night when contrast sensitivity is low and there may well be one or more bright light sources near to the line of sight, such as car headlights, streetlights or floodlights. But even in daylight conditions disability glare may be of practical significance: think of traffic lights when the sun is close to them, or the difficulty viewing paintings hanging next to windows.
12.4.12
It describes how the closer the instance of glare is to the line of sight of the viewer the worse the veiling effect of glare becomes.
12.5 Assessment Methodology and Significance Criteria 12.5.1 The following section outlines the methodologies applied to identify and assess the potential impacts and likely effects to result from the Proposed Development. Scope of the Assessment 12.5.2 An EIA Scoping Report was issued to LBL in January 2024. LBL’s formal Scoping Opinion was issued in June 2024. 12.5.3 The following potential effects were scoped into the assessment:
• • •
the daylight and sunlight amenity to the surrounding residential properties; overshadowing to the surrounding private gardens and public amenity areas; solar glare to the approaching motorists and rail users; and
1
Building Research Establishment Guidelines: Site Layout Planning for Daylight and Sunlight: A Guide to Good Practice, Third Edition (2022) 2
Commission Internationale de L’Eclairage (CIE) 146:2002 & CIE 147:2002 Collection on Glare (2002)
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•
light pollution emitted from the commercial elements of the detailed element of the masterplan to the surrounding residential receptors.
12.5.4 The technical analysis has been undertaken via the creation of a digital three-dimensional model of the existing Site and its surroundings, and the Proposed Development. The cumulative schemes were also considered where they have potential influence over daylight and sunlight conditions to surrounding residential receptors, which was as agreed within the EIA Scoping Report. 12.5.5 The daylight and sunlight assessments used to prepare this chapter are based on the BRE Guidelines. Relevant standards within the BRE Guidelines are set out in the following paragraphs. 12.5.6 Residential receptors/properties are usually most sensitive to daylight and sunlight availability. This assessment therefore focusses on the effects to residential properties that surround the Site. The extent of the properties assessed is set out below under the heading ‘Sensitive Receptors’. 12.5.7 Commercial properties are generally deemed to have a greater reliance on supplementary electric lighting and therefore have been excluded from the assessment. 12.5.8 The BRE Guidelines provide different methods for assessing daylight for existing and proposed residential accommodation. These are, however, based upon the same fundamental principles. Likely Significant Effects Demolition and Construction Phase 12.5.9 Owing to the constantly evolving and changing nature of refurbishment, demolition and construction activities, the assessment of potential effects during refurbishment, demolition and construction of the Proposed Development on daylight, sunlight and overshadowing to the surrounding sensitive receptors have not been modelled and analysed. The effects experienced by the sensitive receptors during the refurbishment, demolition and construction phases will be no greater than that described within the Completed Development section. This approach is often adopted within Daylight, Sunlight, Overshadowing and Solar Glare Environmental Impact Assessments. Operational Phase
• • • •
Likely to be some increases in daylight and sunlight amenity effects to the surrounding residential properties; Likely to be some increases in the level of overshadowing to the surrounding gardens, amenity areas and open spaces; and Likely to be the potential for some adverse solar glare to the approaching motorists, cyclists and train drivers; Likely to be the potential for some light pollution emitted from the detailed N1 and N2 commercial units on to the adjacent residential properties.
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Extent of The Study Area 12.5.10 The assessments undertaken within this ES chapter will be primarily based on the Building Research Establishment (BRE) guidelines entitled ‘Site layout planning for daylight and sunlight: a guide to good practice’ (referred to as the ‘BRE guidelines’), as well as any relevant national, regional or local planning policies. 12.5.11 A study area has been assembled by reference to professional judgement and the likelihood that that surrounding properties may record a BRE transgression as a result of the Proposed Development. Figure 12.1 below shows the extent of the study area, highlighting the site in dark blue and the scope zone outlined in pink. Properties that have been assessed within the Sensitive Receptors section below, which were as set out within the Environmental Scoping Report. Figure 12.1 Lewisham Shopping Centre Site (highlighted dark blue) and scope zone (outlined pink)
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Method of Baseline Collection 12.5.12 The assessment of daylight and sunlight amenity is governed principally by the extent of the existing and proposed structures (obstructions) which surround a sensitive receptor. Using professional judgement and an inspection of the site and surrounding context, the extent of the study area has been established by considering which of the surrounding sensitive receptors and open spaces may be affected by the construction of the Proposed Development. 12.5.13 The current Baseline Conditions are defined as the existing site conditions at the time of the planning submission. Detailed land survey information has been provided by Plowman Craven and Point 2 which surveyed each of the existing buildings and structures on the site, as well as the surrounding area considered to be relevant for the assessment of daylight, sunlight, overshadowing and solar glare effects. 12.5.14 Solar glare and Light Pollution are not assessed in the baseline situation as the effect assessment is not typically based upon a comparison of the existing and proposed situations. Method of Assessment Demolition & Construction Phase 12.5.15 Owing to the constantly evolving and changing nature of refurbishment, demolition and construction activities, the assessment of potential effects during refurbishment, demolition and construction of the Proposed Development on daylight, sunlight, overshadowing and solar glare to the surrounding sensitive receptors have not been modelled and analysed. The effects experienced by the sensitive receptors during the refurbishment, demolition and construction phases will be no greater than that described within the Completed Development section, discussed below.
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Operational Phase 12.5.16 As outlined in Volume 1, Chapter 2: Approach to the Assessment, of this ES for the Outline Proposals, the Parameter Plans are submitted for approval and which therefore set the parameters and form of development. For the Outline Element, this ES and assessment includes an assessment that has been based on the maximum building footprints and maximum building heights as depicted by the Development (ie Maximum Parameters). Therefore, the assessment has been carried out on the basis of the building footprints identified within Appendix 12.1. 12.5.17 This Chapter (Chapter 12) also includes an assessment that considers an illustrative masterplan scheme. Although this this scenario does not form part of the main assessment, it has been supplied to demonstrate daylight and sunlight levels that are more likely to be experienced, as the illustrative masterplan has been designed to represent a reasonable implementation of a future completed scheme. Daylight 12.5.18 The technical specification offered by the BRE Guidelines is generally accepted to be predicated upon a lower-rise suburban environment as opposed to denser urban environments or areas undergoing regeneration. This is recognised in mayoral policy and by LBL in previous planning applications. 12.5.19 The BRE Guidelines repeatedly emphasise to the user, whether that be designers, consultants or planning officials to apply the guidelines in a manner that is appropriate for a particular situation. A recurring theme is that the numerical guidance isn’t fixed and it is appropriate to assess the effects of development against alternative target values that are appropriate for a particular situation. 12.5.20 The BRE Guidelines present two principal tests when calculating daylight to surrounding buildings where they are considered to have a reasonable expectation of daylight. These are:
• •
The Vertical Sky Component test; and The No-Sky Line test (which assesses the Daylight Distribution).
Vertical Sky Component (VSC) 12.5.21 VSC is a quantified measurement of the amount of skylight falling on a vertical wall or window. The BRE Guidelines tell us that: “This is the ratio of the direct sky illuminance falling on a vertical wall at the reference point (usually the centre of the windows), to the simultaneous horizontal illuminance under an unobstructed sky. The standard CIE (Commission International de l’Eclairage – International Commission on illumination) overcast sky is used, and the ratio is usually expressed as a percentage. The maximum value is almost 40% for a completely unobstructed vertical wall”.
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12.5.22 VSC may be calculated by using the sky light indicator or Waldram Diagram. For calculation purposes, the BRE Guidelines advise that it is usual to ignore trees unless they form dense continuous belts. The computer software used for this daylight assessment has utilised the Waldram Diagram method to calculate the VSC. 12.5.23 When analysing windows beneath balconies, the BRE Guidelines state at Paragraph 2.2.11: “2.2.11 Existing windows with balconies above them typically receive less daylight. Because the balcony cuts out light from the top part of the sky, even a modest obstruction opposite may result in a large relative impact on the VSC, and on the area receiving direct skylight. One way to demonstrate this would be to carry out an additional calculation of the VSC and area receiving direct skylight, for both the existing and proposed situations, without the balcony in place. For example, if the existing value with the balcony was under 0.8 times the existing value with the balcony, but the same ratio for the values without the balcony was well over 0.8, this would show that the presence of the balcony, rather than the size of the new obstruction, was the main factor in the relative loss of light.” 12.5.24 The above principle also applies to a window which is set back behind a recessed balcony, located beneath a roof overhang, and also any external staircases etc. No Sky Line (NSL) 12.5.25 The NSL test is a measure of the distribution of daylight at the ‘working plane’ within a room. Typically, the ‘working plane’ is a horizontal ‘desktop’ plane taken at 0.85 metres above finished floor level. The NSL divides those areas of the working plane in a room which receives direct sky light through the windows from those areas of the working plane which does not. The BRE Guidelines advise that if a significant area of the working plane lies beyond the NSL (i.e. it receives no direct sky light) then the distribution of daylight in the room would be poor and supplementary electric lighting may be required. 12.5.26 The potential effect of the daylighting distribution in the surrounding existing buildings is established by plotting the NSL in each of the main rooms. For houses, this includes living rooms, dining rooms and kitchens. The BRE Guidelines advise that bedrooms should also be analysed, although they are less important. Sunlight Annual Probable Sunlight Hours (APSH)
12.5.27 The BRE Guidelines suggest using the Annual Probable Sunlight Hours (APSH) when assessing sunlight impact to neighbouring properties. 12.5.28
For existing residential properties, the BRE Guidelines state in Section 3.2.3 that: “all main living rooms of dwellings…should be checked if they have a window facing within 90° of due south, kitchens and bedrooms are less important, although care should be taken not to block too much sun.” Section 3.2.4 continues:
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“If the main living room to a dwelling has a main window facing within 90° of due north, but a secondary window facing within 90° of due south, sunlight to the secondary window should be checked.” 12.5.29 The BRE Guidelines suggest that when assessing sunlight for existing neighbouring buildings, the point at the centre of the window on the outside window face can be used. Section 3.2.5 states: “If this window point can receive at least one quarter of APSH, including at least 5% of APSH in the winter months between 21 September and 21 March, then the room should still receive enough sunlight.” 12.5.30 Where an existing surrounding room is served by more than one window (regardless of whether they all or only some face within 90⁰ of due south), all windows have been assessed. This ensures that the true level of sunlight amenity to the room in question is considered. Overshadowing 12.5.31 The BRE Guidelines acknowledge that sunlight in the space between buildings has an important effect on the overall appearance and ambience of a development. “3.3.1 Good site layout planning for daylight and sunlight should not limit itself to providing good natural light inside buildings. Sunlight in the space between buildings has an important effect on the overall appearance and ambience of a development.” Sun on Ground 12.5.32 The method for assessing sun on the ground is the ‘sun-on-ground indicator’. The BRE Guidelines suggest that the Spring Equinox (March 21st) is a suitable date for the assessment. 12.5.33 Using specialist software, the path of the sun is tracked to determine where the sun would reach the ground and where it would not. This assessment reviews the total percentage of an area that receives at least 2 hours of direct sunlight on March 21st. 12.5.34 The BRE Guidelines suggest that for a garden or amenity area to appear adequately sunlit throughout the year, no more than half (50%) of the area should be prevented by buildings from receiving 2 hours of sunlight on the 21st March.
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Solar Glare 12.5.35 Glare can be divided into two distinct categories. Discomfort glare (otherwise known as psychological glare) is about the difficulty in being able to see in order to carry out a task, or a reaction to avoid looking towards a bright source of light. Disability glare (otherwise known as physiological glare) is a reduction in visibility caused by light from bright sources being scattered within the eye, across the retina. The result is that vision is impaired by the veiling effect caused by the scattered light. 12.5.36 Discomfort glare has not been assessed as it is a subjective psychological response to bright light. Disability glare resulting from solar reflection from building facades can give rise to increased risk of accidents, and it is this phenomenon which is the subject of detailed analysis in this assessment. 12.5.37 The assessment of solar glare from the Proposed Development is, generally, not a comparative one. There is, therefore, no baseline solar glare condition in this instance. Whilst there may be instances of solar glare from the existing and other surrounding buildings which may be visible from the sensitive viewpoints, or which, when the Proposed Development is constructed, would no longer be visible from the sensitive viewpoints identified, this has not been technically assessed. 12.5.38 The Solar Glare assessment has considered the likely effects on the nearby road and railway user in two scenarios. Scenario one equating to a worse-case which assessed the effects of the scheme if it were to be fully mirrored, and another scenario where the detailed application was modelled as detailed (i.e. with all the windows in the correct places, and brick façades in place etc.) with the outline scheme remaining as fully mirrored (as we do not yet know the position of any windows). 12.5.39 The BRE Guidelines makes the following statement regarding the potential for reflected solar glare on a development at paragraph 5.8.1: “Glare or solar dazzle can occur when sunlight is reflected from a glazed façade or area of metal cladding. This can affect road users outside and the occupants of adjoining buildings. The problem can occur either when there are large areas of reflective tinted glass or cladding on the façade, or when there are areas of glass or cladding, which slope back so that high altitude sunlight can be reflected along the ground. Thus, solar dazzle is only a long-term problem for some heavily glazed (or mirror clad) buildings. Photovoltaic panels tend to dazzle because they are designed to absorb light.” 12.5.40 The BRE guidelines outline a brief methodology for evaluation of the scale of a solar glare issue: “If it is likely that a building may cause solar dazzle the exact scale of the problem should be evaluated...by identifying key locations such as road junctions and windows of nearby buildings and working out the number of hours of the year that sunlight can be reflected to these points.”
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12.5.41 The solar glare assessments undertaken as part of this Chapter first simulate the path of the sun for the entire year around the Proposed Development. This is to establish the locations, times, duration and direction of solar reflections and identify where these may affect sensitive locations, with a particular focus on road users or railways. This is referred to as the ‘annual sequence’. The assessment is carried out using a specialist software applied to a threedimensional AutoCAD model of the building and its surrounding context. 12.5.42 From the annual sequence assessment, the sensitive receptor locations have been identified from which more detailed tests have been run using calendar graphs. The type of calendar graph considered shows the angle at which the solar glare that may occur from the reference point, when it will occur, and the duration. An example calendar graph is given below at Figure 12.2: Figure 12.2 - Example Calendar Graph
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12.5.43 The calendar graphs’ axes show the days of the year along the X axis and time of day on the Y axis. The graph has 365 segments along the X axis, one for each day of the year and 720 segments on the Y axis each representing 5 minutes of the 24hr period per day. The light grey areas illustrate the times of daylight during each day and the dark grey areas illustrates the times of night. The yellow, green, orange and red colours indicate when Solar Glare may occur, and, depending on the colour, the angle at which it is likely to occur from the receptor. If a band of colour is tall it means that solar glare is likely to occur for an extended period of time during that day. If the band of colour is thin and long on the graph, it means solar glare may occur on each day but only for a limited time. This assessment does not account for the limits of the windscreen or for possible use of drivers’ visors, which could mitigate some glare instances. 12.5.44 Glare occurrences that could encroach on the foveal view (which is 3° from the visual axis – See Figure below) are depicted in red on the calendar graphs. Glare occurrences that could encroach between 3° and 10° of the centre of the visual axis are depicted in orange and glare occurrences that could encroach between 10° and 30° of the centre of the visual axis are depicted in green. Beyond 30° the glare occurrences are depicted in yellow. Light Pollution 12.5.45 The ILP Guidance Notes provide measurable lighting level values to ascertain the acceptability of any light pollution. As commercial buildings with large areas of glazing can sometimes cause light intrusion from their internal luminaires to nearby sensitive receptors, quantitative light pollution assessments have been undertaken in relation to these internal luminaires. This is assessed as vertical illuminance in lux (Ev), measured flat at the centre of the sensitive receptor. 12.5.46 Table 12.1 sets out the criteria based on the various environmental zones as per the ILP Professional Lighting Guidance Note 01/20: Guidance notes for the reduction of obtrusive light. Table 12.1 - Light Pollution Criteria for Environmental Zones
Light Intrusion (into windows) Ev (Lux) (2)
Environmental Zone
Pre-curfew
Post-curfew
0
0
areas
2
0 (1*)
brightness
5
1
10
2
25
5
E0 – Dark areas (e.g. UNESCO Starlight Reserves, IDA Dark Sky Parks) E1-
Intrinsically
dark
(e.g. National Parks, areas of outstanding natural beauty) E2-
Low
district
(e.g. rural or small village locations) E3- Medium district brightness (e.g. small-town centres or urban locations) E4- High district brightness (e.g. town/city centres with high levels of night time activity) Notes:
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Ev = Vertical Illuminance in Lux and is measured flat on the glazing at the centre of the window. Curfew = The time after which stricter requirements (for the control of obtrusive light) will apply; often a condition of use of lighting applied by the planning authority. If not otherwise stated – 23.00 hrs is suggested. * = From Public road lighting installations only.
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12.5.47 This chapter considers the likely light pollution effects to the surrounding residential properties which have the potential to be affected. Primary consideration is given to the “post curfew” hours between 11pm and 6am, as this is when ‘nuisance’ is most likely to be noticed by the surrounding residents. 12.5.48 The proposed retail spaces and residential concierge/lobby areas within the detailed proposals of the Development (N1 and N2) are likely to be able to be accessed 24 hours a day, even though operation is expected to mostly be within standard business hours. Therefore, to understand whether there is the potential for light pollution to occur it is assumed that all spaces within the Proposed Development have the lights switched on and any blinds are fully open to understand the worst-case maximum effect. 12.5.49 Detailed floor plans and elevations showing the location and sizes of glazing apertures have been used to construct the detailed model of the commercial retail and residential concierge//lobby areas of the detailed elements of the Development (N1 and N2). 12.5.50 In the absence of detailed internal lighting strategies and proposals at this stage of the design, the assessments of the retail and residential concierge/lobby areas within the detailed proposals of the Development (N2) are based upon a typical retail space illuminance of achieving 100 lux at the working plane, whilst the illuminance levels within the office/service areas of the detailed proposals of the Development (N1) are taken from the Lighting Guide 7: Office Lighting of CIBSE where it is suggested that open-plan offices recommended maintained illuminance (lux) should be 300 lux at the working plane for screen-based work. 12.5.51 With the level of light within the retail and concierge/lobby areas set to achieve 100 Lux at the working plan and the offices set to achieve 300 lux at the working plane, the light is then allowed to spill out through the windows and fall on the neighbouring facades. For the purposes of the calculations, the windows have been assumed to be standard clear double glazing. 12.5.52 To ensure that the effects of the Proposed Development are understood, any other external lighting sources (street lights etc.) have not been included within the calculations. Methodology of Defining an Alternative Target Value 12.5.53 When determining the effects a scheme may have on the neighbouring surrounding sensitive receptors, the scale of reduction is just one of many factors to consider. It is also important to consider whether the level of daylight/sunlight left behind is considered acceptable based upon the ever-evolving city landscape. 12.5.54 The NPPF suggests that the BRE Guidelines should be applied sensitively to higher density developments. 12.5.55 In urban locations where the proposed development is either currently undeveloped or contains relatively low-rise structures, reductions of daylight and sunlight beyond the BRE Guidelines as a result of redevelopments such as this are considered likely. This is because the existing levels of daylight and sunlight can be unusually high for an urban location such as this and applying the BRE guidelines 20% reduction rule can still result in a retained light level above what is considered well above what is expected for an urban or even suburban area.
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12.5.56 The above view is recognised by the BRE guidelines, which suggests that it may not be appropriate to apply the general guidance to all development locations but set alternative target values based on the locality of the Development. Therefore, where the likely reductions are beyond the general BRE guidelines criteria, this Chapter has considered whether the likely retained levels of daylight and sunlight are commensurate with the urban context of the Development and its proposed density. 12.5.57 The London SPG - Housing advises that the daylight impact on adjacent properties should be “assessed drawing on broadly comparable residential typologies within the area and of a similar nature across London”. Similar, recently built/consented, schemes in London (referred to as the ‘contextual sites’) and the levels of daylight retained to the existing surrounding residential properties have therefore been considered as part of the Contextual sites analysis for determining an alternative target value. The aim of this study is to establish what could be considered an acceptable level of retained daylight, which can then be applied to the Development’s results. The full analysis and conclusions of the contextual sites analysis is given within Appendix 12.2 12.5.58 Following the guidance set out in The London SPG – Housing, the BRE guidelines should be applied sensitively and alternative targets should be based on comparable residential typologies within the area and of a similar nature across London. The results of these comparable studies therefore helped to draw the conclusion that a retained VSC of 15% (when ignoring the effect of any obstructions such as balconies) can be considered an acceptable level of daylight, given the proposed density and location of the Development. 12.5.59 When looking to apply the above guidance, these concluding results were in line with one of the key examples presented which was The Whitechapel Estate Site. This is considered a suitable comparator, whereby it was an existing low-rise site which was developed as a highdensity residential led scheme within an urban area of London. In the appeal (Appeal Ref: APP/E5900/W/17/3171437) the Inspector noted:
•
• •
•
A blanket application of the BRE guidelines standards, is not appropriate given the inner-city location and the transformational change sought in the area. The London Housing SPG also encourages that the guidelines should be applied sensitively in opportunity areas and accessible locations given the need to optimise housing capacity. Vertical Sky Component (VSC) values in the ‘mid-teens’ have been found to be acceptable across London and endorsed by the GLA in an inner-city area. Weight is given to the fact that the Whitechapel Vision Masterplan (‘WVM’) and Opportunity Area Planning Framework (‘OAPF’) flag the desirability of high-density development and therefore existing residents ‘would be prepared for change and would not necessarily expect existing standards of daylight and sunlight to persist after development’. The Proposal would result in some significant individual reductions in daylight and sunlight levels, but this is ‘almost unavoidable in achieving the policy requirement for high density development in a confined urban setting’.
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12.5.60 With regards to daylight distribution, it is not feasible to carry out a similar contextual assessment as undertaken for the VSC. This is because the detail such as the layout of each room surrounding each Site is unknown and would take a very long time to model and assess. We are however of the professional view that it is very difficult to retain direct daylight to at least 80% of the working plane in urban locations without having to compromise on other factors, such as, ensuring the development potential of the site is fully utilised. In addition, it is often found that this level is not achieved in the existing condition. For urban locations, we are generally of the professional view that if more than 50% of the working plane can continue to receive some direct daylight, then the room can be considered to retain an adequate level of daylight distribution. 12.5.61 As the ability to receive sunlight is dependent on the orientation of the window it is also not reasonably possible to apply the same methodology to establish some suitable alternative criteria as done for the VSC test. However, based on our collective experience, we would consider a retained total APSH of 15% and above (to a window unobstructed by balconies or other projections etc.) a reasonable level of retained sunlight for a dense urban area.
12.6 Significance Criteria 12.6.1 The assessment of the potential impacts and likely effects as a result of the Proposed Development has taken into account both the Demolition and Construction Phases and Operational phases. The significance level attributed to each effect has been assessed based on the magnitude of change due to the Proposed Development and the sensitivity of the affected receptor/receiving environmental to change, as well as a number of other factors that are outlined in more detail in Chapter 2: Approach to Assessment. 12.6.2 Magnitude of change and the sensitivity of the affected receptor/receiving environmental are both assessed on a scale of high, medium, low and negligible (as shown in Chapter 2: Approach to Assessment). Daylight, Sunlight and Sun on Ground 12.6.3 The BRE Guidelines are predicated upon a suburban environment. Therefore, a degree of flexibility should be applied when assessing the significance of daylight and sunlight effects in urban locations. 12.6.4 The BRE Guidelines state at paragraph H3 – H4 of Appendix H: “H3 Adverse effects occur when there is a significant decrease in the amount of skylight and sunlight reaching an existing building where it is required, or in the amount of sunlight reaching an open space H4 The assessment of effect will depend on a combination of factors, and there is no simple rule of thumb that can be applied.”
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12.6.5 In view of the above, the interpretation of the daylight and sunlight results must be assessed in terms of the quantum of light lost or gained, not purely in terms of the percentage of change. The percentage value may well be misleading, particularly where the baseline values are small. In these situations, a small change in the quantum of light could represent a high percentage change in the overall figure, implying that there would be a significant change in daylight and sunlight, whereas in reality the difference would be negligible. 12.6.6 The numerical criteria provided within the BRE Guidelines are presented in Table 12.2 below: Table 12.2 – Daylight, Sunlight and Sun on Ground Criteria for Existing Surrounding Residential Properties Issue
BRE Criteria
Vertical Sky Component
A window may be adversely affected if the VSC measured at the centre of the window is less than 27% and less than 0.8 times its former value.
No Sky Line
A room may be adversely affected if the daylight distribution (no sky line) is reduced beyond 0.8 times its existing area.
Annual Probable Sunlight Hours
A window may be adversely affected if a point at the centre of the window receives for the whole year, less than 25% of the APSH including at least 5% of the APSH during the winter months (21 September to 21 March) and less than 0.8 times its former sunlight hours during either period, and (for existing neighbouring buildings), if there is a reduction in total APSH which is greater than 4%.
Sun on Ground
An existing garden or amenity area may be adversely affected if it cannot receive two hours of sunlight on 21st March and is less than 0.8 times its former value.
12.6.7 The assessment criteria specified within the BRE Guidelines where a change in daylight and/or sunlight may be noticeable to the occupants, and do not further define effects beyond this. 12.6.8 However, in urban locations where the proposed site is either currently undeveloped or contains relatively low structures, reductions of daylight and sunlight beyond the BRE guidelines as a result of redevelopments such as this are considered likely. This is because the existing levels of daylight and sunlight can be high and applying the BRE Guidelines 20% reduction rule can still result in a level above what is considered a good level of daylight or sunlight for an urban area. 12.6.9 The above view is supported by the BRE Guidelines which recognises that it may not be appropriate to apply the general guidance but set alternative target values based on the locality of the proposed site. 12.6.10 The scale of these reductions/effect have been described as negligible, minor, moderate or major by reference to the criteria summarised within Table 12.3 below, with moderate or major effects considered to be significant: Table 12.3 - Daylight, Sunlight and Sun on Ground Significance Criteria Significance Level
Criteria
Major Adverse
VSC, NSL & APSH
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Significance Level
Criteria Total loss or major/substantial alteration to key elements/features of the baseline (pre-Development) conditions such that the post Development character/composition/attributes will be fundamentally changed. Major infringements (40%+) of the numerical values suggested within the BRE Guidelines. Retained VSC levels below 15%. VSC, NSL & APSH
Moderate Adverse
Loss or alteration to one or more key elements/features of the baseline conditions such that post Development character/composition/attributes of the baseline will be materially changed. Moderate infringements (30.1% - 40%) of the numerical values suggested in the BRE Guidelines. Retained VSC levels greater than 15.01% but less than 17.9% VSC, NSL & APSH A minor shift away from baseline conditions. Change arising from the loss/alteration will be discernible/detectable but not material.
Minor Adverse
The underlying character/composition/attributes of the baseline condition will be similar to the pre-Development circumstances/situation. Marginal infringements (20.1% - 30%) of the numerical values suggested in the BRE Guidelines. Retained VSC levels greater than 18% but less than 19.9%. VSC, NSL & APSH
Negligible
Very little change from baseline conditions. Change barely distinguishable, approximating to a ‘no change’ situation. No alteration or a small alteration from the existing baseline conditions which is within the numerical levels suggested in the BRE Guidelines. Retained VSC levels 20% or greater
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12.6.11 The assessment criteria specified within the BRE Guidelines only suggests where a change in daylight and/or sunlight may be noticeable to the occupants. It does not further define effects beyond this. 12.6.12 Generally, ‘Negligible’ and ‘Minor’ effects are ‘not significant’. ‘Moderate’ or ‘Major’ effects are ‘significant’. 12.6.13 The significance table above provides categorical thresholds and criteria for which the extent of possible changes is perceived. The significance should be used in conjunction with the results discussion and the application of the BRE Guidelines’ Appendix F: Alternative Target Values. 12.6.14 The numerical criteria provided within the BRE Guidelines are presented in Table 12.3 above. 12.6.15 In relation to the VSC, the BRE Guidelines, as a general rule, suggest that 27% is the target and that if this level of daylight is not achieved, the occupants may notice a loss of light if there is more than a 20% reduction from the existing condition. The BRE Guidelines, however, recognise that the target of 27% is not always suitable, especially in urban areas. It is, therefore, often appropriate to consider alternative target values for the first daylight test. 12.6.16 In respect Table 12.3 above, and recognising the weight of the retained values, the effect of the Proposed Development upon the daylight and sunlight amenity to the properties surrounding the site is considered to be permanent, direct and of minor adverse in situations where: •
Despite VSC alterations to the windows serving the room, the NSL alterations to the room is fully BRE compliant and at least 20% VSC is retained by the main window/s; and;
•
Despite NSL alterations to the room, the VSC alteration to all windows serving the room is fully BRE compliant or at least 20% VSC retained by the main window/s; and
•
All the VSC and NSL alterations applicable to the room are no greater than the 30% of their baseline values or, if not, the room’s main window/s retain at least 20% VSC or at least 66% (two-thirds) of the room area can still benefit from direct skylight at working plan height (NSL).
•
Despite Winter APSH alteration to the assessed room, the Annual APSH alteration to the room is fully BRE compliant or the affected room retains an Annual APSH of at least 20%.
Solar Glare 12.6.17 Solar glare is not a comparative measure and the fact that it may occur in a baseline position would not justify the potential for solar glare from a development. As such, the effect of the Proposed Development has been considered as an absolute measurement and not as a relative measurement related to solar glare occurring in the baseline position. 12.6.18 There are no quantitative criteria within the BRE regarding acceptable levels of solar reflectance. There is, however, research which suggests that the significance of a glare occurrence is largely dependent upon its angle from the line of sight and the relevance of this with respect to the human field of vision: Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12:Daylight, Sunlight and Overshadowing
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“The fovea centralis, also generally known as the fovea, is a part of the eye, located in the centre of the macula region of the retina. The fovea is responsible for sharp central vision (also called foveal vision), which is necessary in humans for reading, watching television or movies, driving, and any activity where visual detail is of primary importance.” 3
12.6.19 With reference to Figure 10.2 below, glare occurrences that could encroach on the foveal view (3° from the visual axis) are likely to cause significant visual impairment or distraction. It is also likely that the viewer’s line of sight will vary from the chosen view direction at each viewpoint. To account for this, along with the likely range of movement of the eye, it is considered that lengthy occurrences within approximately 10° of the centre of the visual axis are potentially the most hazardous. In this scenario, the adverse impact would often be considered major and mitigation would be required. 12.6.20 Between 10° and 30° corresponds to Near Periphery field of view and therefore where glare occurs between these angles, the impact would be considered minor or moderate depending upon the location and use of the adjacent sensitive receptor, and the period of time the glare occurs for. 12.6.21 An angle of greater than 30° corresponds to the Far Periphery field of view and, therefore, the risk of reflective solar glare causing a hazard is reduced. As such, the impact would be considered to be of minor or negligible impact (not significant). 12.6.22 To understand the overall effect throughout the year at each assessment point identified for detailed analysis, all of the potential instances of glare, their duration, and their relative angle as seen from the assessment point are plotted onto a grid, creating the Calendar Graphs for each point. The criteria used to assess how far an effect on solar glare deviates from the baseline condition, i.e. the magnitude of change, are described in Table 10.8. Table 12.4 Criteria for Determining Magnitude of Change / Impact (Solar Glare) Magnitude
3
Criteria
Large
Solar reflections are visible within 3° of the viewer’s line of sight. Or lengthy occurrences between 3° and 10°
Medium
Lengthy occurrences of solar reflections are visible between 10° and 30° from the viewer’s line of sight. Or limited occurrences between 3° and 10°
Small
Limited solar reflections are visible between 10° and 30° from the viewer’s line of sight
Negligible
Solar reflections occurring at angles of greater than 30° from the viewer’s line of sight
B. Colbert, et al., Anatomy, Physiology, and Disease, An Interactive Journey for Health Professions, 1st edition, 2016
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Figure 12.3 - Regions Within Human Binocular Field of View
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Light Pollution 12.6.23 Light Pollution is not a comparative measure and the fact that light pollution may occur in a baseline position would not necessarily justify the potential for light pollution from a development. As such, the effect of the Proposed Development in terms of light pollution has been considered as an absolute measurement and not as a relative measurement related to light pollution occurring in the baseline position. 12.6.24 Furthermore, the ILP Guidance used to guide the methodology of the assessment of light spill makes no reference to the effect of the occurrence of light pollution. As a result, the effect of light pollution from the Proposed Development is based on Point 2’s experience and professional judgment based on the number of residential windows impacted and the degree to which thresholds defined in the ILP Guidance are breached. 12.6.25 The ILP Guidance provides definitions of Environmental Zones which themselves then provide recommended maximum levels of light spill pre- and post-curfew which have been used to define the criteria for assessment. The Proposed Development is deemed to be in an E4 environmental zone, i.e. in an urban surrounding, with high district brightness and typical of town/city centres with high levels of night-time activity. 12.6.26 On the basis the ILP guidance suggests that 25 lux is an acceptable level of illuminance pre-curfew, Table 12.5 provides guidance on how the scale of effects have been determined. Consideration is also given to the extent of the residential façades adversely affected. It is assumed that post-curfew the building will predominantly be unoccupied. As such lights will be switched off and therefore there will be minimal light spillage. Table 12.5 Criteria for Determining Magnitude of Change / Impact (Light Pollution) Magnitude
Criteria
Large
Level of illuminance pre-curfew is >45 lux
Medium
Level of illuminance pre-curfew is between 35 lux and 45 lux
Small
Level of illuminance pre-curfew is between 25 lux and 35 lux
Negligible
Level of illuminance pre-curfew is <25 lux
Effect Significance 12.6.27
• • • •
The following terms have been used to define the significance of effects identified:
Major positive or negative effect – where the Proposed Development would cause a large improvement (or deterioration) to the existing environment; Moderate positive or negative effect – where the Proposed Development would cause a noticeable improvement (or deterioration) to the existing environment; Minor positive or negative effect – where the Proposed Development would cause a small improvement (or deterioration) to the existing environment; and Negligible – no discernible improvement or deterioration to the existing environment as a result of the development will occur.
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12.7 Sensitive Receptors 12.7.1 The assessments undertaken within this ES chapter will be primarily based on the Building Research Establishment (BRE) guidelines entitled ‘Site layout planning for daylight and sunlight: a guide to good practice’ (referred to as the ‘BRE guidelines’), as well as any relevant national, regional or local planning policies. Daylight and Sunlight 12.7.2 In accordance with the BRE guidelines, the potential sensitive receptors to daylight and sunlight reductions are the surrounding residential properties and within these the habitable rooms. All receptors assessed are therefore considered to be of high sensitivity. In accordance with the BRE guidelines, commercial/retail uses, and non-habitable rooms are not considered to have a reasonable expectation of daylight or sunlight and will therefore not be assessed. 12.7.3 The properties identified as having a reasonable expectation for daylight and sunlight amenity have been established using desktop research of the London Borough of Lewisham online planning applications database and the Valuation Office Agency’s online database of property council tax bands. 12.7.4 Based on professional opinion and initial calculations undertaken during the design phases, we have deemed that the sensitive receptors (the surrounding existing residential properties and amenity spaces) that require detailed assessment within the ES Chapter include the following: (the locations are shown in Figure 12.4). 1. Isabella Apartments, 102 Granville Park 2. 25-31 Lewisham Shopping Centre (odd only) 3. 1-23 Cressingham Road 4. St. Stephens Church Vicarage, Cressingham Road 5. 1-19 Stephens Grove 6. 1-5 Lockmead Road (odd only) 7. 1 & 3 Boyne Road 8. 20-27 Granville Grove 9. 65-71 Lewisham High Street 10. 85 Lewisham High Street, 1-3 Belmont Hill 11. 2-9 Belmont Hill 12. 1-21 Lee High Road 13. 1 Lewis Grove 14. 1-23 Mercia Grove 15. 2&4 Albion Way 16. 1-8 Bonfield Road 17. 131-141 Lewisham High Street (odd only) 18. 151-171 Lewisham High Street (odd only) 19. St. Saviours Church, 175 Lewisham High Street 20. 187-211 Lewisham High Street (odd only) 21. 226-230 Lewisham High Street 22. Riverdale House, 68 Molesworth Street 23. Mill Apartments, 68 Molesworth Street 24. 1-23 Odell Walk (odd only) 25. 2-14 Odell Walk 26. Bellflower Court, Odell Walk 27. 1-15 Bankside Avenue 28. 1-13 Yew Tree Close (odd only) 29. 2-10 Yew Tree Close (even only) 30. 1-7 Elder Walk 31. Mill House, Elder Walk Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12:Daylight, Sunlight and Overshadowing
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32. Venice Corte, 2 Elmira Street 33. Torre Vista, 45 Loampit Vale 34. Sienna Alto, 2 Cornmill Lane 35. Glass Mill Leisure Centre, 41 Loampit Vale 36. Lewisham Gateway 37. 50-118 Lewisham High Street (even only) 38. 174-176 Lewisham High Street 39. 198-206 Lewisham High Street 40. 117-129 Lewisham High Street (odd only) 41. 85-99 Lewisham High Street (odd only)
Figure12. 4 – Location of Sensitive Receptors (shown highlighted in black)
Light Pollution 12.7.5 The locations at which baseline levels were measured are shown below in 0 as numbers. The viewpoints shown in the results of the analysis are shown on the same image as numbers; the plots of these viewpoints show the effect of the potential light spill on the receptors.
Figure 12. 5 – Location of Sensitive Receptors assessed for Light Pollution Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12:Daylight, Sunlight and Overshadowing
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Table 12.6 - Views for Light Pollution Receptor
View
Sensitivity
Land Use
50-70 Lewisham High Street
E01
High
Residential
86-118 Lewisham High Street
E02
High
Residential
73-85 Lewisham High Street
V01
High
Residential
1-21 Lee High Road
V02
High
Residential
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Solar Glare 12.7.6 Analysis of the likely potential for solar glare to arise has been undertaken and commentary provided on the likelihood of some glare occurring at the locations identified as important locations for the consideration of solar glare. These locations can be seen in Error! Reference source not found. and are listed below in 0. Table 12.7 - Solar Glare Receptor Locations Location
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12:Daylight, Sunlight and Overshadowing
View
Sensitivity
1
High
2
High
3
High
4
High
5
High
Plowman Craven 46730 October 2024
12.8 Baseline Conditions 12.8.1 This section outlines the existing baseline conditions of the Site. 12.8.2 A 3D model of the existing baseline scenario was constructed. Detailed drawings of this scenario assessment model can be found at Appendix 12.1. The drawings in Appendix 12.1 also illustrate the location of the surrounding residential properties in relation to the Site. 12.8.3 The model was analysed in order to ascertain the baseline levels of daylight and sunlight amenity within the surrounding residential properties against the minimum recommended values recommended in the BRE Guidelines. Baseline VSC 12.8.4 The baseline VSC conditions were assessed. Full detailed results can be found in Appendix 12.2. These are summarised in Table 12.4. Table 12.4 - Summary of Baseline VSC Results BASELINE VSC SUMMARY Address
No. of Windows that meet VSC criterion (>27%)
No. of Windows
% BRE Compliant
Isabella Apartments, 102 Granville Park
23
40
58
25 Lewisham High Street
1
7
14
27 Lewisham High Street
0
6
0
29 Lewisham High Street
0
6
0
31 Lewisham High Street
3
9
33
1 Cressingham Road
8
9
89
3 Cressingham Road
4
5
80
5 Cressingham Road
4
5
80
7 Cressingham Road
4
5
80
9 Cressingham Road
4
5
80
11 Cressingham Road
4
5
80
13 Cressingham Road
4
5
80
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE VSC SUMMARY Address
No. of Windows that meet VSC criterion (>27%)
No. of Windows
% BRE Compliant
15 Cressingham Road
4
5
80
17 Cressingham Road
5
6
83
19 Cressingham Road
4
5
80
21 Cressingham Road
8
10
80
23 Cressingham Road
5
6
83
16 Cressingham Road
6
8
75
14 Cressingham Road
6
9
67
12 Cressingham Road
6
9
67
10 Cressingham Road
6
9
67
8 Cressingham Road
5
8
63
6 Cressingham Road
5
8
63
4 Cressingham Road
5
8
63
2 Cressingham Road
3
8
38
St Stephens Church Vicarage, Cressingham Road
13
23
57
1 Stephens Grove
3
5
60
2 Stephens Grove
3
5
60
3 Stephens Grove
3
5
60
4 Stephens Grove
3
5
60
5 Stephens Grove
3
5
60
6 Stephens Grove
3
5
60
7 Stephens Grove
3
5
60
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE VSC SUMMARY Address
No. of Windows that meet VSC criterion (>27%)
No. of Windows
% BRE Compliant
8 Stephens Grove
4
5
80
1 Lockmead Road
5
5
100
3 Lockmead Road
5
5
100
5 Lockmead Road
6
7
86
3 Boyne Road
4
6
67
1 Boyne Road
5
9
56
9 Stephens Grove
7
8
88
10 Stephens Grove
5
5
100
11 Stephens Grove
4
5
80
12 Stephens Grove
5
5
100
13 Stephens Grove
5
5
100
14 Stephens Grove
5
5
100
15 Stephens Grove
5
5
100
16 Stephens Grove
4
5
80
17 Stephens Grove
3
5
60
18 Stephens Grove
3
5
60
19 Stephens Grove
3
5
60
19 Granville Grove
3
5
60
20 Granville Grove
3
5
60
21 Granville Grove
3
5
60
22 Granville Grove
3
5
60
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE VSC SUMMARY Address
No. of Windows that meet VSC criterion (>27%)
No. of Windows
% BRE Compliant
23 Granville Grove
3
5
60
24 Granville Grove
3
5
60
25 Granville Grove
3
5
60
27 Granville Grove
7
10
70
65-71 Lewisham High Street
25
44
57
85 Lewisham High Street, 1-3 Belmont Hill
13
13
100
5 Belmont Hill
2
2
100
7-9 Belmont Hill
2
2
100
2-4 Belmont Hill
7
29
24
1 Lee High Road
17
21
81
3-5 Lee High Road
3
5
60
7 Lee High Road
6
6
100
9 Lee High Road
2
2
100
11-13 Lee High Road
3
3
100
15 Lee High Road
2
2
100
17 Lee High Road
9
9
100
19 Lee High Road
3
5
60
21 Lee High Road
3
7
43
14-16 Lee High Road
12
16
75
4-6 Lee High Road
15
16
94
1 Lewis Grove
6
6
100
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE VSC SUMMARY Address
No. of Windows that meet VSC criterion (>27%)
No. of Windows
% BRE Compliant
1 Mercia Grove
4
7
57
2 Mercia Grove
5
7
71
3 Mercia Grove
7
8
88
4 Mercia Grove
6
7
86
5 Mercia Grove
6
7
86
6 Mercia Grove
5
7
71
7 Mercia Grove
6
7
86
8 Mercia Grove
6
7
86
9 Mercia Grove
6
7
86
10 Mercia Grove
7
9
78
11 Mercia Grove
5
7
71
12 Mercia Grove
6
10
60
13 Mercia Grove
7
10
70
14 Mercia Grove
5
7
71
15 Mercia Grove
6
7
86
16 Mercia Grove
4
6
67
17 Mercia Grove
6
7
86
18 Mercia Grove
6
9
67
19 Mercia Grove
6
7
86
20 Mercia Grove
6
7
86
21 Mercia Grove
6
7
86
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE VSC SUMMARY Address
No. of Windows that meet VSC criterion (>27%)
No. of Windows
% BRE Compliant
23 Merci Grove
64
65
98
4 Albion Way
9
10
90
2 Albion Way
10
12
83
8 Bonfield Road
2
4
50
7 Bonfield Road
8
9
89
6 Bonfield Road
2
5
40
5 Bonfield Road
4
6
67
4 Bonfield Road
4
7
57
3 Bonfield Road
4
7
57
2 Bonfield Road
3
7
43
1 Bonfield Road
4
9
44
131-133 Lewisham High Street
35
43
81
135 Lewisham High Street
2
2
100
137 Lewisham High Street
2
2
100
139-141 Lewisham High Street
9
14
64
153 Lewisham High Street
6
8
75
155 Lewisham High Street
19
44
43
161 Lewisham High Street
6
7
86
163 Lewisham High Street
6
6
100
165 Lewisham High Street
4
6
67
167 Lewisham High Street
4
6
67
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE VSC SUMMARY Address
No. of Windows that meet VSC criterion (>27%)
No. of Windows
% BRE Compliant
169 Lewisham High Street
4
4
100
171 Lewisham High Street
4
4
100
St Saviours Church, 175 Lewisham High Street
5
23
22
187 Lewisham High Street
6
6
100
189 Lewisham High Street
5
5
100
191-193 Lewisham High Street
8
10
80
195 Lewisham High Street
4
5
80
197 Lewisham High Street
16
30
53
203 Lewisham High Street
9
9
100
205 Lewisham High Street
12
17
71
207 Lewisham High Street
9
9
100
209-211 Lewisham High Street
17
18
94
226-230 Lewisham High Street
41
52
79
Riverdale House, 68 Molesworth Street
162
286
57
Mill Apartments, 68 Molesworth Street
40
66
61
23 Odell Walk
3
3
100
21 Odell Walk
3
3
100
19 Odell Walk
3
3
100
17 Odell Walk
3
3
100
15 Odell Walk
3
3
100
13 Odell Walk
3
3
100
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE VSC SUMMARY Address
No. of Windows that meet VSC criterion (>27%)
No. of Windows
% BRE Compliant
11 Odell Walk
3
3
100
9 Odell Walk
3
3
100
7 Odell Walk
3
3
100
5 Odell Walk
3
3
100
3 Odell Walk
3
3
100
1 Odell Walk
1
3
33
Bellflower Court, Odell Walk
12
20
60
14 Odell Walk
7
8
88
12 Odell Walk
7
8
88
10 Odell Walk
7
8
88
8 Odell Walk
6
8
75
6 Odell Walk
6
8
75
4 Odell Walk
6
8
75
2 Odell Walk
6
8
75
1 Bankside Avenue
4
4
100
2 Bankside Avenue
4
4
100
3 Bankside Avenue
4
4
100
4 Bankside Avenue
3
4
75
5 Bankside Avenue
2
4
50
6 Bankside Avenue
8
8
100
1 Yew Tree Close
6
6
100
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE VSC SUMMARY Address
No. of Windows that meet VSC criterion (>27%)
No. of Windows
% BRE Compliant
3 Yew Tree Close
6
6
100
5 Yew Tree Close
6
6
100
7 Yew Tree Close
6
6
100
9 Yew Tree Close
6
6
100
11 Yew Tree Close
6
6
100
13 Yew Tree Close
6
6
100
10 Yew Tree Close
6
8
75
8 Yew Tree Close
6
8
75
6 Yew Tree Close
5
8
63
4 Yew Tree Close
5
8
63
2 Yew Tree Close
5
8
63
7 Bankside Avenue
8
8
100
8 Bankside Avenue
2
4
50
9 Bankside Avenue
4
4
100
10 Bankside Avenue
4
4
100
11 Bankside Avenue
4
4
100
12 Bankside Avenue
4
4
100
13 Bankside Avenue
3
4
75
14 Bankside Avenue
2
4
50
15 Bankside Avenue
5
8
63
1 Elder Walk
3
6
50
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE VSC SUMMARY Address
No. of Windows that meet VSC criterion (>27%)
No. of Windows
% BRE Compliant
3 Elder Walk
5
6
83
5 Elder Walk
5
6
83
7 Elder Walk
6
7
86
Mill House, Elder Walk
28
111
25
Venice Corte, 2 Elmira Street
71
226
31
Torre Vista, 45 Loampit Vale
90
150
60
Sienna Alto, 2 Cornmill Lane
44
424
10
Glass Mill Leisure Centre, 41 Loampit Vale
1
1
100
Lewisham Gateway (Under Construction)
321
657
49
50 Lewisham High Street
2
8
25
52 Lewisham High Street
2
7
29
58-60 Lewisham High Street
3
8
38
66 Lewisham High Street
1
8
13
86-88 Lewisham High Street
1
15
7
90 Lewisham High Street
1
4
25
92 Lewisham High Street
2
4
50
94 Lewisham High Street
1
4
25
96 Lewisham High Street
0
2
0
98 Lewisham High Street
0
7
0
116-118 Lewisham High Street
2
11
18
174-176 Lewisham High Street
3
6
50
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE VSC SUMMARY Address
No. of Windows that meet VSC criterion (>27%)
No. of Windows
% BRE Compliant
198-206 Lewisham High Street
9
11
82
129 Lewisham High Street
9
9
100
127 Lewisham High Street
6
6
100
125 Lewisham High Street
8
8
100
123 Lewisham High Street
8
8
100
121 Lewisham High Street
6
6
100
117-119 Lewisham High Street
4
8
50
97-99 Lewisham High Street
14
25
56
93-95 Lewisham High Street
40
56
71
85-87 Lewisham High Street
63
71
89
110 Lewisham High Street
2
4
50
112 Lewisham High Street
2
3
67
114 Lewisham High Street
1
6
17
Total
2052
3737
55
12.8.5 The VSC baseline results show that in the current situation, 55% of the surrounding properties benefit from at least 27% VSC which is in accordance with the BRE guidelines. Baseline NSL 12.8.6 The baseline NSL conditions of the same properties included within the VSC baseline were assessed. Full detailed results can be found in Appendix 12.2 These are summarised in Table 12.5.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Table 12.5 - Summary of Baseline NSL Results BASELINE NSL SUMMARY Address
No. of Rooms that Receive NSL in excess of 80%
No. of Rooms
% BRE Compliant
Isabella Apartments, 102 Granville Park
28
28
100
25 Lewisham High Street
1
4
25
27 Lewisham High Street
0
4
0
29 Lewisham High Street
0
4
0
31 Lewisham High Street
5
6
83
1 Cressingham Road
5
7
71
3 Cressingham Road
3
4
75
5 Cressingham Road
3
4
75
7 Cressingham Road
3
4
75
9 Cressingham Road
2
4
50
11 Cressingham Road
2
4
50
13 Cressingham Road
2
4
50
15 Cressingham Road
2
4
50
17 Cressingham Road
3
5
60
19 Cressingham Road
2
4
50
21 Cressingham Road
8
10
80
23 Cressingham Road
3
4
75
16 Cressingham Road
5
6
83
14 Cressingham Road
2
6
33
12 Cressingham Road
2
6
33
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE NSL SUMMARY Address
No. of Rooms that Receive NSL in excess of 80%
No. of Rooms
% BRE Compliant
10 Cressingham Road
2
6
33
8 Cressingham Road
2
6
33
6 Cressingham Road
2
6
33
4 Cressingham Road
2
6
33
2 Cressingham Road
5
6
83
St Stephens Church Vicarage, Cressingham Road
9
10
90
1 Stephens Grove
2
3
67
2 Stephens Grove
2
3
67
3 Stephens Grove
2
3
67
4 Stephens Grove
2
3
67
5 Stephens Grove
2
3
67
6 Stephens Grove
2
3
67
7 Stephens Grove
2
3
67
8 Stephens Grove
2
3
67
1 Lockmead Road
3
3
100
3 Lockmead Road
3
3
100
5 Lockmead Road
3
3
100
3 Boyne Road
3
3
100
1 Boyne Road
3
3
100
9 Stephens Grove
5
5
100
10 Stephens Grove
5
5
100
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE NSL SUMMARY Address
No. of Rooms that Receive NSL in excess of 80%
No. of Rooms
% BRE Compliant
11 Stephens Grove
5
5
100
12 Stephens Grove
5
5
100
13 Stephens Grove
5
5
100
14 Stephens Grove
5
5
100
15 Stephens Grove
5
5
100
16 Stephens Grove
5
5
100
17 Stephens Grove
4
5
80
18 Stephens Grove
3
5
60
19 Stephens Grove
5
5
100
19 Granville Grove
3
3
100
20 Granville Grove
3
3
100
21 Granville Grove
3
3
100
22 Granville Grove
3
3
100
23 Granville Grove
3
3
100
24 Granville Grove
3
3
100
25 Granville Grove
3
3
100
27 Granville Grove
6
6
100
65-71 Lewisham High Street
18
20
90
85 Lewisham High Street, 1-3 Belmont Hill
3
4
75
5 Belmont Hill
2
2
100
7-9 Belmont Hill
2
2
100
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE NSL SUMMARY Address
No. of Rooms that Receive NSL in excess of 80%
No. of Rooms
% BRE Compliant
2-4 Belmont Hill
7
14
50
1 Lee High Road
7
10
70
3-5 Lee High Road
2
3
67
7 Lee High Road
4
4
100
9 Lee High Road
1
1
100
11-13 Lee High Road
3
3
100
15 Lee High Road
1
1
100
17 Lee High Road
4
4
100
19 Lee High Road
4
4
100
21 Lee High Road
6
6
100
14-16 Lee High Road
10
10
100
4-6 Lee High Road
12
12
100
1 Lewis Grove
3
4
75
1 Mercia Grove
5
5
100
2 Mercia Grove
4
5
80
3 Mercia Grove
5
5
100
4 Mercia Grove
4
5
80
5 Mercia Grove
4
5
80
6 Mercia Grove
4
5
80
7 Mercia Grove
4
5
80
8 Mercia Grove
4
5
80
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE NSL SUMMARY Address
No. of Rooms that Receive NSL in excess of 80%
No. of Rooms
% BRE Compliant
9 Mercia Grove
4
5
80
10 Mercia Grove
5
5
100
11 Mercia Grove
4
5
80
12 Mercia Grove
3
3
100
13 Mercia Grove
3
3
100
14 Mercia Grove
4
4
100
15 Mercia Grove
6
6
100
16 Mercia Grove
4
4
100
17 Mercia Grove
4
4
100
18 Mercia Grove
6
6
100
19 Mercia Grove
5
5
100
20 Mercia Grove
4
5
80
21 Mercia Grove
5
6
83
23 Merci Grove
29
29
100
4 Albion Way
6
6
100
2 Albion Way
7
7
100
8 Bonfield Road
3
3
100
7 Bonfield Road
4
4
100
6 Bonfield Road
3
4
75
5 Bonfield Road
5
5
100
4 Bonfield Road
4
5
80
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE NSL SUMMARY Address
No. of Rooms that Receive NSL in excess of 80%
No. of Rooms
% BRE Compliant
3 Bonfield Road
5
6
83
2 Bonfield Road
4
6
67
1 Bonfield Road
6
6
100
131-133 Lewisham High Street
26
26
100
135 Lewisham High Street
2
2
100
137 Lewisham High Street
2
2
100
139-141 Lewisham High Street
7
10
70
153 Lewisham High Street
4
4
100
155 Lewisham High Street
11
13
85
161 Lewisham High Street
2
4
50
163 Lewisham High Street
2
3
67
165 Lewisham High Street
2
3
67
167 Lewisham High Street
2
3
67
169 Lewisham High Street
3
3
100
171 Lewisham High Street
3
4
75
St Saviours Church, 175 Lewisham High Street
9
13
69
187 Lewisham High Street
6
6
100
189 Lewisham High Street
5
5
100
191-193 Lewisham High Street
10
10
100
195 Lewisham High Street
5
5
100
197 Lewisham High Street
16
20
80
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE NSL SUMMARY Address
No. of Rooms that Receive NSL in excess of 80%
No. of Rooms
% BRE Compliant
203 Lewisham High Street
6
6
100
205 Lewisham High Street
6
7
86
207 Lewisham High Street
3
3
100
209-211 Lewisham High Street
9
9
100
226-230 Lewisham High Street
43
52
83
Riverdale House, 68 Molesworth Street
180
187
96
Mill Apartments, 68 Molesworth Street
27
30
90
23 Odell Walk
2
2
100
21 Odell Walk
2
2
100
19 Odell Walk
2
2
100
17 Odell Walk
2
2
100
15 Odell Walk
2
2
100
13 Odell Walk
2
2
100
11 Odell Walk
2
2
100
9 Odell Walk
2
2
100
7 Odell Walk
2
2
100
5 Odell Walk
2
2
100
3 Odell Walk
2
2
100
1 Odell Walk
2
2
100
Bellflower Court, Odell Walk
12
12
100
14 Odell Walk
5
5
100
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE NSL SUMMARY Address
No. of Rooms that Receive NSL in excess of 80%
No. of Rooms
% BRE Compliant
12 Odell Walk
5
5
100
10 Odell Walk
5
5
100
8 Odell Walk
5
5
100
6 Odell Walk
5
5
100
4 Odell Walk
4
5
80
2 Odell Walk
5
5
100
1 Bankside Avenue
4
4
100
2 Bankside Avenue
4
4
100
3 Bankside Avenue
4
4
100
4 Bankside Avenue
4
4
100
5 Bankside Avenue
2
4
50
6 Bankside Avenue
6
6
100
1 Yew Tree Close
4
4
100
3 Yew Tree Close
4
4
100
5 Yew Tree Close
3
4
75
7 Yew Tree Close
3
4
75
9 Yew Tree Close
3
4
75
11 Yew Tree Close
3
4
75
13 Yew Tree Close
3
4
75
10 Yew Tree Close
5
5
100
8 Yew Tree Close
5
5
100
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE NSL SUMMARY Address
No. of Rooms that Receive NSL in excess of 80%
No. of Rooms
% BRE Compliant
6 Yew Tree Close
5
5
100
4 Yew Tree Close
5
5
100
2 Yew Tree Close
5
5
100
7 Bankside Avenue
6
6
100
8 Bankside Avenue
2
4
50
9 Bankside Avenue
4
4
100
10 Bankside Avenue
4
4
100
11 Bankside Avenue
4
4
100
12 Bankside Avenue
4
4
100
13 Bankside Avenue
4
4
100
14 Bankside Avenue
2
4
50
15 Bankside Avenue
6
6
100
1 Elder Walk
3
4
75
3 Elder Walk
4
4
100
5 Elder Walk
4
4
100
7 Elder Walk
3
4
75
Mill House, Elder Walk
85
95
89
Venice Corte, 2 Elmira Street
85
174
49
Torre Vista, 45 Loampit Vale
107
126
85
Sienna Alto, 2 Cornmill Lane
177
177
100
Glass Mill Leisure Centre, 41 Loampit Vale
1
1
100
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE NSL SUMMARY Address
No. of Rooms that Receive NSL in excess of 80%
No. of Rooms
% BRE Compliant
Lewisham Gateway (Under Construction)
311
391
80
50 Lewisham High Street
1
5
20
52 Lewisham High Street
4
7
57
58-60 Lewisham High Street
4
6
67
66 Lewisham High Street
3
6
50
86-88 Lewisham High Street
4
14
29
90 Lewisham High Street
0
2
0
92 Lewisham High Street
2
3
67
94 Lewisham High Street
0
4
0
96 Lewisham High Street
0
2
0
98 Lewisham High Street
1
6
17
116-118 Lewisham High Street
5
11
45
174-176 Lewisham High Street
6
6
100
198-206 Lewisham High Street
11
11
100
129 Lewisham High Street
5
5
100
127 Lewisham High Street
3
3
100
125 Lewisham High Street
3
3
100
123 Lewisham High Street
3
3
100
121 Lewisham High Street
3
3
100
117-119 Lewisham High Street
3
4
75
97-99 Lewisham High Street
4
7
57
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE NSL SUMMARY Address
No. of Rooms that Receive NSL in excess of 80%
No. of Rooms
% BRE Compliant
93-95 Lewisham High Street
26
27
96
85-87 Lewisham High Street
9
10
90
110 Lewisham High Street
2
3
67
112 Lewisham High Street
2
2
100
114 Lewisham High Street
5
5
100
Total
1927
2327
83
12.8.7 The NSL baseline results show that in the current situation 83% of the rooms within the surrounding properties benefit from direct skylight at working plane height to in excess of 80% of the room area which is in accordance with the BRE guidelines. Baseline APSH 12.8.8 The baseline APSH conditions of those properties which have windows which are orientated to within 90⁰ of due south were assessed. Full detailed results can be found in Appendix 12.2 These are summarised in Table 12.6. Table 12.6 - Summary of Baseline APSH Results BASELINE ROOM APSH SUMMARY Address
No. of Rooms that Meet APSH Criteria
No. of Rooms
% BRE Compliant
Isabella Apartments, 102 Granville Park
20
28
71
25 Lewisham High Street
4
4
100
27 Lewisham High Street
3
4
75
29 Lewisham High Street
4
4
100
31 Lewisham High Street
6
6
100
1 Cressingham Road
7
7
100
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE ROOM APSH SUMMARY Address
No. of Rooms that Meet APSH Criteria
No. of Rooms
% BRE Compliant
3 Cressingham Road
4
4
100
5 Cressingham Road
4
4
100
7 Cressingham Road
4
4
100
9 Cressingham Road
4
4
100
11 Cressingham Road
4
4
100
13 Cressingham Road
4
4
100
15 Cressingham Road
4
4
100
17 Cressingham Road
5
5
100
19 Cressingham Road
4
4
100
21 Cressingham Road
10
10
100
23 Cressingham Road
4
4
100
16 Cressingham Road
6
6
100
14 Cressingham Road
6
6
100
12 Cressingham Road
6
6
100
10 Cressingham Road
6
6
100
8 Cressingham Road
6
6
100
6 Cressingham Road
6
6
100
4 Cressingham Road
6
6
100
2 Cressingham Road
6
6
100
St Stephens Church Vicarage, Cressingham Road
10
10
100
1 Stephens Grove
3
3
100
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE ROOM APSH SUMMARY Address
No. of Rooms that Meet APSH Criteria
No. of Rooms
% BRE Compliant
2 Stephens Grove
3
3
100
3 Stephens Grove
3
3
100
4 Stephens Grove
3
3
100
5 Stephens Grove
3
3
100
6 Stephens Grove
3
3
100
7 Stephens Grove
3
3
100
8 Stephens Grove
3
3
100
1 Lockmead Road
3
3
100
3 Lockmead Road
3
3
100
5 Lockmead Road
3
3
100
3 Boyne Road
3
3
100
1 Boyne Road
3
3
100
9 Stephens Grove
5
5
100
10 Stephens Grove
5
5
100
11 Stephens Grove
5
5
100
12 Stephens Grove
5
5
100
13 Stephens Grove
5
5
100
14 Stephens Grove
5
5
100
15 Stephens Grove
5
5
100
16 Stephens Grove
5
5
100
17 Stephens Grove
4
5
80
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE ROOM APSH SUMMARY Address
No. of Rooms that Meet APSH Criteria
No. of Rooms
% BRE Compliant
18 Stephens Grove
4
5
80
19 Stephens Grove
4
5
80
19 Granville Grove
3
3
100
20 Granville Grove
3
3
100
21 Granville Grove
3
3
100
22 Granville Grove
3
3
100
23 Granville Grove
3
3
100
24 Granville Grove
3
3
100
25 Granville Grove
3
3
100
27 Granville Grove
6
6
100
65-71 Lewisham High Street
16
20
80
85 Lewisham High Street, 1-3 Belmont Hill
4
4
100
5 Belmont Hill
2
2
100
7-9 Belmont Hill
2
2
100
2-4 Belmont Hill
1
1
100
1 Lee High Road
3
3
100
3-5 Lee High Road
2
2
100
7 Lee High Road
4
4
100
9 Lee High Road
1
1
100
11-13 Lee High Road
3
3
100
15 Lee High Road
1
1
100
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE ROOM APSH SUMMARY Address
No. of Rooms that Meet APSH Criteria
No. of Rooms
% BRE Compliant
17 Lee High Road
3
3
100
19 Lee High Road
3
3
100
21 Lee High Road
5
6
83
14-16 Lee High Road
9
9
100
4-6 Lee High Road
6
6
100
1 Lewis Grove
2
2
100
1 Mercia Grove
3
3
100
2 Mercia Grove
3
3
100
3 Mercia Grove
3
3
100
4 Mercia Grove
3
3
100
5 Mercia Grove
3
3
100
6 Mercia Grove
3
3
100
7 Mercia Grove
3
3
100
8 Mercia Grove
3
3
100
9 Mercia Grove
3
3
100
10 Mercia Grove
4
4
100
11 Mercia Grove
3
3
100
12 Mercia Grove
2
2
100
13 Mercia Grove
2
2
100
14 Mercia Grove
2
2
100
15 Mercia Grove
2
2
100
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE ROOM APSH SUMMARY Address
No. of Rooms that Meet APSH Criteria
No. of Rooms
% BRE Compliant
16 Mercia Grove
2
2
100
17 Mercia Grove
2
2
100
18 Mercia Grove
4
4
100
19 Mercia Grove
2
2
100
20 Mercia Grove
2
2
100
21 Mercia Grove
3
3
100
23 Merci Grove
11
11
100
4 Albion Way
3
3
100
2 Albion Way
3
3
100
8 Bonfield Road
1
1
100
6 Bonfield Road
0
1
0
4 Bonfield Road
2
2
100
2 Bonfield Road
2
3
67
131-133 Lewisham High Street
12
12
100
139-141 Lewisham High Street
6
6
100
155 Lewisham High Street
11
13
85
St Saviours Church, 175 Lewisham High Street
2
2
100
197 Lewisham High Street
3
3
100
205 Lewisham High Street
2
2
100
226-230 Lewisham High Street
21
25
84
Riverdale House, 68 Molesworth Street
33
34
97
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE ROOM APSH SUMMARY Address
No. of Rooms that Meet APSH Criteria
No. of Rooms
% BRE Compliant
Mill Apartments, 68 Molesworth Street
19
20
95
14 Odell Walk
3
3
100
12 Odell Walk
3
3
100
10 Odell Walk
3
3
100
8 Odell Walk
3
3
100
6 Odell Walk
3
3
100
4 Odell Walk
3
3
100
2 Odell Walk
3
3
100
1 Bankside Avenue
4
4
100
2 Bankside Avenue
4
4
100
3 Bankside Avenue
4
4
100
4 Bankside Avenue
4
4
100
5 Bankside Avenue
4
4
100
6 Bankside Avenue
4
4
100
1 Yew Tree Close
2
2
100
3 Yew Tree Close
2
2
100
5 Yew Tree Close
2
2
100
7 Yew Tree Close
2
2
100
9 Yew Tree Close
2
2
100
11 Yew Tree Close
2
2
100
13 Yew Tree Close
2
2
100
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE ROOM APSH SUMMARY Address
No. of Rooms that Meet APSH Criteria
No. of Rooms
% BRE Compliant
10 Yew Tree Close
3
3
100
8 Yew Tree Close
3
3
100
6 Yew Tree Close
3
3
100
4 Yew Tree Close
3
3
100
2 Yew Tree Close
3
3
100
7 Bankside Avenue
6
6
100
8 Bankside Avenue
4
4
100
9 Bankside Avenue
4
4
100
10 Bankside Avenue
4
4
100
11 Bankside Avenue
4
4
100
12 Bankside Avenue
4
4
100
13 Bankside Avenue
4
4
100
14 Bankside Avenue
4
4
100
15 Bankside Avenue
4
4
100
1 Elder Walk
2
2
100
3 Elder Walk
2
2
100
5 Elder Walk
2
2
100
7 Elder Walk
2
2
100
Mill House, Elder Walk
44
47
94
Venice Corte, 2 Elmira Street
52
60
87
Sienna Alto, 2 Cornmill Lane
147
177
83
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
BASELINE ROOM APSH SUMMARY Address
No. of Rooms that Meet APSH Criteria
No. of Rooms
% BRE Compliant
Glass Mill Leisure Centre, 41 Loampit Vale
1
1
100
Lewisham Gateway (Under Construction)
309
391
79
50 Lewisham High Street
4
5
80
52 Lewisham High Street
6
7
86
58-60 Lewisham High Street
6
6
100
66 Lewisham High Street
3
6
50
86-88 Lewisham High Street
14
14
100
90 Lewisham High Street
2
2
100
92 Lewisham High Street
2
3
67
129 Lewisham High Street
4
4
100
117-119 Lewisham High Street
2
2
100
97-99 Lewisham High Street
2
2
100
93-95 Lewisham High Street
11
11
100
85-87 Lewisham High Street
5
5
100
Total
1260
1416
89
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
12.8.9 The APSH baseline results show that in the current situation 89% of the rooms within the surrounding properties benefit from at least 25% total APSH, of which at least 5% APSH are in the winter months. According to the BRE Guidelines this is sufficient to give reasonable sunlight amenity results in a suburban environment. The APSH assessment takes into account sunlight amenity to all windows serving a room, which means that those windows where sky visibility is obscured by surrounding buildings are mitigated by other windows serving the room. Baseline Sun on Ground 12.8.10 The baseline Sun on Ground of the public amenity spaces and the residential gardens were assessed in March and June, the location of these can be seen in Figure 12.5. Full detailed results can be seen in Appendix 12.4 Figure 12.5 - Location of Public and Private Amenity Spaces Considered for Sun on Ground Assessments
12.8.11 The majority of the considered surrounding amenity spaces record existing values far exceeding the BRE’s target 50% area that receives at least 2 hours in sunlight on March 21st. The following Table 12.7 provides a summary of the existing spaces that meet the BRE’s target value.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Table 12.7 – Summary of Existing Baseline Sun on Ground Results
Existing Sun Hours on Ground
Assessment Date
No. of Assessed Amenity Spaces
No. Assessed Amenity Spaces Meeting BRE Target
% amenity spaces >50% Surface are that receives 5 hours in sunlight
March 21st
221
144
65
12.8.12 The above results show that 114 of the 221 areas (65%) currently enjoy good levels of sunlight above that recommended by the BRE guidelines. 12.8.13 The isolated amenity spaces that fall below the sunlight levels recommended by the BRE Guidelines are listed below. 1. River Mill One Station Road 2. 1 Cressingham Road 3. 28 Limes Grove 4. 29 Limes Grove 5. 3 Cressingham Road 6. 5 Cressingham Road 7. 7 Cressingham Road 8. 8 Mill House, Odell Walk 9. 9 Cressingham Road 10. 10 Mill House, Odell Walk 11. 12 Mill House, Odell Walk 12. 11 Cressingham Road 13. 13 Cressingham Road
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
14. 15 Cressingham Road 15. 14 Bankside Avenue 16. 1 Smead Way 17. 56 Elmira Street 18. 17 Cressingham Road 19. 31 Waterway Avenue 20. 25 Waterway Avenue 21. 23 Waterway Avenue 22. 21 Waterway Avenue 23. 19 Waterway Avenue 24. 19 Cressingham Road 25. 9 Pine Tree Way 26. 16 Pine Tree Way 27. 15 Waterway Avenue 28. 13 Waterway Avenue 29. 15 lewisham High Street 30. 39 Elmira Street 31. 5 Waterway Avenue 32. 7 Waterway Avenue 33. 9 Waterway Avenue 34. 11 Waterway Avenue 35. 13 Waterway Avenue 36. St. Stephens Church North 37. 46 Elmira Street
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
38. 48 Elmira Street 39. 62-64 Lewisham High Street (1) 40. 62-64 Lewisham High Street (2) 41. 62-64 Lewisham High Street (3) 42. 62-64 Lewisham High Street (4) 43. 62-64 Lewisham High Street (5) 44. 6 Cressingham Road 45. 8 Stephens Grove 46. 7 Stephens Grove 47. 6 Stephens Grove 48. 5 Stephens Grove 49. 4 Stpehens Grove 50. 3 Stephens Grove 51. 2 Stephens Grove 52. 1 Stephens Grove 53. 19 Stephens Grove 54. 17 Stephens Grove 55. 15 Stephens Grove 56. 27 Granville Grove 57. 26 Granville Grove 58. 25 Granville Grove 59. 24 Granville Grove
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
60. 23 Granville Grove 61. 22 Granville Grove 62. 21 Granville Grove 63. 20 Granville Grove 64. 19 Granville Grove 65. Lewisham Station
Police
66. 1 Mercia Grove 67. 2 Mercia Grove 68. 3 Mercia Grove 69. 4 Mercia Grove 70. 5 Mercia Grove 71. 6 Mercia Grove 72. 1a Cressingham Road 73. 197 Lewisham Street
High
74. 3 Limes Grove 75. 5 Limes Grove 76. 7 Limes Grove 77. 9 Limes Grove
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
12.9 Assessment of Effects, Mitigation and Residual Effects Demolition & Construction Phase Assessment of Effects 12.9.1 This section identifies and assesses the scale and nature of the main effects arising from the Proposed Development during the construction phase. 12.9.2 Effects in relation to daylight, sunlight, overshadowing, solar glare and light pollution will vary throughout the demolition and construction phase. 12.9.3 There will be no notable anticipated effect whilst the existing buildings on the Site are demolished. There will also be no anticipated effect following the completion of the demolition of the buildings. During the construction of the Development, the effects would be no worse than those of the completed Development as set out below. For those residents, who would be living in the initial phases of the Development (completed blocks of the detailed element of the Development), during the construction of the outline element of the Development, they would enjoy higher levels of daylight/sunlight which will gradually reduce during the course of construction until they reach the residual levels derived from the Completed Development. Mitigation and Residual Effects 12.9.4 No mitigation measures are considered necessary as the effects would develop to those of the completed Development, as described below. The residual effect would therefore remain as described below. Therefore, the mitigation and residual effects are the same as reported in the main assessment below. Operational Phase 12.9.5 This section identifies and assesses the scale and nature of the main effects arising from the Proposed Development during the operational phase. Assessment of Effects Daylight to Surrounding Properties 12.9.6 The effects discussed below consider the Maximum Parameter Masterplan Proposal, that include the detailed elements of the application (Block N1 and Block N2) in situ. The Maximum Parameter Scheme was assessed against the surrounding baseline conditions. 12.9.7 There are 3,737 windows serving 2,327 residential rooms within the assessed properties surrounding the Site. These have all been assessed in terms of both VSC and NSL. Full detailed results can be found at Appendices 12.3 and are summarised in Table 12.8 and Table 12.9 and show those properties that record full BRE compliance, in respect of the VSC and NSL, highlighted in green.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Table 12.8 – VSC Summary with the Development in Place VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Windows
Isabella Apartments, 102 Granville Park
40
0
0
0
0
40
25 Lewisham High Street
7
0
0
0
0
7
27 Lewisham High Street
6
0
0
0
0
6
29 Lewisham High Street
6
0
0
0
0
6
31 Lewisham High Street
9
0
0
0
0
9
1 Cressingham Road
9
0
0
0
0
9
3 Cressingham Road
5
0
0
0
0
5
5 Cressingham Road
5
0
0
0
0
5
7 Cressingham Road
5
0
0
0
0
5
9 Cressingham Road
5
0
0
0
0
5
11 Cressingham Road
5
0
0
0
0
5
13 Cressingham Road
5
0
0
0
0
5
15 Cressingham Road
5
0
0
0
0
5
17 Cressingham Road
6
0
0
0
0
6
19 Cressingham Road
5
0
0
0
0
5
21 Cressingham Road
10
0
0
0
0
10
23 Cressingham Road
6
0
0
0
0
6
16 Cressingham Road
8
0
0
0
0
8
14 Cressingham Road
9
0
0
0
0
9
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Windows
12 Cressingham Road
9
0
0
0
0
9
10 Cressingham Road
9
0
0
0
0
9
8 Cressingham Road
8
0
0
0
0
8
6 Cressingham Road
8
0
0
0
0
8
4 Cressingham Road
8
0
0
0
0
8
2 Cressingham Road
8
0
0
0
0
8
St Stephens Church Vicarage, Cressingham Road
23
0
0
0
0
23
1 Stephens Grove
5
0
0
0
0
5
2 Stephens Grove
4
0
0
1
1
5
3 Stephens Grove
5
0
0
0
0
5
4 Stephens Grove
4
0
0
1
1
5
5 Stephens Grove
5
0
0
0
0
5
6 Stephens Grove
4
0
0
1
1
5
7 Stephens Grove
5
0
0
0
0
5
8 Stephens Grove
4
0
0
1
1
5
1 Lockmead Road
5
0
0
0
0
5
3 Lockmead Road
5
0
0
0
0
5
5 Lockmead Road
7
0
0
0
0
7
3 Boyne Road
6
0
0
0
0
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Windows
1 Boyne Road
9
0
0
0
0
9
9 Stephens Grove
8
0
0
0
0
8
10 Stephens Grove
5
0
0
0
0
5
11 Stephens Grove
5
0
0
0
0
5
12 Stephens Grove
5
0
0
0
0
5
13 Stephens Grove
5
0
0
0
0
5
14 Stephens Grove
5
0
0
0
0
5
15 Stephens Grove
5
0
0
0
0
5
16 Stephens Grove
5
0
0
0
0
5
17 Stephens Grove
5
0
0
0
0
5
18 Stephens Grove
5
0
0
0
0
5
19 Stephens Grove
5
0
0
0
0
5
19 Granville Grove
5
0
0
0
0
5
20 Granville Grove
4
0
1
0
1
5
21 Granville Grove
5
0
0
0
0
5
22 Granville Grove
4
0
0
1
1
5
23 Granville Grove
5
0
0
0
0
5
24 Granville Grove
4
0
0
1
1
5
25 Granville Grove
5
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Windows
27 Granville Grove
9
0
0
1
1
10
65-71 Lewisham High Street
40
4
0
0
4
44
85 Lewisham High Street, 1-3 Belmont Hill
13
0
0
0
0
13
5 Belmont Hill
2
0
0
0
0
2
7-9 Belmont Hill
2
0
0
0
0
2
2-4 Belmont Hill
29
0
0
0
0
29
1 Lee High Road
21
0
0
0
0
21
3-5 Lee High Road
5
0
0
0
0
5
7 Lee High Road
6
0
0
0
0
6
9 Lee High Road
2
0
0
0
0
2
11-13 Lee High Road
3
0
0
0
0
3
15 Lee High Road
2
0
0
0
0
2
17 Lee High Road
9
0
0
0
0
9
19 Lee High Road
5
0
0
0
0
5
21 Lee High Road
7
0
0
0
0
7
14-16 Lee High Road
16
0
0
0
0
16
4-6 Lee High Road
16
0
0
0
0
16
1 Lewis Grove
6
0
0
0
0
6
1 Mercia Grove
7
0
0
0
0
7
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Windows
2 Mercia Grove
7
0
0
0
0
7
3 Mercia Grove
8
0
0
0
0
8
4 Mercia Grove
7
0
0
0
0
7
5 Mercia Grove
7
0
0
0
0
7
6 Mercia Grove
7
0
0
0
0
7
7 Mercia Grove
7
0
0
0
0
7
8 Mercia Grove
7
0
0
0
0
7
9 Mercia Grove
7
0
0
0
0
7
10 Mercia Grove
9
0
0
0
0
9
11 Mercia Grove
7
0
0
0
0
7
12 Mercia Grove
10
0
0
0
0
10
13 Mercia Grove
10
0
0
0
0
10
14 Mercia Grove
7
0
0
0
0
7
15 Mercia Grove
7
0
0
0
0
7
16 Mercia Grove
6
0
0
0
0
6
17 Mercia Grove
7
0
0
0
0
7
18 Mercia Grove
9
0
0
0
0
9
19 Mercia Grove
7
0
0
0
0
7
20 Mercia Grove
7
0
0
0
0
7
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Windows
21 Mercia Grove
7
0
0
0
0
7
23 Merci Grove
65
0
0
0
0
65
4 Albion Way
10
0
0
0
0
10
2 Albion Way
12
0
0
0
0
12
8 Bonfield Road
4
0
0
0
0
4
7 Bonfield Road
9
0
0
0
0
9
6 Bonfield Road
5
0
0
0
0
5
5 Bonfield Road
6
0
0
0
0
6
4 Bonfield Road
7
0
0
0
0
7
3 Bonfield Road
7
0
0
0
0
7
2 Bonfield Road
7
0
0
0
0
7
1 Bonfield Road
9
0
0
0
0
9
131-133 Lewisham High Street
41
2
0
0
2
43
135 Lewisham High Street
0
2
0
0
2
2
137 Lewisham High Street
0
2
0
0
2
2
139-141 Lewisham High Street
8
6
0
0
6
14
153 Lewisham High Street
0
4
4
0
8
8
155 Lewisham High Street
24
6
11
3
20
44
161 Lewisham High Street
1
3
3
0
6
7
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Windows
163 Lewisham High Street
0
3
3
0
6
6
165 Lewisham High Street
0
3
1
2
6
6
167 Lewisham High Street
0
3
2
1
6
6
169 Lewisham High Street
1
1
2
0
3
4
171 Lewisham High Street
1
2
1
0
3
4
St Saviours Church, 175 Lewisham High Street
8
6
7
2
15
23
187 Lewisham High Street
0
2
4
0
6
6
189 Lewisham High Street
0
1
4
0
5
5
191-193 Lewisham High Street
0
5
5
0
10
10
195 Lewisham High Street
1
4
0
0
4
5
197 Lewisham High Street
25
5
0
0
5
30
203 Lewisham High Street
9
0
0
0
0
9
205 Lewisham High Street
17
0
0
0
0
17
207 Lewisham High Street
9
0
0
0
0
9
209-211 Lewisham High Street
18
0
0
0
0
18
226-230 Lewisham High Street
52
0
0
0
0
52
Riverdale House, 68 Molesworth Street
98
10
18
160
188
286
Mill Apartments, 68 Molesworth Street
45
7
0
14
21
66
23 Odell Walk
0
3
0
0
3
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Windows
21 Odell Walk
0
3
0
0
3
3
19 Odell Walk
1
2
0
0
2
3
17 Odell Walk
1
2
0
0
2
3
15 Odell Walk
1
2
0
0
2
3
13 Odell Walk
1
2
0
0
2
3
11 Odell Walk
0
3
0
0
3
3
9 Odell Walk
0
3
0
0
3
3
7 Odell Walk
0
3
0
0
3
3
5 Odell Walk
0
3
0
0
3
3
3 Odell Walk
0
3
0
0
3
3
1 Odell Walk
0
3
0
0
3
3
Bellflower Court, Odell Walk
4
16
0
0
16
20
14 Odell Walk
5
1
2
0
3
8
12 Odell Walk
5
2
1
0
3
8
10 Odell Walk
5
2
1
0
3
8
8 Odell Walk
5
3
0
0
3
8
6 Odell Walk
5
3
0
0
3
8
4 Odell Walk
5
3
0
0
3
8
2 Odell Walk
5
3
0
0
3
8
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Windows
1 Bankside Avenue
1
3
0
0
3
4
2 Bankside Avenue
0
4
0
0
4
4
3 Bankside Avenue
2
2
0
0
2
4
4 Bankside Avenue
2
2
0
0
2
4
5 Bankside Avenue
2
2
0
0
2
4
6 Bankside Avenue
4
4
0
0
4
8
1 Yew Tree Close
3
3
0
0
3
6
3 Yew Tree Close
3
3
0
0
3
6
5 Yew Tree Close
3
3
0
0
3
6
7 Yew Tree Close
3
3
0
0
3
6
9 Yew Tree Close
3
1
2
0
3
6
11 Yew Tree Close
3
1
2
0
3
6
13 Yew Tree Close
3
1
2
0
3
6
10 Yew Tree Close
5
0
3
0
3
8
8 Yew Tree Close
5
0
3
0
3
8
6 Yew Tree Close
5
2
1
0
3
8
4 Yew Tree Close
5
3
0
0
3
8
2 Yew Tree Close
5
3
0
0
3
8
7 Bankside Avenue
5
2
1
0
3
8
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Windows
8 Bankside Avenue
1
2
1
0
3
4
9 Bankside Avenue
0
1
3
0
4
4
10 Bankside Avenue
0
0
4
0
4
4
11 Bankside Avenue
0
0
4
0
4
4
12 Bankside Avenue
0
0
4
0
4
4
13 Bankside Avenue
0
2
2
0
4
4
14 Bankside Avenue
0
2
2
0
4
4
15 Bankside Avenue
4
0
3
1
4
8
1 Elder Walk
3
3
0
0
3
6
3 Elder Walk
3
3
0
0
3
6
5 Elder Walk
3
3
0
0
3
6
7 Elder Walk
5
2
0
0
2
7
Mill House, Elder Walk
94
7
0
10
17
111
Venice Corte, 2 Elmira Street
209
16
1
0
17
226
Torre Vista, 45 Loampit Vale
143
7
0
0
7
150
Sienna Alto, 2 Cornmill Lane
328
54
36
6
96
424
Glass Mill Leisure Centre, 41 Loampit Vale
1
0
0
0
0
1
Lewisham Gateway (Under Construction)
463
31
55
108
194
657
50 Lewisham High Street
2
0
0
6
6
8
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Windows
52 Lewisham High Street
0
0
0
7
7
7
58-60 Lewisham High Street
3
0
0
5
5
8
66 Lewisham High Street
0
0
0
8
8
8
86-88 Lewisham High Street
3
1
6
5
12
15
90 Lewisham High Street
0
0
0
4
4
4
92 Lewisham High Street
1
1
0
2
3
4
94 Lewisham High Street
1
1
2
0
3
4
96 Lewisham High Street
0
0
0
2
2
2
98 Lewisham High Street
0
1
4
2
7
7
116-118 Lewisham High Street
1
0
0
10
10
11
174-176 Lewisham High Street
0
0
0
6
6
6
198-206 Lewisham High Street
0
0
0
11
11
11
129 Lewisham High Street
7
2
0
0
2
9
127 Lewisham High Street
0
6
0
0
6
6
125 Lewisham High Street
0
8
0
0
8
8
123 Lewisham High Street
0
8
0
0
8
8
121 Lewisham High Street
0
6
0
0
6
6
117-119 Lewisham High Street
2
4
0
2
6
8
97-99 Lewisham High Street
19
6
0
0
6
25
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Total that Meet BRE Guidelines
Address
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Windows
93-95 Lewisham High Street
50
6
0
0
6
56
85-87 Lewisham High Street
66
5
0
0
5
71
110 Lewisham High Street
0
0
0
4
4
4
112 Lewisham High Street
0
0
0
3
3
3
114 Lewisham High Street
0
0
0
6
6
6
Total
2753
376
211
397
984
3737
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Rooms
Isabella Apartments, 102 Granville Park
28
0
0
0
0
28
25 Lewisham High Street
4
0
0
0
0
4
27 Lewisham High Street
4
0
0
0
0
4
29 Lewisham High Street
4
0
0
0
0
4
31 Lewisham High Street
6
0
0
0
0
6
1 Cressingham Road
7
0
0
0
0
7
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Rooms
3 Cressingham Road
4
0
0
0
0
4
5 Cressingham Road
4
0
0
0
0
4
7 Cressingham Road
4
0
0
0
0
4
9 Cressingham Road
4
0
0
0
0
4
11 Cressingham Road
4
0
0
0
0
4
13 Cressingham Road
4
0
0
0
0
4
15 Cressingham Road
4
0
0
0
0
4
17 Cressingham Road
5
0
0
0
0
5
19 Cressingham Road
4
0
0
0
0
4
21 Cressingham Road
10
0
0
0
0
10
23 Cressingham Road
4
0
0
0
0
4
16 Cressingham Road
6
0
0
0
0
6
14 Cressingham Road
6
0
0
0
0
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Rooms
12 Cressingham Road
6
0
0
0
0
6
10 Cressingham Road
6
0
0
0
0
6
8 Cressingham Road
6
0
0
0
0
6
6 Cressingham Road
6
0
0
0
0
6
4 Cressingham Road
6
0
0
0
0
6
2 Cressingham Road
6
0
0
0
0
6
St Stephens Church Vicarage, Cressingham Road
10
0
0
0
0
10
1 Stephens Grove
3
0
0
0
0
3
2 Stephens Grove
3
0
0
0
0
3
3 Stephens Grove
3
0
0
0
0
3
4 Stephens Grove
3
0
0
0
0
3
5 Stephens Grove
3
0
0
0
0
3
6 Stephens Grove
3
0
0
0
0
3
7 Stephens Grove
3
0
0
0
0
3
8 Stephens Grove
3
0
0
0
0
3
1 Lockmead Road
3
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Rooms
3 Lockmead Road
3
0
0
0
0
3
5 Lockmead Road
3
0
0
0
0
3
3 Boyne Road
3
0
0
0
0
3
1 Boyne Road
3
0
0
0
0
3
9 Stephens Grove
5
0
0
0
0
5
10 Stephens Grove
5
0
0
0
0
5
11 Stephens Grove
5
0
0
0
0
5
12 Stephens Grove
5
0
0
0
0
5
13 Stephens Grove
5
0
0
0
0
5
14 Stephens Grove
5
0
0
0
0
5
15 Stephens Grove
5
0
0
0
0
5
16 Stephens Grove
5
0
0
0
0
5
17 Stephens Grove
5
0
0
0
0
5
18 Stephens Grove
5
0
0
0
0
5
19 Stephens Grove
5
0
0
0
0
5
19 Granville Grove
3
0
0
0
0
3
20 Granville Grove
3
0
0
0
0
3
21 Granville Grove
3
0
0
0
0
3
22 Granville Grove
3
0
0
0
0
3
23 Granville Grove
3
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Rooms
24 Granville Grove
3
0
0
0
0
3
25 Granville Grove
3
0
0
0
0
3
27 Granville Grove
6
0
0
0
0
6
65-71 Lewisham High Street
20
0
0
0
0
20
85 Lewisham High Street, 1-3 Belmont Hill
4
0
0
0
0
4
5 Belmont Hill
2
0
0
0
0
2
7-9 Belmont Hill
2
0
0
0
0
2
2-4 Belmont Hill
14
0
0
0
0
14
1 Lee High Road
10
0
0
0
0
10
3-5 Lee High Road
3
0
0
0
0
3
7 Lee High Road
4
0
0
0
0
4
9 Lee High Road
1
0
0
0
0
1
11-13 Lee High Road
3
0
0
0
0
3
15 Lee High Road
1
0
0
0
0
1
17 Lee High Road
4
0
0
0
0
4
19 Lee High Road
4
0
0
0
0
4
21 Lee High Road
6
0
0
0
0
6
14-16 Lee High Road
10
0
0
0
0
10
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Rooms
4-6 Lee High Road
12
0
0
0
0
12
1 Lewis Grove
4
0
0
0
0
4
1 Mercia Grove
5
0
0
0
0
5
2 Mercia Grove
5
0
0
0
0
5
3 Mercia Grove
5
0
0
0
0
5
4 Mercia Grove
5
0
0
0
0
5
5 Mercia Grove
5
0
0
0
0
5
6 Mercia Grove
5
0
0
0
0
5
7 Mercia Grove
5
0
0
0
0
5
8 Mercia Grove
5
0
0
0
0
5
9 Mercia Grove
5
0
0
0
0
5
10 Mercia Grove
5
0
0
0
0
5
11 Mercia Grove
5
0
0
0
0
5
12 Mercia Grove
3
0
0
0
0
3
13 Mercia Grove
3
0
0
0
0
3
14 Mercia Grove
4
0
0
0
0
4
15 Mercia Grove
6
0
0
0
0
6
16 Mercia Grove
4
0
0
0
0
4
17 Mercia Grove
4
0
0
0
0
4
18 Mercia Grove
6
0
0
0
0
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Rooms
19 Mercia Grove
5
0
0
0
0
5
20 Mercia Grove
5
0
0
0
0
5
21 Mercia Grove
6
0
0
0
0
6
23 Merci Grove
29
0
0
0
0
29
4 Albion Way
6
0
0
0
0
6
2 Albion Way
7
0
0
0
0
7
8 Bonfield Road
3
0
0
0
0
3
7 Bonfield Road
4
0
0
0
0
4
6 Bonfield Road
4
0
0
0
0
4
5 Bonfield Road
5
0
0
0
0
5
4 Bonfield Road
5
0
0
0
0
5
3 Bonfield Road
6
0
0
0
0
6
2 Bonfield Road
6
0
0
0
0
6
1 Bonfield Road
6
0
0
0
0
6
131-133 Lewisham High Street
26
0
0
0
0
26
135 Lewisham High Street
1
1
0
0
1
2
137 Lewisham High Street
1
1
0
0
1
2
139-141 Lewisham High Street
8
2
0
0
2
10
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Rooms
153 Lewisham High Street
2
1
1
0
2
4
155 Lewisham High Street
10
3
0
0
3
13
161 Lewisham High Street
3
0
0
1
1
4
163 Lewisham High Street
1
1
0
1
2
3
165 Lewisham High Street
1
1
0
1
2
3
167 Lewisham High Street
1
1
0
1
2
3
169 Lewisham High Street
3
0
0
0
0
3
171 Lewisham High Street
1
2
0
1
3
4
St Saviours Church, 175 Lewisham High Street
7
2
3
1
6
13
187 Lewisham High Street
0
3
2
1
6
6
189 Lewisham High Street
2
3
0
0
3
5
191-193 Lewisham High Street
3
7
0
0
7
10
195 Lewisham High Street
3
2
0
0
2
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Rooms
197 Lewisham High Street
20
0
0
0
0
20
203 Lewisham High Street
6
0
0
0
0
6
205 Lewisham High Street
7
0
0
0
0
7
207 Lewisham High Street
3
0
0
0
0
3
209-211 Lewisham High Street
9
0
0
0
0
9
226-230 Lewisham High Street
52
0
0
0
0
52
Riverdale House, 68 Molesworth Street
98
38
18
33
89
187
Mill Apartments, 68 Molesworth Street
25
1
0
4
5
30
23 Odell Walk
2
0
0
0
0
2
21 Odell Walk
2
0
0
0
0
2
19 Odell Walk
2
0
0
0
0
2
17 Odell Walk
2
0
0
0
0
2
15 Odell Walk
2
0
0
0
0
2
13 Odell Walk
2
0
0
0
0
2
11 Odell Walk
2
0
0
0
0
2
9 Odell Walk
2
0
0
0
0
2
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Rooms
7 Odell Walk
2
0
0
0
0
2
5 Odell Walk
1
1
0
0
1
2
3 Odell Walk
1
1
0
0
1
2
1 Odell Walk
2
0
0
0
0
2
Bellflower Court, Odell Walk
12
0
0
0
0
12
14 Odell Walk
4
1
0
0
1
5
12 Odell Walk
3
2
0
0
2
5
10 Odell Walk
3
2
0
0
2
5
8 Odell Walk
4
1
0
0
1
5
6 Odell Walk
4
1
0
0
1
5
4 Odell Walk
4
1
0
0
1
5
2 Odell Walk
5
0
0
0
0
5
1 Bankside Avenue
2
2
0
0
2
4
2 Bankside Avenue
2
2
0
0
2
4
3 Bankside Avenue
2
2
0
0
2
4
4 Bankside Avenue
2
2
0
0
2
4
5 Bankside Avenue
3
1
0
0
1
4
6 Bankside Avenue
3
1
2
0
3
6
1 Yew Tree Close
4
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Rooms
3 Yew Tree Close
4
0
0
0
0
4
5 Yew Tree Close
4
0
0
0
0
4
7 Yew Tree Close
4
0
0
0
0
4
9 Yew Tree Close
4
0
0
0
0
4
11 Yew Tree Close
4
0
0
0
0
4
13 Yew Tree Close
3
1
0
0
1
4
10 Yew Tree Close
4
0
1
0
1
5
8 Yew Tree Close
4
1
0
0
1
5
6 Yew Tree Close
4
1
0
0
1
5
4 Yew Tree Close
5
0
0
0
0
5
2 Yew Tree Close
5
0
0
0
0
5
7 Bankside Avenue
4
1
1
0
2
6
8 Bankside Avenue
3
1
0
0
1
4
9 Bankside Avenue
0
2
1
1
4
4
10 Bankside Avenue
0
1
1
2
4
4
11 Bankside Avenue
0
1
1
2
4
4
12 Bankside Avenue
0
1
1
2
4
4
13 Bankside Avenue
0
2
0
2
4
4
14 Bankside Avenue
2
1
0
1
2
4
15 Bankside Avenue
2
2
0
2
4
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Rooms
1 Elder Walk
4
0
0
0
0
4
3 Elder Walk
4
0
0
0
0
4
5 Elder Walk
4
0
0
0
0
4
7 Elder Walk
4
0
0
0
0
4
Mill House, Elder Walk
91
4
0
0
4
95
Venice Corte, 2 Elmira Street
174
0
0
0
0
174
Torre Vista, 45 Loampit Vale
126
0
0
0
0
126
Sienna Alto, 2 Cornmill Lane
168
2
6
1
9
177
Glass Mill Leisure Centre, 41 Loampit Vale
1
0
0
0
0
1
Lewisham Gateway (Under Construction)
351
25
8
7
40
391
50 Lewisham High Street
0
2
1
2
5
5
52 Lewisham High Street
0
0
1
6
7
7
58-60 Lewisham High Street
2
1
1
2
4
6
66 Lewisham High Street
0
1
1
4
6
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Rooms
86-88 Lewisham High Street
2
1
1
10
12
14
90 Lewisham High Street
0
0
0
2
2
2
92 Lewisham High Street
0
0
1
2
3
3
94 Lewisham High Street
1
0
0
3
3
4
96 Lewisham High Street
0
0
0
2
2
2
98 Lewisham High Street
0
0
2
4
6
6
116-118 Lewisham High Street
1
0
0
10
10
11
174-176 Lewisham High Street
2
4
0
0
4
6
198-206 Lewisham High Street
0
0
0
11
11
11
129 Lewisham High Street
4
0
1
0
1
5
127 Lewisham High Street
2
0
1
0
1
3
125 Lewisham High Street
3
0
0
0
0
3
123 Lewisham High Street
3
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Rooms
121 Lewisham High Street
3
0
0
0
0
3
117-119 Lewisham High Street
0
0
0
4
4
4
97-99 Lewisham High Street
7
0
0
0
0
7
93-95 Lewisham High Street
27
0
0
0
0
27
85-87 Lewisham High Street
10
0
0
0
0
10
110 Lewisham High Street
0
0
0
3
3
3
112 Lewisham High Street
1
1
0
0
1
2
114 Lewisham High Street
0
0
0
5
5
5
Total
1992
145
56
134
335
2327
12.9.8 The BRE Guidelines state that: “…the diffuse daylighting of the existing building may be adversely affected if either the VSC measured at the centre of an existing main window is less than 27% and less than 0.8 times its former value [or] the area of the working plane in a room which can receive direct skylight is reduced to less than 0.8 times its former value.” 12.9.9 In situations where the Development would result in fully BRE compliant VSC and NSL alterations to the windows and rooms within a property, the effect on the daylight amenity to that property is considered to be of negligible significance. 12.9.10 The following properties will experience alterations which, in accordance with the BRE Guidelines, will not be noticeable to the occupants and therefore classified as negligible:
•
Isabella Apartments, 102 Granville Park
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
•
25 Lewisham High Street Plowman Craven 46730 October 2024
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •
27 Lewisham High Street 29 Lewisham High Street 31 Lewisham High Street 1 Cressingham Road 3 Cressingham Road 5 Cressingham Road 7 Cressingham Road 9 Cressingham Road 11 Cressingham Road 13 Cressingham Road 15 Cressingham Road 17 Cressingham Road 19 Cressingham Road 21 Cressingham Road 23 Cressingham Road 16 Cressingham Road 14 Cressingham Road 12 Cressingham Road 10 Cressingham Road 8 Cressingham Road 6 Cressingham Road 4 Cressingham Road 2 Cressingham Road St Stephens Church Vicarage, Cressingham Road 1 Stephens Grove 3 Stephens Grove 5 Stephens Grove 7 Stephens Grove 1 Lockmead Road 3 Lockmead Road 5 Lockmead Road 3 Boyne Road 1 Boyne Road 9 Stephens Grove 10 Stephens Grove 11 Stephens Grove 12 Stephens Grove 13 Stephens Grove 14 Stephens Grove 15 Stephens Grove 16 Stephens Grove
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •
17 Stephens Grove 18 Stephens Grove 19 Stephens Grove 19 Granville Grove 21 Granville Grove 23 Granville Grove 25 Granville Grove 85 Lewisham High Street, 1-3 Belmont Hill 5 Belmont Hill 7-9 Belmont Hill 2-4 Belmont Hill 1 Lee High Road 3-5 Lee High Road 7 Lee High Road 9 Lee High Road 11-13 Lee High Road 15 Lee High Road 17 Lee High Road 19 Lee High Road 21 Lee High Road 14-16 Lee High Road 4-6 Lee High Road 1 Lewis Grove 1 Mercia Grove 2 Mercia Grove 3 Mercia Grove 4 Mercia Grove 5 Mercia Grove 6 Mercia Grove 7 Mercia Grove 8 Mercia Grove 9 Mercia Grove 10 Mercia Grove 11 Mercia Grove 12 Mercia Grove 13 Mercia Grove 14 Mercia Grove 15 Mercia Grove 16 Mercia Grove 17 Mercia Grove 18 Mercia Grove 19 Mercia Grove Plowman Craven 46730 October 2024
• • • • • • • • • •
20 Mercia Grove 21 Mercia Grove 23 Merci Grove 4 Albion Way 2 Albion Way 8 Bonfield Road 7 Bonfield Road 6 Bonfield Road 5 Bonfield Road 4 Bonfield Road
• • • • • • • • • •
3 Bonfield Road 2 Bonfield Road 1 Bonfield Road 197 Lewisham High Street 203 Lewisham High Street 205 Lewisham High Street 207 Lewisham High Street 209-211 Lewisham High Street 226-230 Lewisham High Street Glass Mill Leisure Centre, 41 Loampit Vale
12.9.11 The effect on the daylight amenity of a property in an urban context is considered to be minor negative in situations where both the VSC and NSL alterations applicable to the room are no greater than 30% of their baseline values. 12.9.12 The following properties are therefore considered to experience reductions which are of minor negative significance:
• • • • • • • • • • • • • • • • • • • • • • •
2 Stephens Grove 4 Stephens Grove 6 Stephens Grove 8 Stephens Grove 20 Granville Grove 22 Granville Grove 24 Granville Grove 27 Granville Grove 65-71 Lewisham High Street 131-133 Lewisham High Street 135 Lewisham High Street 137 Lewisham High Street 139-141 Lewisham High Street 155 Lewisham High Street 169 Lewisham High Street 195 Lewisham High Street 23 Odell Walk 21 Odell Walk 19 Odell Walk 17 Odell Walk 15 Odell Walk 13 Odell Walk
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
• • • • • • • • • • • • • • • • • • • • • • •
11 Odell Walk 9 Odell Walk 7 Odell Walk 5 Odell Walk 3 Odell Walk 1 Odell Walk Bellflower Court, Odell Walk 14 Odell Walk 12 Odell Walk 10 Odell Walk 8 Odell Walk 6 Odell Walk 4 Odell Walk 2 Odell Walk 1 Bankside Avenue 2 Bankside Avenue 3 Bankside Avenue 4 Bankside Avenue 5 Bankside Avenue 1 Yew Tree Close 3 Yew Tree Close 5 Yew Tree Close 7 Yew Tree Close Plowman Craven 46730 October 2024
• • • • • • • • • •
9 Yew Tree Close 11 Yew Tree Close 8 Yew Tree Close 6 Yew Tree Close 4 Yew Tree Close 2 Yew Tree Close 7 Bankside Avenue 8 Bankside Avenue 1 Elder Walk 3 Elder Walk
• • • • • • • • • •
5 Elder Walk 7 Elder Walk Venice Corte, 2 Elmira Street Torre Vista, 45 Loampit Vale 125 Lewisham High Street 123 Lewisham High Street 121 Lewisham High Street 97-99 Lewisham High Street 93-95 Lewisham High Street 85-87 Lewisham High Street
12.9.13 The following properties experience daylight alterations beyond those described as negligible or minor (i.e. experience an effect which is either moderate or major negative) in accordance with Table 12.3 above and, therefore, are considered in more detail below: 110 Lewisham High Street
12.9.14 There are 4 windows serving 3 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.15 The VSC test shows that 0 out of 4 windows will meet the strict application of the BRE Guidelines. Each window serves a Living-Kitchen-Diner (LKD). The affected windows record light change >40% from former value. 12.9.16 The NSL test shows that 0 out of 3 rooms will meet the strict application of the BRE Guidelines. Each affected room records a light change >40% from former value. 12.9.17 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
112 Lewisham High Street
12.9.18 There are 3 windows serving 2 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.19 The result of the VSC test shows that 0 out of 3 windows will meet the strict application of the BRE Guidelines. Each affected room records a light change >40%, although the retained VSC values record 10%-14%. The isolated window (window ref: W1/8201) that records the lower retained VSC value serves a bedroom. It is acknowledged by the BRE Guidelines that this room classification does not carry the same expectation for natural light when compared to a living room. 12.9.20 The result of the NSL test shows that 1 out of 2 rooms will meet the strict application of the BRE Guidelines. The isolated affected room (room ref: R1/8201) records a light change of 28% from former value and is considered a minor alteration. This room is also a bedroom and is acknowledged to carry less expectation for natural light when compared to a living room. 12.9.21 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. 114 Lewisham High Street
12.9.22 There are 6 windows serving 5 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.23 The result of the VSC test shows that 0 out of 6 windows will meet the strict application of the BRE Guidelines. Each affected window records a light change >40% from former value. Of the affected windows, 3 record a retained VSC <10%. 12.9.24 The result of the NSL test shows that 0 out of 5 rooms will meet the strict application of the BRE Guidelines. The NSL test shows that each room records exceptionally high existing daylight values, considered uncharacteristic for an urban location. This is borne out of the existing Lewisham Shopping Centre being low-lying in nature. 12.9.25 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
116-118 Lewisham High Street
12.9.26 There are 11 windows serving 11 rooms within this building that have been considered in the technical assessments. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.27 The VSC test shows that 1 out of 11 windows will meet the strict application of the BRE Guidelines. The assessment shows that the 10 affected windows record light change >40% from former value. 12.9.28 The NSL test shows that 1 out of 11 rooms will meet the strict application of the BRE Guidelines. The assessment shows that the affected 10 rooms will record a light change >40% from former value. 12.9.29 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
165 Lewisham High Street 12.9.30 There 6 windows serving 3 rooms within this building that have been considered in the technical assessments. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.31 The VSC test shows that 0 out of 6 windows will meet the strict application of the BRE Guidelines. The assessment shows that 4 windows will retain VSC values that exceed >21% (and record light change <29.9% from former value) and is considered excellent for an urban location. The two remaining affected windows (window ref: W1/1182 & W2/1182) record retained VSC values of 2.8% and 14.68% respectively. W2/1182 falling marginally below the alternative mid-teen target value. 12.9.32 The NSL test shows that 1 out of 3 rooms will meet the strict application of the BRE Guidelines. The assessment shows that R1/1172 records a light change of 23.6% from former value and is considered minor in isolation. The remaining affected room (room ref: R1/1173) records light change >40% from former value. 12.9.33 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. 167 Lewisham High Street 12.9.34 There are 6 windows serving 3 rooms within this building that have been considered in the technical assessments. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.35 The VSC test shows that 0 out of 6 windows will meet the strict application of the BRE Guidelines. There are 4 affected windows that retain a VSC >21% (and record percentage light change <29.9% from former value) and is considered very good for an urban location. There is one window (window ref: W1/1172) that retains VSC 16% and is considered an acceptable retain level of daylight for an urban location. The remaining affected window records a light change >40% from former value. 12.9.36 The NSL test shows that 1 out of 3 rooms will meet the strict application of the BRE Guidelines. The assessment shows that R1/1172 records a light change of 29.7% from former value and is considered minor in isolation. The remaining affected room (room ref: R1/1173) records light change >40% from former value. 12.9.37 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
174-176 Lewisham High Street
12.9.38 There are 6 windows serving 6 rooms within this building that have been considered in the technical assessments. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.39 The VSC test shows that 0 out of 6 windows will meet the strict application of the BRE Guidelines. The results show that each affected window retains VSC values >10% but records a light change >40% from former value. 12.9.40 The NSL test shows that 2 out of 6 rooms will meet the strict application of the BRE Guidelines. Each affected rooms records a light change <26% from former value and is considered a minor alteration in isolation. 12.9.41 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. 198-206 Lewisham Shopping Centre
12.9.42 There are 12 windows serving 12 rooms within this building that have been considered in the technical assessments. This property is located on the southern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.43 The VSC test shows that 0 out of 12 windows will meet the strict application of the BRE Guidelines. The assessment shows that 8 windows will retain a VSC value >13% and is not uncommon for an urban location. Each affected window records a light change >40% from former value. 12.9.44 The NSL test shows that 0 out of 12 rooms will meet the strict application of the BRE Guidelines. The assessment shows that all affected rooms record existing NSL values >93% and is considered uncharacteristic for an urban location. The recorded percentage change from former value for each room is >40%. 12.9.45 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
50 Lewisham High Street
12.9.46 There are 8 windows serving 5 rooms within this building that have been considered in the technical assessments. This property is located on the north-eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.47 The VSC test shows that 2 out of 8 windows will meet the strict application of the BRE Guidelines. Of the affected, 2 windows record retained VSC values >22% and is considered very good for an urban setting. Each affected window records light change >40% from former value. 12.9.48 The NSL test shows that 0 out of 5 rooms will meet the strict application of the BRE Guidelines. A bedroom and a living kitchen diner record a light change of 27.4% and 24.2% from former value, respectively. The remaining rooms record a change >30% from former value. 12.9.49 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. 52 Lewisham High Street 12.9.50 There are 7 windows serving 7 rooms within this building that have been considered in the technical assessments. This property is located on the north-eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.51 The VSC test shows that 0 out of 7 windows will meet the strict application of the BRE Guidelines. The assessment shows that 2 windows (window ref: W1/7013 & W2/7013) record retained VSC values >21% and is considered very good for an urban environment. All affected windows record >40% change from former value. 12.9.52 The NSL test shows that 0 out of 7 rooms will meet the strict application of the BRE Guidelines. Each affected room records a light change >40% from former value. 12.9.53 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
58-60 Lewisham High Street
12.9.54 There are 8 windows serving 6 rooms within this building have been considered in the technical assessments. This property is located on the north-eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.55 The VSC test shows that 2 out of 8 windows will meet the strict application of the BRE Guidelines. Each affected window records a change in light >40% from former value. 12.9.56 The NSL test shows that 2 out of 6 rooms will meet the strict application of the BRE Guidelines. Of the affected rooms, 2 (room ref: R2/7031 & R2/7032) record a retained NSL value of 73% and 67% and is considered good and not uncommon for an urban setting. The remaining affected rooms record a light change >40% from former value. 12.9.57 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. 66 Lewisham High Street
12.9.58 There are 8 windows serving 6 rooms within this building that have been considered in the technical assessments. This property is located on the north-eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.59 The VSC test shows that 0 out of 8 windows will meet the strict application of the BRE Guidelines. Each affected window records a light change >40% from former value. 12.9.60 The NSL test shows that 0 out of 6 rooms will meet the strict application of the BRE Guidelines. Each affected room records a light change >40% from former value. 12.9.61 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
86-88 Lewisham High Street
12.9.62 There are 15 windows serving 14 rooms within this property that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.63 The VSC test shows that 3 out of 15 windows will meet the strict application of the BRE Guidelines. The assessment shows that the average retained VSC across all the considered windows is 15.19%. The analysis also shows that 9 affected windows record an absolute VSC change <8 with 3 of these windows recorded <4% absolute change. 12.9.64 The NSL test shows that 2 out of 14 rooms will meet the strict application of the BRE Guidelines. The assessment shows that each 10 out of 12 affected rooms record light change >40% from former value. 12.9.65 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. 90 Lewisham High Street
12.9.66 There are 4 windows serving 2 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.67 The VSC test shows that 0 out of 4 windows will meet the strict application of the BRE Guidelines. The assessment shows that the affected windows will record a light change >40% from former value and an average retained VSC of 13.15% is recorded. 12.9.68 The NSL test shows that 0 out of 2 rooms will meet the strict application of the BRE Guidelines. The assessment shows that both affected rooms, being a living room and a bedroom records light change >40% from former value. 12.9.69 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
92 Lewisham High Street
12.9.70 There are 4 windows serving 3 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.71 The VSC test shows that 1 out of 4 windows will meet the strict application of the BRE Guidelines. The average retained VSC across the assessed windows is 24%. Window W1/7141 records a light change 25% from former value, whereas the remaining affected windows record changes >40% from former value. 12.9.72 The NSL test shows that 0 out of 3 rooms will meet the strict application of the BRE Guidelines. The assessment shows that the affected rooms will record light change >35% from former value. 12.9.73 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. 94 Lewisham High Street
12.9.74 There are 4 windows serving 4 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.75 The VSC test shows that 1 out of 4 windows will meet the strict application of the BRE Guidelines. The assessment shows that the average retained VSC across the assessed windows is 24%. The affected windows record a percentage change between 27%-38% from former value. 12.9.76 The NSL test shows that 1 out of 4 rooms will meet the strict application of the BRE Guidelines. The assessment shows that each affected room records a light change >40% from former value. 12.9.77 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
96 Lewisham High Street
12.9.78 There are 2 windows serving 2 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.79 The VSC test shows that 0 out of 2 windows will meet the strict application of the BRE Guidelines. Window W1/7171 records an existing VSC of 2.5% and therefore any slight alteration from the baseline is likely to trigger a disproportionate change in light. The remaining affected window records a light change >40% from former value. 12.9.80 The NSL test shows that 0 out of 2 rooms will meet the strict application of the BRE Guidelines. The assessment shows that both rooms will records >40% change from former value. 12.9.81 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. 98 Lewisham High Street
12.9.82 There are 7 windows serving 6 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.9.83 The VSC test shows that 0 out of 7 windows will meet the strict application of the BRE Guidelines. The assessment shows that the affected windows retain an average VSC of 11.3% with 3 windows retaining daylight values between 13%-16.4%. 12.9.84 The NSL test shows that 0 out of 6 rooms will meet the strict application of the BRE Guidelines. The assessment shows that all affected rooms will record >40% change from former value. 12.9.85 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Lewisham Gateway 12.9.86 There are 657 windows serving 391 rooms within this building that have been considered in the technical assessments. It is noted that there are a number of windows / rooms that are served by projecting balconies and render the windows below the features sensitive to a change in their outlook. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment it is appropriate to apply alternative, less stringent, guidelines for windows that have an overhang (balconies above). 12.9.87 The VSC test shows that 463 out of 657 windows will meet the strict application of the BRE Guidelines. It is noted that The technical assessment shows that of the affected windows there are 133 windows that retain VSC values >15% (ranging to 26.94%) and is considered acceptable for an urban location. Of the 133 windows that retain VSC >15%, 102 windows retain >18% VSC. The VSC test also shows that there a number of affected windows that record low existing values in the baseline condition (<12%) and will be sensitive to minor alterations in their outlook and trigger disproportionate percentage changes in light. 12.9.88 The NSL test shows that 351 out of 391 rooms will meet the strict application of the BRE Guidelines. The technical assessment shows that the majority of transgressions (25 windows) record minor alterations beyond the permissible 20% change from former value and fall within 10% beyond the threshold. The majority of the remaining affected rooms (14 rooms) are bedrooms and is acknowledged by the BRE that this room classification does not carry the same expectation for natural light when compared to a living room. 12.9.89 The majority of windows and rooms are hindered by an overhang balcony or inset façade configuration to provide amenity space for the occupier. A trade-off should therefore be taken into consideration when forming a view between private amenity and daylight amenity. 12.9.90 That being said, there remain windows/rooms not positioned under a balcony or within the inset façade configuration that record BRE transgressions and thus the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. Mill Apartments, 68 Molesworth Street 12.9.91 There are 66 windows serving 30 rooms within this building that have been considered in the technical assessments. 12.9.92 The VSC test shows that 45 out of 66 windows will meet the strict application of the BRE Guidelines. The assessment shows that 7 affected windows record a light change <5% beyond the BRE’s permissible 20% change from former value. The technical analysis also confirms that of the 21 BRE transgressions, 13 rooms are bedrooms and is a classification acknowledged by the BRE Guidelines to carry the same expectation for natural light when compared to a living room. The average retained VSC values across those affected windows is 16.8%.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
12.9.93 The NSL test shows that 25 out of 30 rooms will meet the strict application of the BRE Guidelines. The assessment shows that 4 out of the 5 affected rooms are bedrooms; this classification is acknowledged to carry less expectation for natural light when compared to a living room. The remaining affected room is a kitchen, that records exceptionally high existing NSL value and records a light change >40% from former value. 12.9.94 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. Mill House, Elder Walk 12.9.95 There are 111 windows serving 95 rooms within this building that have been considered in the technical assessments. 12.9.96 The VSC test shows that 94 out of 111 windows will meet the strict application of the BRE Guidelines. The technical assessment shows that 7 windows will retain >15% VSC and is considered a value deemed acceptable for an urban setting. There are 2 windows (window ref: R6/500 & R7/501) that record an absolute VSC 1.6% and 1.62%, respectively and is considered marginal. The remainder of the affected windows record >40% change from former value. 12.9.97 The NSL test shows that 91 out of 95 rooms will meet the strict application of the BRE Guidelines. The technical results show that the 4 affected rooms record a light change <6.1% beyond the BRE’s permissible 20% change from former value and is considered minor. 12.9.98 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant Riverdale House, 68 Molesworth 12.9.99 There are 286 windows serving 187 rooms within this building that have been considered in the technical assessments. This property is located on the south-west boundary of the Lewisham Shopping Centre Site. The property is residential throughout from ground floor upwards and has a footprint configuration that self-constricts a number of windows serving habitable rooms. 12.9.100 The VSC test shows that 98 out of 286 windows will meet the strict application of the BRE Guidelines. The analysis shows that 102 affected rooms record existing light values >27% (up to 39%) and is considered uncharacteristically high for an urban location. For reference, the maximum VSC that can be achieved is just below 40%. 12.9.101 In respect of the retained VSC values, windows that have an outlook over the Proposed Development retain an average VSC 18.92% which is considered to be reasonable in an urban town centre location. 12.9.102 Of the affected windows, 28 windows record a light change <39.9% from former value. The remaining affected windows record light change >30% from former value with would be a minor adverse negative effect.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
12.9.103 The technical assessment shows that 83 affected rooms are bedrooms; this room classification is acknowledged by the BRE Guidelines to carry less expectation for natural light when compared to a living room. 12.9.104 The NSL test shows that 98 out of 187 rooms will meet the strict application of the BRE Guidelines. The technical assessment shows that 38 affected rooms will record a percentage <29.9% from former value. The remaining affected rooms record change >30% from former value. 12.9.105 Of the affected rooms, there are 60 bedrooms. This room classification is acknowledged by the BRE Guidelines to carry less expectation for natural light when compared to a living room by virtue of its intended use. 12.9.106 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant St. Saviours Church, 175 Lewisham High Street
12.9.107 There are 23 windows serving 13 rooms within this building that have been considered in the technical assessments. 12.9.108 The VSC test shows that 8 out of 23 windows will meet the strict application of the BRE Guidelines. The assessment shows that 13 affected windows record a light change<39.9% from former value. The remaining 2 windows record >40% change from former value. The technical analysis also shows that 7 affected windows retain VSC >15% (up to 22.8%) and by reference to recent planning appeals is considered an acceptable retained value for an urban setting within London. 12.9.109 The NSL test shows that 7 out of 13 rooms will meet the strict application of the BRE Guidelines. This property records existing light values considered uncharacteristic for an urban location, with 8 of the 13 assessed rooms record existing NSL values >90%. The assessment shows that 5 out of 6 affected rooms record retained NSL values >50% and is considered an indicator for good daylight availability. 12.9.110 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
10 Yew Tree Close
12.9.111 There are 8 windows serving 5 rooms within this building that have been considered within the technical assessment. 12.9.112 The VSC test shows that 5 out of 8 windows will meet the strict application of the BRE Guidelines. The assessment shows that the three windows (window ref: W5/600; W6/600 & W3/601) record retained VSC values 19.89%; 19.83% and 17.36% respectively. Although these windows record BRE transgressions by reference to the permissible 20% change from former value, the retained values are greater than 15% and it is considered acceptable for an urban location. 12.9.113 The NSL test shows that 4 out of 5 rooms will meet the strict application of the BRE Guidelines. The isolated room (room ref: R2/601) records a light change 30.9% from former value but retains an NSL >68% that is considered an indicator for good daylight availability, particularly in an urban setting. 12.9.114 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Moderate Adverse and therefore significant. . 191-193 Lewisham High Street
12.9.115 There are 10 windows serving 10 rooms within this building that have been considered within the technical assessment. 12.9.116 The VSC test shows that 0 out of 10 windows will meet the strict application of the BRE Guidelines. The technical assessment shows that 7 out of the 10 affected windows record retained VSC values >21% and is considered very good for an urban location. The remaining 3 windows record retained VSC values of 17% and it is still considered acceptable for an urban setting, by reference to recent planning outcomes.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
12.9.117 The NSL test shows that 3 out of 10 rooms will meet the strict application of the BRE Guidelines. The technical assessment shows that all 7 affected rooms record a light change <29.9% from former value and is classified as a minor significance. 12.9.118 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Moderate Adverse and therefore significant. 12.9.119 The windows that record BRE transgression and do not retain >20% VSC far exceed an acceptable retained VSC value for an urban setting and minor alterations in respect of the NSL test. Although the significance classification is applied as moderate, the daylight to this property is considered acceptable. Sienna Alto, 2 Cornmill Lane
12.9.120 There are 424 windows serving 177 rooms within this building that have been considered in the technical assessment. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment it is appropriate to apply alternative, less stringent, guidelines for windows that have an inherent design feature that inhibits access to direct skylight such as balconies. 12.9.121 The VSC test shows that 328 out of 424 windows will meet the strict application of the BRE Guidelines. The assessment shows that 41 of the affected windows record an absolute VSC change <4% from former value and is considered a minor alteration. In respect of the remaining affected windows, the absolute VSC change to these windows do not exceed 6.55% from former value. 12.9.122 It is also worth noting that 53 of the 96 windows that experience VSC reductions beyond BRE guidelines serve LKDs lit by multiple other windows that exceed the recommendations such that overall the rooms as a whole should continue to receive good levels of direct skylight. In addition, the remaining 43 windows each serve bedrooms which have a lesser requirement for daylight than main living rooms.
12.9.123 The NSL test shows that 168 out of 177 rooms (95%) will meet the strict application of the BRE Guidelines. The assessment shows that the retained NSL values of the 7 affected rooms record >52% daylight to the working plane, with 5 of the rooms retaining >60%. This level of retained NSL demonstrates an indicator for good daylight availability, notwithstanding the inset window/room configuration of the building. 12.9.124 Overall, the daylight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Minor Adverse and therefore not significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Sunlight to Surrounding Properties 12.9.125 There are 2477 windows serving 1416 residential rooms surrounding the Site that are relevant for sunlight amenity assessment. These have all been assessed in terms of total and winter APSH. Full detailed results can be found at Appendix 12.2 and are summarised in Table 12.10 and shows the properties that record full BRE compliance highlighted in green. Table 12.10 - APSH Summary with the Development in Place APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guidelines
Below Threshold for Winter APSH
Below Threshold for Annual APSH
20 30%
30 40%
>40 %
Total
2030%
3040%
>40 %
Total
Total No. Rooms
Isabella Apartments, 102 Granville Park
28
0
0
0
0
0
0
0
0
28
25 Lewisham High Street
3
0
0
1
1
0
0
0
0
4
27 Lewisham High Street
3
0
0
1
1
0
0
0
0
4
29 Lewisham High Street
3
0
0
1
1
0
0
0
0
4
31 Lewisham High Street
6
0
0
0
0
0
0
0
0
6
1 Cressingham Road
7
0
0
0
0
0
0
0
0
7
3 Cressingham Road
4
0
0
0
0
0
0
0
0
4
5 Cressingham Road
4
0
0
0
0
0
0
0
0
4
7 Cressingham Road
4
0
0
0
0
0
0
0
0
4
9 Cressingham Road
4
0
0
0
0
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guidelines
Below Threshold for Winter APSH
Below Threshold for Annual APSH
20 30%
30 40%
>40 %
Total
2030%
3040%
>40 %
Total
Total No. Rooms
11 Cressingham Road
4
0
0
0
0
0
0
0
0
4
13 Cressingham Road
4
0
0
0
0
0
0
0
0
4
15 Cressingham Road
4
0
0
0
0
0
0
0
0
4
17 Cressingham Road
5
0
0
0
0
0
0
0
0
5
19 Cressingham Road
4
0
0
0
0
0
0
0
0
4
21 Cressingham Road
10
0
0
0
0
0
0
0
0
10
23 Cressingham Road
4
0
0
0
0
0
0
0
0
4
16 Cressingham Road
6
0
0
0
0
0
0
0
0
6
14 Cressingham Road
6
0
0
0
0
0
0
0
0
6
12 Cressingham Road
6
0
0
0
0
0
0
0
0
6
10 Cressingham Road
6
0
0
0
0
0
0
0
0
6
8 Cressingham Road
6
0
0
0
0
0
0
0
0
6
6 Cressingham Road
6
0
0
0
0
0
0
0
0
6
4 Cressingham Road
6
0
0
0
0
0
0
0
0
6
2 Cressingham Road
6
0
0
0
0
0
0
0
0
6
St Stephens Church Vicarage, Cressingham Road
10
0
0
0
0
0
0
0
0
10
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guidelines
Below Threshold for Winter APSH
Below Threshold for Annual APSH
20 30%
30 40%
>40 %
Total
2030%
3040%
>40 %
Total
Total No. Rooms
1 Stephens Grove
3
0
0
0
0
0
0
0
0
3
2 Stephens Grove
3
0
0
0
0
0
0
0
0
3
3 Stephens Grove
3
0
0
0
0
0
0
0
0
3
4 Stephens Grove
3
0
0
0
0
0
0
0
0
3
5 Stephens Grove
3
0
0
0
0
0
0
0
0
3
6 Stephens Grove
3
0
0
0
0
0
0
0
0
3
7 Stephens Grove
3
0
0
0
0
0
0
0
0
3
8 Stephens Grove
3
0
0
0
0
0
0
0
0
3
1 Lockmead Road
3
0
0
0
0
0
0
0
0
3
3 Lockmead Road
3
0
0
0
0
0
0
0
0
3
5 Lockmead Road
3
0
0
0
0
0
0
0
0
3
3 Boyne Road
3
0
0
0
0
0
0
0
0
3
1 Boyne Road
3
0
0
0
0
0
0
0
0
3
9 Stephens Grove
5
0
0
0
0
0
0
0
0
5
10 Stephens Grove
5
0
0
0
0
0
0
0
0
5
11 Stephens Grove
5
0
0
0
0
0
0
0
0
5
12 Stephens Grove
5
0
0
0
0
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guidelines
Below Threshold for Winter APSH
Below Threshold for Annual APSH
20 30%
30 40%
>40 %
Total
2030%
3040%
>40 %
Total
Total No. Rooms
13 Stephens Grove
5
0
0
0
0
0
0
0
0
5
14 Stephens Grove
5
0
0
0
0
0
0
0
0
5
15 Stephens Grove
5
0
0
0
0
0
0
0
0
5
16 Stephens Grove
5
0
0
0
0
0
0
0
0
5
17 Stephens Grove
5
0
0
0
0
0
0
0
0
5
18 Stephens Grove
5
0
0
0
0
0
0
0
0
5
19 Stephens Grove
5
0
0
0
0
0
0
0
0
5
19 Granville Grove
3
0
0
0
0
0
0
0
0
3
20 Granville Grove
3
0
0
0
0
0
0
0
0
3
21 Granville Grove
3
0
0
0
0
0
0
0
0
3
22 Granville Grove
3
0
0
0
0
0
0
0
0
3
23 Granville Grove
3
0
0
0
0
0
0
0
0
3
24 Granville Grove
3
0
0
0
0
0
0
0
0
3
25 Granville Grove
3
0
0
0
0
0
0
0
0
3
27 Granville Grove
6
0
0
0
0
0
0
0
0
6
65-71 Lewisham High Street
20
0
0
0
0
0
0
0
0
20
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guidelines
Below Threshold for Winter APSH
Below Threshold for Annual APSH
20 30%
30 40%
>40 %
Total
2030%
3040%
>40 %
Total
Total No. Rooms
85 Lewisham High Street, 1-3 Belmont Hill
4
0
0
0
0
0
0
0
0
4
5 Belmont Hill
2
0
0
0
0
0
0
0
0
2
7-9 Belmont Hill
2
0
0
0
0
0
0
0
0
2
2-4 Belmont Hill
1
0
0
0
0
0
0
0
0
1
1 Lee High Road
3
0
0
0
0
0
0
0
0
3
3-5 Lee High Road
2
0
0
0
0
0
0
0
0
2
7 Lee High Road
4
0
0
0
0
0
0
0
0
4
9 Lee High Road
1
0
0
0
0
0
0
0
0
1
11-13 Lee High Road
3
0
0
0
0
0
0
0
0
3
15 Lee High Road
1
0
0
0
0
0
0
0
0
1
17 Lee High Road
3
0
0
0
0
0
0
0
0
3
19 Lee High Road
3
0
0
0
0
0
0
0
0
3
21 Lee High Road
6
0
0
0
0
0
0
0
0
6
14-16 Lee High Road
9
0
0
0
0
0
0
0
0
9
4-6 Lee High Road
6
0
0
0
0
0
0
0
0
6
1 Lewis Grove
2
0
0
0
0
0
0
0
0
2
1 Mercia Grove
3
0
0
0
0
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guidelines
Below Threshold for Winter APSH
Below Threshold for Annual APSH
20 30%
30 40%
>40 %
Total
2030%
3040%
>40 %
Total
Total No. Rooms
2 Mercia Grove
3
0
0
0
0
0
0
0
0
3
3 Mercia Grove
3
0
0
0
0
0
0
0
0
3
4 Mercia Grove
3
0
0
0
0
0
0
0
0
3
5 Mercia Grove
3
0
0
0
0
0
0
0
0
3
6 Mercia Grove
3
0
0
0
0
0
0
0
0
3
7 Mercia Grove
3
0
0
0
0
0
0
0
0
3
8 Mercia Grove
3
0
0
0
0
0
0
0
0
3
9 Mercia Grove
3
0
0
0
0
0
0
0
0
3
10 Mercia Grove
4
0
0
0
0
0
0
0
0
4
11 Mercia Grove
3
0
0
0
0
0
0
0
0
3
12 Mercia Grove
2
0
0
0
0
0
0
0
0
2
13 Mercia Grove
2
0
0
0
0
0
0
0
0
2
14 Mercia Grove
2
0
0
0
0
0
0
0
0
2
15 Mercia Grove
2
0
0
0
0
0
0
0
0
2
16 Mercia Grove
2
0
0
0
0
0
0
0
0
2
17 Mercia Grove
2
0
0
0
0
0
0
0
0
2
18 Mercia Grove
4
0
0
0
0
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guidelines
Below Threshold for Winter APSH
Below Threshold for Annual APSH
20 30%
30 40%
>40 %
Total
2030%
3040%
>40 %
Total
Total No. Rooms
19 Mercia Grove
2
0
0
0
0
0
0
0
0
2
20 Mercia Grove
2
0
0
0
0
0
0
0
0
2
21 Mercia Grove
3
0
0
0
0
0
0
0
0
3
23 Merci Grove
11
0
0
0
0
0
0
0
0
11
4 Albion Way
3
0
0
0
0
0
0
0
0
3
2 Albion Way
3
0
0
0
0
0
0
0
0
3
8 Bonfield Road
1
0
0
0
0
0
0
0
0
1
6 Bonfield Road
1
0
0
0
0
0
0
0
0
1
4 Bonfield Road
2
0
0
0
0
0
0
0
0
2
2 Bonfield Road
3
0
0
0
0
0
0
0
0
3
131-133 Lewisham High Street
12
0
0
0
0
0
0
0
0
12
139-141 Lewisham High Street
6
0
0
0
0
0
0
0
0
6
155 Lewisham High Street
10
0
0
0
0
1
2
0
3
13
St Saviours Church, 175 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guidelines
Below Threshold for Winter APSH
Below Threshold for Annual APSH
20 30%
30 40%
>40 %
Total
2030%
3040%
>40 %
Total
Total No. Rooms
197 Lewisham High Street
3
0
0
0
0
0
0
0
0
3
205 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
226-230 Lewisham High Street
25
0
0
0
0
0
0
0
0
25
Riverdale House, 68 Molesworth Street
34
0
0
0
0
0
0
0
0
34
Mill Apartments, 68 Molesworth Street
19
0
0
1
1
0
0
1
1
20
14 Odell Walk
3
0
0
0
0
0
0
0
0
3
12 Odell Walk
3
0
0
0
0
0
0
0
0
3
10 Odell Walk
3
0
0
0
0
0
0
0
0
3
8 Odell Walk
3
0
0
0
0
0
0
0
0
3
6 Odell Walk
3
0
0
0
0
0
0
0
0
3
4 Odell Walk
3
0
0
0
0
0
0
0
0
3
2 Odell Walk
3
0
0
0
0
0
0
0
0
3
1 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
2 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
3 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guidelines
Below Threshold for Winter APSH
Below Threshold for Annual APSH
20 30%
30 40%
>40 %
Total
2030%
3040%
>40 %
Total
Total No. Rooms
4 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
5 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
6 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
1 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
3 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
5 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
7 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
9 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
11 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
13 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
10 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
8 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
6 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
4 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
2 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
7 Bankside Avenue
6
0
0
0
0
0
0
0
0
6
8 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guidelines
Below Threshold for Winter APSH
Below Threshold for Annual APSH
20 30%
30 40%
>40 %
Total
2030%
3040%
>40 %
Total
Total No. Rooms
9 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
10 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
11 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
12 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
13 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
14 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
15 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
1 Elder Walk
2
0
0
0
0
0
0
0
0
2
3 Elder Walk
2
0
0
0
0
0
0
0
0
2
5 Elder Walk
2
0
0
0
0
0
0
0
0
2
7 Elder Walk
2
0
0
0
0
0
0
0
0
2
Mill House, Elder Walk
38
0
0
0
0
0
2
7
9
47
Venice Corte, 2 Elmira Street
60
0
0
0
0
0
0
0
0
60
Sienna Alto, 2 Cornmill Lane
152
0
0
14
14
12
6
7
25
177
Glass Mill Leisure Centre, 41 Loampit Vale
1
0
0
0
0
0
0
0
0
1
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guidelines
Below Threshold for Winter APSH
Below Threshold for Annual APSH
20 30%
30 40%
>40 %
Total
2030%
3040%
>40 %
Total
Total No. Rooms
Lewisham Gateway (Under Construction)
379
0
0
6
6
3
1
8
12
391
50 Lewisham High Street
1
0
0
4
4
0
0
4
4
5
52 Lewisham High Street
1
0
0
4
4
0
0
6
6
7
58-60 Lewisham High Street
1
0
0
5
5
0
0
4
4
6
66 Lewisham High Street
0
0
0
6
6
0
0
6
6
6
86-88 Lewisham High Street
3
0
0
1
1
0
9
2
11
14
90 Lewisham High Street
1
0
0
0
0
0
0
1
1
2
92 Lewisham High Street
2
0
0
0
0
0
0
1
1
3
129 Lewisham High Street
4
0
0
0
0
0
0
0
0
4
117-119 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
97-99 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Meet BRE Guidelines
Address
Below Threshold for Winter APSH
Below Threshold for Annual APSH
20 30%
30 40%
>40 %
Total
2030%
3040%
>40 %
Total
Total No. Rooms
93-95 Lewisham High Street
11
0
0
0
0
0
0
0
0
11
85-87 Lewisham High Street
5
0
0
0
0
0
0
0
0
5
Total
1329
0
0
44
44
16
20
47
83
1416
12.9.126
The BRE Guidelines state that: “…the sunlighting of the existing building may be adversely affected…if the centre of the window receives less than 25% of annual probable sunlight hours, or less than 5% of annual probable sunlight hours between 21 September and 21 March and receives less than 0.8 times its former sunlight hours during either period and has a reduction in sunlight received over the whole year greater than 4% of annual probable sunlight hours.”
12.9.127
For existing residential properties, the BRE Guidelines state in Section 3.2.3 that: “all main living rooms of dwellings…should be checked if they have a window facing within 90° of due south, kitchens and bedrooms are less important, although care should be taken not to block too much sun.”
12.9.128
Section 3.2.4 continues: “If the main living room to a dwelling has a main window facing within 90° of due north, but a secondary window facing within 90° of due south, sunlight to the secondary window should be checked.”
12.9.129 The following properties have the following number of Site-facing rooms that are within 90 degrees of due south and will experience alterations which, in accordance with the BRE Guidelines, will not be noticeable to the occupants and therefore negligible:
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •
31 Lewisham High Street 1 Cressingham Road 3 Cressingham Road 5 Cressingham Road 7 Cressingham Road 9 Cressingham Road 11 Cressingham Road 13 Cressingham Road 15 Cressingham Road 17 Cressingham Road 19 Cressingham Road 21 Cressingham Road 23 Cressingham Road 16 Cressingham Road 14 Cressingham Road 12 Cressingham Road 10 Cressingham Road 8 Cressingham Road 6 Cressingham Road 4 Cressingham Road 2 Cressingham Road St Stephens Church Vicarage, Cressingham Road 1 Stephens Grove 2 Stephens Grove 3 Stephens Grove 4 Stephens Grove 5 Stephens Grove 6 Stephens Grove 7 Stephens Grove 8 Stephens Grove 1 Lockmead Road 3 Lockmead Road 5 Lockmead Road 3 Boyne Road 1 Boyne Road 9 Stephens Grove 10 Stephens Grove 11 Stephens Grove 12 Stephens Grove 13 Stephens Grove
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •
14 Stephens Grove 15 Stephens Grove 16 Stephens Grove 17 Stephens Grove 18 Stephens Grove 19 Stephens Grove 19 Granville Grove 20 Granville Grove 21 Granville Grove 22 Granville Grove 23 Granville Grove 24 Granville Grove 25 Granville Grove 27 Granville Grove 65-71 Lewisham High Street 85 Lewisham High Street, 1-3 Belmont Hill 5 Belmont Hill 7-9 Belmont Hill 2-4 Belmont Hill 1 Lee High Road 3-5 Lee High Road 7 Lee High Road 9 Lee High Road 11-13 Lee High Road 15 Lee High Road 17 Lee High Road 19 Lee High Road 21 Lee High Road 14-16 Lee High Road 4-6 Lee High Road 1 Lewis Grove 1 Mercia Grove 2 Mercia Grove 3 Mercia Grove 4 Mercia Grove 5 Mercia Grove 6 Mercia Grove 7 Mercia Grove 8 Mercia Grove 9 Mercia Grove Plowman Craven 46730 October 2024
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •
10 Mercia Grove 11 Mercia Grove 12 Mercia Grove 13 Mercia Grove 14 Mercia Grove 15 Mercia Grove 16 Mercia Grove 17 Mercia Grove 18 Mercia Grove 19 Mercia Grove 20 Mercia Grove 21 Mercia Grove 23 Merci Grove 4 Albion Way 2 Albion Way 8 Bonfield Road 6 Bonfield Road 4 Bonfield Road 2 Bonfield Road 131-133 Lewisham High Street 139-141 Lewisham High Street St Saviours Church, 175 Lewisham High Street 197 Lewisham High Street 205 Lewisham High Street 226-230 Lewisham High Street Riverdale House, 68 Molesworth Street 14 Odell Walk 12 Odell Walk 10 Odell Walk 8 Odell Walk 6 Odell Walk 4 Odell Walk 2 Odell Walk 1 Bankside Avenue 2 Bankside Avenue
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •
3 Bankside Avenue 4 Bankside Avenue 5 Bankside Avenue 6 Bankside Avenue 1 Yew Tree Close 3 Yew Tree Close 5 Yew Tree Close 7 Yew Tree Close 9 Yew Tree Close 11 Yew Tree Close 13 Yew Tree Close 10 Yew Tree Close 8 Yew Tree Close 6 Yew Tree Close 4 Yew Tree Close 2 Yew Tree Close 7 Bankside Avenue 8 Bankside Avenue 9 Bankside Avenue 10 Bankside Avenue 11 Bankside Avenue 12 Bankside Avenue 13 Bankside Avenue 14 Bankside Avenue 15 Bankside Avenue 1 Elder Walk 3 Elder Walk 5 Elder Walk 7 Elder Walk Venice Corte, 2 Elmira Street Glass Mill Leisure Centre, 41 Loampit Vale 129 Lewisham High Street 117-119 Lewisham High Street 97-99 Lewisham High Street 93-95 Lewisham High Street 85-87 Lewisham High Street
12.9.130 The following properties are therefore considered to experience reductions which are of minor negative significance:
•
25 Lewisham High Street
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
• • • • • •
27 Lewisham High Street 29 Lewisham High Street 155 Lewisham High Street Mill Apartments, 68 Molesworth Street 86-88 Lewisham High Street 90 Lewisham High Street
12.9.131 Site-facing rooms, located within the following properties, will experience APSH alterations that are beyond those described above and so will be considered in more detail: •
Sienna Alto, 2 Cornmill Lane
•
66 Lewisham High Street
• Lewisham Gateway (Under Construction)
•
92 Lewisham High Street
•
Mill Apartments, 68 Molesworth Street
•
86-88 Lewisham High Street
•
90 Lewisham High Street
•
Mill House, Elder Walk
•
50 Lewisham High Street
•
52 Lewisham High Street
•
58-60 Lewisham High Street 50 Lewisham High Street
12.9.132 The sunlight test considers 5 rooms within the building that have an orientation 90 degrees of due south. 12.9.133 The result of the APSH assessment shows that 1 of out 5 rooms will meet the strict application of the BRE Guidelines. Each affected room (4) records >40% change from former value, although 2 rooms (room ref: R1/7002 & R2/7003) record retained annual sunlight values of 16% and 21% respectively. 12.9.134 Overall, the sunlight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
52 Lewisham High Street
12.9.135 The sunlight test considers 7 rooms within the building that have an orientation 90 degrees of due south. 12.9.136 The result of the APSH assessment shows that 1 out of 7 rooms will meet the strict application of the BRE guidelines. The sunlight test shows that 3 rooms record retained sunlight values >20% and is considered good for an urban location. The remaining rooms record change >40% from former value. 12.9.137 Overall, the sunlight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. 58-60 Lewisham High Street
12.9.138 The sunlight test considers 6 rooms within the building that have an orientation 90 degrees of due south. 12.9.139 The APSH test shows that 1 out of 6 rooms will meet the strict application of the BRE Guidelines. Notably, 3 affected rooms record retained annual sunlight values 17%-39%. The bigger daylight challenges are recorded within the winter months when sunlight availability is inherently more challenged by virtue of the low sun path. 12.9.140 Overall, the sunlight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. 62-64 Lewisham High Street
12.9.141 The sunlight test considers 1 room within the building that has an orientation 90 degrees of due south. 12.9.142 The APSH test shows that 0 out of 1 room will meet the strict application of the BRE Guidelines. Notably, 3 affected rooms record retained annual sunlight values 17%-39%. The bigger daylight challenges are recorded within the winter months when sunlight availability is inherently more challenged by virtue of the low sun path. 12.9.143 Overall, the sunlight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
66 Lewisham High Street
12.9.144 The sunlight test considers 6 rooms within the building that have an orientation 90 degrees of due south. 12.9.145 The APSH test shows that 0 out of 6 rooms will meet the strict application of the BRE Guidelines. Each affected room records a light change >40% from former value with retained annual sunlight values ranging from 3%-10%. 12.9.146 Overall, the sunlight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. 92 Lewisham High Street
12.9.147 The sunlight test considers 3 rooms within the building that have an orientation 90 degrees of due south. 12.9.148 The APSH test shows that 2 out of 3 rooms will meet the strict application of the BRE Guidelines. The assessment shows that the isolated affected room (room ref: R2/7141) records a light change >40% from former value. 12.9.149 Overall, the sunlight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. Lewisham Gateway
12.9.150 The sunlight test considers 391 rooms within the building that have an orientation 90 degrees of due south. 12.9.151 The APSH test shows that 379 out of 391 rooms will meet the strict application of the BRE Guidelines. The technical assessment shows that 5 affected rooms will retain annual sunlight values >15%, with 3 record >20% and considered very good for an urban setting. The remaining affected rooms record >40% change from former value during the annual months. 12.9.152 Overall, the sunlight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Mill House, Elder Walk
12.9.153 The sunlight test considers 47 rooms within the building that have an orientation 90 degrees of due south. 12.9.154 The APSH test shows that 38 out of 47 rooms will meet the strict application of the BRE Guidelines. The assessment shows that 6 of the affected rooms record retained annual sunlight availability >20% and is considered very good for an urban setting. The remaining 3 rooms retain annual sunlight availability of 13%-15% respectively and are retained values not uncommon within an urban setting. 12.9.155 Overall, the sunlight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Moderate Adverse and therefore significant. Sienna Alto, 2 Cornmill Lane
12.9.156 The sunlight test considers 177 rooms within the building that have an orientation 90 degrees of due south. 12.9.157 The APSH test shows that 152 out of 177 rooms will meet the strict application of the BRE Guidelines. The assessment shows that 12 rooms record a percentage change <29.9% from former value during the annual sunlight analysis. The majority of assessed rooms record <38% change from former value. The remaining 7 rooms record a change >40% from former value. 12.9.158 Overall, the sunlight effect to this property as a result of the Proposed Development (Max Parameters) is considered direct, permanent, Major Adverse and therefore significant. Overshadowing 12.9.159 The potential for overshadowing to the public and private amenity spaces to the surrounding the Proposed Development have been assessed. Sun on Ground 12.9.160 The proposed Sun on Ground of the public amenity spaces and the residential gardens were assessed in March. Full detailed results can be seen in Appendix 12.4. The proposed levels of shadowing, compared to the baseline results for each area are summarised in Table 12.11.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Table 12.11 – Summary of Proposed Sun on Ground Results Proposed Sun Hours on Ground
Assessment Date No. of Assessed Amenity Spaces
March 21st
No. Assessed Amenity Spaces Meeting BRE Target
% amenity spaces >50% Surface are that receives 2 hours in sunlight
201
91
221
12.9.161 There are 20 amenity spaces that will experience a reduction in sunlight availability triggering a technical BRE breach. Table 12.12 below provides a breakdown of the surrounding amenity spaces that do not meet the sunlight values recommended by the BRE Guidelines. Table 12.12 – Proposed Sun on Ground Results – Affected Amenity Spaces
Area
% of Area Receiving at Least 2 Hours of Sunlight on 21st March Existing Baseline
% of Area Receiving at Least 2 Hours of Sunlight on 21st March Proposed
% Reduction from Existing Baseline
Significance Classification (Direct, Permanent and Adverse)
4 Mill House, Elder Walk
96
41
57
Major and Significant
6 Mill House, Elder Walk
63
33
47
Major and Significant
10 Mill House, Elder Walk
40
29
29
Minor and Not Significant
2 Yew Tree Close
52
28
47
Major and Significant
4 Yew Tree Close
51
25
52
Major and Significant
6 Yew Tree Close
52
25
53
Major and Significant
8 Yew Tree Cloose
69
35
50
Major and Significant
St. Stephen's Church North
14
6
58
Major and Significant
62-64 Lewisham High Street
48
24
49
Major and Significant
66 Lewisham High Street
16
0
100
Major and Significant
8 Stephens Grove
5
0
93
Major and Significant
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Area
% of Area Receiving at Least 2 Hours of Sunlight on 21st March Existing Baseline
% of Area Receiving at Least 2 Hours of Sunlight on 21st March Proposed
% Reduction from Existing Baseline
Significance Classification (Direct, Permanent and Adverse)
7 Stephens Grove
10
0
100
Major and Significant
6 Stephens Grove
2
0
100
Major and Significant
5 Stephens Grove
10
0
100
Major and Significant
4 Stephens Grove
8
0
100
Major and Significant
3 Stephens Grove
0
0
100
Major and Significant
2 Stephens Grove
2
0
100
Major and Significant
24 Granville Grove
1
1
62
Major and Significant
23 Granville Grove
24
15
36
Moderate and Significant
21 Granville Grove
6
5
22
Minor and Not Significant
Light Pollution 12.9.162 The full results of the light pollution analysis to the surrounding receptors arising from the Proposed Development are included in Appendix 12.6 and a summary of the findings for each surrounding receptor follows below. 12.9.163 It should be noted that the analysis below assumes that all lights within the Proposed Development are turned on which provides a worst-case and therefore somewhat unrealistic position. It should also be noted that the analysis focuses solely on the extent of any light spill from the proposed commercial offices, retails spaces and concierge/lobby areas within the detailed element of the Proposed Development (N1 and N2).
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
50-70 Lewisham High Street 12.9.164 The results of the light spill analysis to the 50-70 Lewisham High Street are shown on plot P0511/LP/02 in Appendix 12.6. 12.9.165 The results show additional light spill of between approximately 3 lux and 18 lux which is below the pre-curfew intrusion level of 25 lux. While it is above the post-curfew threshold of 5 lux, it should be noted that the analysis assumes all lights within the Proposed Development are turned on post-curfew which is highly unlikely to be the case. It is reasonable to assume that post-curfew, the building will be predominantly unoccupied and therefore, the majority of the lights will be switched off and so the post-curfew lux level is likely to be notably lower. 12.9.166 Internal lighting control measures such as PIR sensors to turn lighting off in unoccupied rooms and floors can be put in place to reduce the potential light spill arising from the Proposed Development to an acceptable level post-curfew. This would likely include motion sensors to limit lighting to where it is needed and blinds on windows. Therefore, when applying professional judgement, the likely light spill effect arising from the Proposed Development would be Negligible and not significant. 86-118 Lewisham High Street 12.9.167 The results of the light spill analysis to 86-118 Lewisham High Street are shown plot P0511/LP/03 in Appendix 12.6. 12.9.168 The results show additional light spill of up to approximately 10 lux on the lower commercial floors and between 0 and 3 lux, at most, on the upper residential floors, which is below the pre-curfew intrusion level of 25 lux. 12.9.169 As above, internal lighting control measures such as PIR sensors to turn down lighting on unoccupied floors can be put in place to reduce the potential light spill arising from the Proposed Development to an acceptable level post-curfew. Therefore, when applying professional judgement and given the lower levels of light spill on the upper residential floors, the likely light spill effect arising from the Proposed Development will be Negligible and not significant. 73-85 Lewisham High Street 12.9.170 The results of the light spill analysis to 73-85 Lewisham High Street are shown on plot P0511/LP/04 in Appendix 12.6. 12.9.171 The results show that there will be no discernible light spill reaching the facades of the sensitive residential receptors in this location. 12.9.172 As such, any additional light spill arising from the Proposed Development to this building is Negligible and not significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
1-21 Lee High Road 12.9.173 The results of the light spill analysis to 1-21 Lee High Road are shown on plot P0511/LP/05 in Appendix 6. 12.9.174 The results show that there will be no discernible light spill reaching the facades of the sensitive residential receptors in this location. 12.9.175 As such, any additional light spill arising from the Proposed Development to this building is Negligible and not significant. Solar Glare 12.9.176 For the purposes of the Solar Glare assessments, as we are assessing both the detailed and outline elements of the scheme together, a worse-case scenario where we have assumed all the buildings are fully mirrored. 12.9.177 Using scenario 1 (Fully Mirrored) the annual sequence images showed that there was the potential for solar glare to occur to the road users travelling south and north Lewisham High Street and Molesworth Street and the north-south railway line located to the west of the Proposed Development. 12.9.178 Calendar graph assessments have therefore been carried out at 9 assessment points and these can be found within Appendix 12.5. The results of these assessments are discussed below: 12.9.179 Viewpoint 1 – This viewpoint is located to the north of the proposed scheme and considers the view of a vehicle position on the road. The glare calendar shows that there will be continued glare of >30 degrees throughout the year at various time of the day. The instances of >30 degrees occur for periods of 20-50mins. This degree of glare is considered far periphery field of view and is not considered to hazardous reflective glare. 12.9.180 There are isolated moments of glare <30 degrees during January to early February for periods of 15 mins between 09:00 – 10:00am and later in the year from October to the end of December for 15 mins between 10:00am – 10:30am. This recorded degree of glare corresponds to Near Periphery field of view and is considered not to be material or significant given the period of time the glare occurs. 12.9.181 The overall scale of effect is therefore considered to be negligible or minor negative which is not significant, particularly as this is assuming a fully mirrored scheme. 12.9.182 Viewpoint 2 – This viewpoint is located to the east of the Proposed Development and considers the view of a vehicular position on the road. There are periods of 15 minutes of glare recorded >30 degrees between February and April between 07:00am-10:30am and separately, between August and November between 07:00am and 08:00am-11:00am for no longer than 20 minutes. This degree of glare is considered far periphery field of view and is not considered hazardous reflective glare.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
12.9.183 The assessment also shows instances of glare of <30 degrees for periods ranging from 5minutes to 60 minutes. This occurs between the hours of 07:00am-08:30am and 13:00pm - 15:15pm in the early months of the year. In the later months of the year, from August to October, <30 degree glare is recorded 07:00am -09:15am, between 09:45am – 10:00am; 13:15pm - 15:30pm. This recorded degree of glare corresponds to Near Periphery field of view and is considered not to be material or significant given the period of time the glare occurs. 12.9.184 This viewpoint also records a glare angle <10 degree, but greater than 3 degrees. These occur in isolated moments during the first week of March at 07:20 for 20 minutes and the first week of October at 08:00am for 15 minutes. 12.9.185 It should also be acknowledged that the analysis has been undertaken assuming a worst-case scenario, where the windows have been adopted as the external façade to act as a perfect polished mirror for the purposes of the annual pattern of reflection and assumes a clear sky throughout. It is understood that the materials are largely brick and this façade material is non-reflective and will likely absorb reflection, dampening and reducing the extent of the solar glare reflectance. Therefore, in reality, the analysis results presented for this viewpoint has been overstated. 12.9.186 The overall scale of effect is therefore considered to be negligible or minor negative which is not significant, particularly as this is assuming a fully mirrored scheme. 12.9.187 Viewpoint 3 – This viewpoint is located to the east of the Proposed Development and considers the viewpoint of a vehicular position on the road. There are periods in the mornings of glare >30 degree from February to October, lasting between 15minutes and 2.5hours. This degree of glare is considered far periphery field of view and is not considered to hazardous reflective glare. 12.9.188 Throughout the year there are intervals of <30 degree glare, although greater than 10 degrees. This degree of glare occurs during January to February between 09:45am to 10:15am and 12:00pm to 12:30pm; during March and April between 06:50am-07:30am and in the afternoon at 15:00pm, 17:00pm and 18:00pm for periods of 15-30mins; during MayJuly from 04:00am to 05:00am and at 18:00pm; 06:50am – 07:30am, 15:30pm-16:00pm and 18:00pm; during October-December in short duration from 10:30am-11:am and 12:45pm13:20pm. This recorded degree of glare corresponds to Near Periphery field of view and is considered not to be material or significant given the period of time the glare occurs. 12.9.189 The overall scale of effect is therefore considered to be negligible or minor negative which is not significant, particularly as this is assuming a fully mirrored scheme. 12.9.190 Viewpoint 4 – This viewpoint is located to the south of the Proposed Development and orientates northerly along the Lewisham High Street. This viewpoint records glare of >30 degree, mostly during the morning hours between February and October from 06:00am – 10:00am and instances of 5 minutes during January at 11:00am-12:30pm; during March at 15:00pm; late September at 15:45pm and early November from 12:00pm and 13:00pm. This degree of glare is considered far periphery field of view and is not considered hazardous reflective glare. 12.9.191 The overall scale of effect is therefore considered to be negligible or minor negative which is not significant, particularly as this is assuming a fully mirrored scheme. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
12.9.192 Viewpoint 5 – This viewpoint is located to the south of the Proposed Development and has a view of the southern boundary of the Site. Glare of >30 degrees is recorded in the early months of the year, from |January to March between 11:00am-14:00pm and in the later months of the year during September to December between 12:00pm and 14:00pm. 12.9.193 There is glare of <30 degrees, but greater than 10 degrees recorded for periods of an hour(s) in January – February from 09:00am-11:00am and 12:00pm-15:00pm. Momentarily there is glare of this degree in March/April and August/September from 06:30am-07:15am and during May to July from 18:30pm t0 19;05am. In the months October to December there are glare <30 degrees for a duration of 90mins – 150mins from 10:00am -11:30am and 13:00pm – 15:30pm. 12.9.194 This viewpoint also records isolated instances of glare <10 degree in January for no more than 5 minutes at 09:00am and 14:55pm; during March at 06:30am; for 15 minutes during May - July at 04:45am; for 10 minutes during September at 07:20am; less than 5 minutes during November at 09:55am and for a period of 5 minutes during December at 15:45pm. 12.9.195 The majority of recorded glare is considered non-hazardous given the angle of the reflection. Although there are isolated instances of glare <10 degree, it should be acknowledged that the analysis has been undertaken assuming a worst-case scenario, where the windows have been adopted as the external façade to act as a perfect polished mirror for the purposes of the annual pattern of reflection and assumes a clear sky throughout. It is understood that the materials are largely brick and this façade material is non-reflective and will likely absorb reflection, dampening and reducing the extent of the solar glare reflectance. Therefore, in reality, the analysis results presented for this viewpoint has been overstated. 12.9.196 The overall scale of effect is therefore considered to be negligible or minor negative which is not significant, particularly as this is assuming a fully mirrored scheme. 12.9.197 Viewpoint 6 – This viewpoint is located to the west of the Proposed Development and has a northerly orientation along Molesworth Street. This viewpoint records glare >30 degrees in March-April for internals of 10-15mins from 13:00pm – 14:00pm; in May for 20 minutes from 10:40am-11:00am; for a period of 45mins during May-July from 15:45pm16:30pm; in July for 10 minutes from 10:50am and during August-October for 5-10minutes between 14:00pm – 15:00pm. This degree of glare is considered far periphery field of view and is not considered to hazardous reflective glare. 12.9.198 There are instances of glare at <30 degrees but greater than 10 degrees during January to February for 10 minute intervals from 14:00pm-14:10pm and in the later months of the year during October to December from 14:40pm-15:15pm for intervals no longer than 10 minutes. This recorded degree of glare corresponds to Near Periphery field of view and is considered not to be material or significant given the period of time the glare occurs. 12.9.199 The overall scale of effect is therefore considered to be negligible or minor negative which is not significant, particularly as this is assuming a fully mirrored scheme.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
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12.9.200 Viewpoint 7 – This viewpoint is located to the north of the Proposed Development and has a southerly orientation facing Molesworth Street. This mostly records glare >30 degrees throughout the year in the afternoon. The >30 degree glare is recorded for periods of circa 30minutes in January-April and August and December between 12:00pm-13:00pm and 13:00pm – 14:00pm. Longer intervals of circa 60 minutes are recorded during March and September that occur between 13:30pm-16:00pm. This degree of glare is considered far periphery field of view and is not considered to hazardous reflective glare. This degree of glare is considered far periphery field of view and is not considered to hazardous reflective glare. 12.9.201 This viewpoint also records instances of >30 degree glare but great than <10 degree glare. This level of glare occurs during January – March for 10 minutes between 13:00pm – 14:00pm and for 60 minutes between 14:00pm-15:00pm. This degree of glare is also recorded during September to December for 10 minutes between 13:00pm – 14:00pm and for 60 minutes between 14:00pm-15:00pm. This recorded degree of glare corresponds to Near Periphery field of view and is considered not to be material or significant given the period of time the glare occurs. 12.9.202 The overall scale of effect is therefore considered to be negligible or minor negative which is not significant, particularly as this is assuming a fully mirrored scheme. 12.9.203 Viewpoint 8 – This viewpoint is located to the north-west of the Proposed Development and situated on the railway orientated south. There are prolonged instances of >30 degree glare that occur during January – February from 12:00pm to 12:45pm and from October to December between 12:50pm-13:30pm. The longer intervals are recorded during March to October between 14:45pm extending to 17:20pm in instances. This degree of glare is considered far periphery field of view and is not considered to hazardous reflective glare. 12.9.204 Glare of <30 degree but greater than 10 degrees is recorded between January to March in the afternoon from 14:00pm to 17:00pm and is also recorded for the same duration in September to November between 15:00pm-17:45pm. This recorded degree of glare corresponds to Near Periphery field of view and is considered not to be material or significant given the period of time the glare occurs. 12.9.205 There are instances of <10 degree glare during January between 14:45pm – 15:15pm and during November to December from 14:30pm-15:15pm. The majority of recorded glare is considered non-hazardous given the angle of the reflection. Although there is isolated instances of glare <10 degree, it should be acknowledged that the analysis has been undertaken assuming a worst-case scenario, where the windows have been adopted as the external façade to act as a perfect polished mirror for the purposes of the annual pattern of reflection and assumes a clear sky throughout. It is understood that the materials are largely brick and this façade material is non-reflective and will likely absorb reflection, dampening and reducing the extent of the solar glare reflectance. Therefore, in reality, the analysis results presented for this viewpoint has been overstated. 12.9.206 The overall scale of effect is therefore considered to be negligible or minor negative which is not significant, particularly as this is assuming a fully mirrored scheme.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
12.9.207 Viewpoint 9 – This viewpoint is located to the west of the Proposed Development and situated on a railway with a northerly orientation. This viewpoint records glare at >30 degrees across the year and is considered negligible. This occurs periods of 5 minutes in the early morning (pre-08:00am) during March and May and August and September. There are longer periods of glare recorded >30 degrees of circa 60 mins from February to November between 15:00pm-17:30pm. This degree of glare is considered far periphery field of view and is not considered to hazardous reflective glare. 12.9.208 There are isolated moments of glare <30 degrees but greater than 10 degrees in March from 11:00am for 15 minutes and in October at 11:45pm for 15 minutes. This recorded degree of glare corresponds to Near Periphery field of view and is considered not to be material or significant given the period of time the glare occurs. 12.9.209 The overall scale of effect is therefore considered to be negligible or minor negative which is not significant, particularly as this is assuming a fully mirrored scheme. Mitigation Demolition and Construction Mitigation
12.9.210 No mitigation measures are required for the demolition and construction stage. Effects in relation to daylight, sunlight and overshadowing would vary throughout the refurbishment, demolition and construction stage. They would, however, certainly be less than the effects of the completed Proposed Development. Those effects, which may be perceptible during construction, would be similar or less than those of the completed Proposed Development set out previously.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
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Completed Development Mitigation 12.9.211 Mitigation measures that were considered necessary to reduce the effects of the detailed elements of the Proposed Development to the levels set out above have already been embedded in the design from advice given during the design stage. 12.9.212 In terms of future mitigation measures in respect of the Outline Phases of the Masterplan, the detailed reserved matters for the current Outline Masterplan will address any residual daylight, sunlight and overshadowing effects through detailed design. Whilst the maximum parameters represent a worst case in terms of external envelope, they incorporate buffer zones for design features such as roof plant, parapets, lift overruns, projecting balconies etc. 12.9.213 This means that the eventual detailed developments within the Outline Masterplan may not realistically be built out to the full extent of the maximum parameters. The design of the individual buildings at the future reserved matters stages will ensure that building heights and forms are not only within the maximum parameters, but also sensitive to daylight/sunlight amenity of nearby sensitive receptors. Residual Effects 12.9.214 All of the residual effects resulting from the Proposed Development, are as presented within the Assessment of Effects whereby, if reductions exceeded 30% of the existing baseline figures, then the effects were considered significant. Any window or room experiencing less than a 30% reduction was considered to experience an effect which is not significant.
12.10 Limitation and Assumptions 12.10.1 Daylight and Sunlight - the results set out in the appendices and discussed in this ES chapter are based on a 3D computer model of the site and the surrounding area and the use of bespoke analysis software. The surrounding buildings that have been assessed, and the size/locations of the surrounding windows is based on measured land survey data. Further contextual modelling of the local area is based on a topographically correct 3D model of the area by Z-mapping Ltd. 12.10.2 Access into the surrounding properties has not been obtained. The layouts used for the No-Sky Line test (discussed below) have therefore been principally based on publicly available information on the internet, such as planning applications, previous sales particulars, or lease plans available from the Land Registry. Where the layouts for the surrounding properties have not been obtained using these sources, the room layouts have been assumed and typically taken as half the depth of the property. 12.10.3 The uses of the adjoining properties, in terms of whether they are of commercial or residential use, were established using external observations, Valuation Office Agency (VOA) checks and the data held on the local authority website. 12.10.4 Overshadowing - The model, which is orientated to the north, enables the path of the sun to be tracked throughout the year to establish the shadows that will be cast by the existing buildings and the Proposed Development on the nearby amenity spaces. The extent and height of the ground level used in our assessments are based on site notes and a topographically correct 3D model of the area by Z-mapping Ltd. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
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12.10.5 Solar Glare – The solar glare assessments have assumed a fully mirrored scheme in order to test a worse-case scenario. 12.10.6 Light Pollution – The light pollution assessments have focussed on the commercial office spaces, retail areas and residential concierge/lobby areas of the detailed elements of the Development (N1 and N2) only. Reasonable assumptions in respect of the lighting strategy, lighting intensity and glazing have all been applied. For the purposes of the assessments, it was assumed that the lights were on 24 hours a day at full intensity to represent a worst-case scenario.
12.11 Cumulative Effects 12.11.1 This section considers the likely cumulative effects that could arise from the Proposed Development when considered alongside other committed development schemes proximate to the Site. It identifies whether effects from several developments which individually may be insignificant could, when considered together, cause significant cumulative effects requiring mitigation. 12.11.2 A number of committed developments have been identified as being relevant to this assessment. These were identified through a review of LBL’s planning portal and have been agreed with LBL. 12.11.3 The assessment is based on the best available information and draws on the assessments included in the ES and Application Reports that accompany the development applications, where available. 12.11.4 From a daylight, sunlight and overshadowing assessment perspective, evolution of the baseline condition can only occur with further schemes being built in the local area. The cumulative baseline evolution therefore considers those developments that are known to have been granted planning permission. 12.11.5 Given the nature of solar glare this topic is typically assessed in absolute terms with the implementation of the Proposed Development. As such, the consideration of this assessment within the context of an evolved baseline is not applicable. 12.11.6 Of the Cumulative Schemes identified, only Lewisham open Market (planning ref: DC/24/136236) directly to the east of the Site is in close enough proximity to be able to cause the Proposed Development to cause an additional effect and this additional effect would solely be to the Lewisham High Street properties. All of the other nearby sensitive receptors are of a sufficient distance from Lewisham Open Market as to not be affected.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
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Demolition & Construction Phase Assessment of Effects 12.11.7 This section identifies and assesses the scale and nature of the main effects arising from the Proposed Development during the construction phase. 12.11.8 Effects in relation to daylight, sunlight and overshadowing will vary throughout the demolition and construction phase. 12.11.9 There will be no notable anticipated effect whilst the existing buildings on the Site are demolished. There will also be no anticipated effect following the completion of the demolition of the buildings. During the construction of the Development, the effects would be no worse than those of the completed Development as set out below. For those residents, who would be living in the initial phases of the Development (completed blocks of the detailed element of the Development), during the construction of the outline element of the Development, they would enjoy higher levels of daylight/sunlight. Cumulative Assessment of Effects
Cumulative Daylight to Surrounding Properties 12.11.10 There are 3737 windows serving 2327 residential rooms within the assessed properties surrounding the Site. These have all been assessed in terms of both VSC and NSL. Full detailed results can be found at Appendices 12.3 and 12.3 and are summarised in Table 12.16 and Table 12.17 and show those properties that record full BRE compliance, in respect of VSC and NSL, highlighted in green. Table 12.16 – Cumulative VSC Summary with the Development in Place VSC SUMMARY
Address
Total that Meet BRE Guidelines
Below BRE Guidelines 20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Windows
Isabella Apartments, 102 Granville Park
40
0
0
0
0
40
25 Lewisham High Street
7
0
0
0
0
7
27 Lewisham High Street
6
0
0
0
0
6
29 Lewisham High Street
6
0
0
0
0
6
31 Lewisham High Street
9
0
0
0
0
9
1 Cressingham Road
9
0
0
0
0
9
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
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VSC SUMMARY
Address
Total that Meet BRE Guidelines
Below BRE Guidelines 20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Windows
3 Cressingham Road
5
0
0
0
0
5
5 Cressingham Road
5
0
0
0
0
5
7 Cressingham Road
5
0
0
0
0
5
9 Cressingham Road
5
0
0
0
0
5
11 Cressingham Road
5
0
0
0
0
5
13 Cressingham Road
5
0
0
0
0
5
15 Cressingham Road
5
0
0
0
0
5
17 Cressingham Road
6
0
0
0
0
6
19 Cressingham Road
5
0
0
0
0
5
21 Cressingham Road
10
0
0
0
0
10
23 Cressingham Road
6
0
0
0
0
6
16 Cressingham Road
8
0
0
0
0
8
14 Cressingham Road
9
0
0
0
0
9
12 Cressingham Road
9
0
0
0
0
9
10 Cressingham Road
9
0
0
0
0
9
8 Cressingham Road
8
0
0
0
0
8
6 Cressingham Road
8
0
0
0
0
8
4 Cressingham Road
8
0
0
0
0
8
2 Cressingham Road
8
0
0
0
0
8
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
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VSC SUMMARY
Address
Total that Meet BRE Guidelines
Below BRE Guidelines 20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Windows
St Stephens Church Vicarage, Cressingham Road
23
0
0
0
0
23
1 Stephens Grove
5
0
0
0
0
5
2 Stephens Grove
4
0
0
1
1
5
3 Stephens Grove
5
0
0
0
0
5
4 Stephens Grove
4
0
0
1
1
5
5 Stephens Grove
5
0
0
0
0
5
6 Stephens Grove
4
0
0
1
1
5
7 Stephens Grove
5
0
0
0
0
5
8 Stephens Grove
4
0
0
1
1
5
1 Lockmead Road
5
0
0
0
0
5
3 Lockmead Road
5
0
0
0
0
5
5 Lockmead Road
7
0
0
0
0
7
3 Boyne Road
6
0
0
0
0
6
1 Boyne Road
9
0
0
0
0
9
9 Stephens Grove
8
0
0
0
0
8
10 Stephens Grove
5
0
0
0
0
5
11 Stephens Grove
5
0
0
0
0
5
12 Stephens Grove
5
0
0
0
0
5
13 Stephens Grove
5
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
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VSC SUMMARY
Address
Total that Meet BRE Guidelines
Below BRE Guidelines 20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Windows
14 Stephens Grove
5
0
0
0
0
5
15 Stephens Grove
5
0
0
0
0
5
16 Stephens Grove
5
0
0
0
0
5
17 Stephens Grove
5
0
0
0
0
5
18 Stephens Grove
5
0
0
0
0
5
19 Stephens Grove
5
0
0
0
0
5
19 Granville Grove
5
0
0
0
0
5
20 Granville Grove
4
0
1
0
1
5
21 Granville Grove
5
0
0
0
0
5
22 Granville Grove
4
0
0
1
1
5
23 Granville Grove
5
0
0
0
0
5
24 Granville Grove
4
0
0
1
1
5
25 Granville Grove
5
0
0
0
0
5
27 Granville Grove
9
0
0
1
1
10
65-71 Lewisham High Street
40
4
0
0
4
44
85 Lewisham High Street, 1-3 Belmont Hill
13
0
0
0
0
13
5 Belmont Hill
2
0
0
0
0
2
7-9 Belmont Hill
2
0
0
0
0
2
2-4 Belmont Hill
29
0
0
0
0
29
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
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VSC SUMMARY
Address
Total that Meet BRE Guidelines
Below BRE Guidelines 20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Windows
1 Lee High Road
21
0
0
0
0
21
3-5 Lee High Road
5
0
0
0
0
5
7 Lee High Road
6
0
0
0
0
6
9 Lee High Road
2
0
0
0
0
2
11-13 Lee High Road
3
0
0
0
0
3
15 Lee High Road
2
0
0
0
0
2
17 Lee High Road
9
0
0
0
0
9
19 Lee High Road
5
0
0
0
0
5
21 Lee High Road
7
0
0
0
0
7
14-16 Lee High Road
16
0
0
0
0
16
4-6 Lee High Road
16
0
0
0
0
16
1 Lewis Grove
6
0
0
0
0
6
1 Mercia Grove
7
0
0
0
0
7
2 Mercia Grove
7
0
0
0
0
7
3 Mercia Grove
8
0
0
0
0
8
4 Mercia Grove
7
0
0
0
0
7
5 Mercia Grove
7
0
0
0
0
7
6 Mercia Grove
7
0
0
0
0
7
7 Mercia Grove
7
0
0
0
0
7
8 Mercia Grove
7
0
0
0
0
7
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
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VSC SUMMARY
Address
Total that Meet BRE Guidelines
Below BRE Guidelines 20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Windows
9 Mercia Grove
7
0
0
0
0
7
10 Mercia Grove
9
0
0
0
0
9
11 Mercia Grove
7
0
0
0
0
7
12 Mercia Grove
10
0
0
0
0
10
13 Mercia Grove
10
0
0
0
0
10
14 Mercia Grove
7
0
0
0
0
7
15 Mercia Grove
7
0
0
0
0
7
16 Mercia Grove
6
0
0
0
0
6
17 Mercia Grove
7
0
0
0
0
7
18 Mercia Grove
9
0
0
0
0
9
19 Mercia Grove
7
0
0
0
0
7
20 Mercia Grove
7
0
0
0
0
7
21 Mercia Grove
7
0
0
0
0
7
23 Merci Grove
65
0
0
0
0
65
4 Albion Way
10
0
0
0
0
10
2 Albion Way
12
0
0
0
0
12
8 Bonfield Road
4
0
0
0
0
4
7 Bonfield Road
9
0
0
0
0
9
6 Bonfield Road
5
0
0
0
0
5
5 Bonfield Road
6
0
0
0
0
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
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VSC SUMMARY
Address
Total that Meet BRE Guidelines
Below BRE Guidelines 20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Windows
4 Bonfield Road
7
0
0
0
0
7
3 Bonfield Road
7
0
0
0
0
7
2 Bonfield Road
7
0
0
0
0
7
1 Bonfield Road
9
0
0
0
0
9
131-133 Lewisham High Street
41
2
0
0
2
43
135 Lewisham High Street
0
2
0
0
2
2
137 Lewisham High Street
0
2
0
0
2
2
139-141 Lewisham High Street
8
6
0
0
6
14
153 Lewisham High Street
0
4
4
0
8
8
155 Lewisham High Street
24
6
11
3
20
44
161 Lewisham High Street
1
3
3
0
6
7
163 Lewisham High Street
0
3
3
0
6
6
165 Lewisham High Street
0
3
1
2
6
6
167 Lewisham High Street
0
3
2
1
6
6
169 Lewisham High Street
1
1
2
0
3
4
171 Lewisham High Street
1
2
1
0
3
4
St Saviours Church, 175 Lewisham High Street
8
6
7
2
15
23
187 Lewisham High Street
0
2
4
0
6
6
189 Lewisham High Street
0
1
4
0
5
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
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VSC SUMMARY
Address
Total that Meet BRE Guidelines
Below BRE Guidelines 20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Windows
191-193 Lewisham High Street
0
5
5
0
10
10
195 Lewisham High Street
1
4
0
0
4
5
197 Lewisham High Street
25
5
0
0
5
30
203 Lewisham High Street
9
0
0
0
0
9
205 Lewisham High Street
17
0
0
0
0
17
207 Lewisham High Street
9
0
0
0
0
9
209-211 Lewisham High Street
18
0
0
0
0
18
226-230 Lewisham High Street
52
0
0
0
0
52
Riverdale House, 68 Molesworth Street
98
10
18
160
188
286
Mill Apartments, 68 Molesworth Street
45
7
0
14
21
66
23 Odell Walk
0
3
0
0
3
3
21 Odell Walk
0
3
0
0
3
3
19 Odell Walk
1
2
0
0
2
3
17 Odell Walk
1
2
0
0
2
3
15 Odell Walk
1
2
0
0
2
3
13 Odell Walk
1
2
0
0
2
3
11 Odell Walk
0
3
0
0
3
3
9 Odell Walk
0
3
0
0
3
3
7 Odell Walk
0
3
0
0
3
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY
Address
Total that Meet BRE Guidelines
Below BRE Guidelines 20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Windows
5 Odell Walk
0
3
0
0
3
3
3 Odell Walk
0
3
0
0
3
3
1 Odell Walk
0
3
0
0
3
3
Bellflower Court, Odell Walk
4
16
0
0
16
20
14 Odell Walk
5
1
2
0
3
8
12 Odell Walk
5
2
1
0
3
8
10 Odell Walk
5
2
1
0
3
8
8 Odell Walk
5
3
0
0
3
8
6 Odell Walk
5
3
0
0
3
8
4 Odell Walk
5
3
0
0
3
8
2 Odell Walk
5
3
0
0
3
8
1 Bankside Avenue
1
3
0
0
3
4
2 Bankside Avenue
0
4
0
0
4
4
3 Bankside Avenue
2
2
0
0
2
4
4 Bankside Avenue
2
2
0
0
2
4
5 Bankside Avenue
2
2
0
0
2
4
6 Bankside Avenue
4
4
0
0
4
8
1 Yew Tree Close
3
3
0
0
3
6
3 Yew Tree Close
3
3
0
0
3
6
5 Yew Tree Close
3
3
0
0
3
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY
Address
Total that Meet BRE Guidelines
Below BRE Guidelines 20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Windows
7 Yew Tree Close
3
3
0
0
3
6
9 Yew Tree Close
3
1
2
0
3
6
11 Yew Tree Close
3
1
2
0
3
6
13 Yew Tree Close
3
1
2
0
3
6
10 Yew Tree Close
5
0
3
0
3
8
8 Yew Tree Close
5
0
3
0
3
8
6 Yew Tree Close
5
2
1
0
3
8
4 Yew Tree Close
5
3
0
0
3
8
2 Yew Tree Close
5
3
0
0
3
8
7 Bankside Avenue
5
2
1
0
3
8
8 Bankside Avenue
1
2
1
0
3
4
9 Bankside Avenue
0
1
3
0
4
4
10 Bankside Avenue
0
0
4
0
4
4
11 Bankside Avenue
0
0
4
0
4
4
12 Bankside Avenue
0
0
4
0
4
4
13 Bankside Avenue
0
2
2
0
4
4
14 Bankside Avenue
0
2
2
0
4
4
15 Bankside Avenue
4
0
3
1
4
8
1 Elder Walk
3
3
0
0
3
6
3 Elder Walk
3
3
0
0
3
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY
Address
Total that Meet BRE Guidelines
Below BRE Guidelines 20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Windows
5 Elder Walk
3
3
0
0
3
6
7 Elder Walk
5
2
0
0
2
7
Mill House, Elder Walk
94
7
0
10
17
111
Venice Corte, 2 Elmira Street
209
16
1
0
17
226
Torre Vista, 45 Loampit Vale
143
7
0
0
7
150
Sienna Alto, 2 Cornmill Lane
328
54
36
6
96
424
Glass Mill Leisure Centre, 41 Loampit Vale
1
0
0
0
0
1
Lewisham Gateway (Under Construction)
463
31
55
108
194
657
50 Lewisham High Street
2
0
0
6
6
8
52 Lewisham High Street
0
0
0
7
7
7
58-60 Lewisham High Street
3
0
0
5
5
8
66 Lewisham High Street
0
0
0
8
8
8
86-88 Lewisham High Street
3
1
6
5
12
15
90 Lewisham High Street
0
0
0
4
4
4
92 Lewisham High Street
1
1
0
2
3
4
94 Lewisham High Street
1
1
2
0
3
4
96 Lewisham High Street
0
0
0
2
2
2
98 Lewisham High Street
0
1
4
2
7
7
116-118 Lewisham High Street
1
0
0
10
10
11
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY
Address
Total that Meet BRE Guidelines
Below BRE Guidelines 20-29% Loss
30-39.9% Loss
>=40% Loss
Total
Total No. of Windows
174-176 Lewisham High Street
0
0
0
6
6
6
198-206 Lewisham High Street
0
0
0
11
11
11
129 Lewisham High Street
7
2
0
0
2
9
127 Lewisham High Street
0
6
0
0
6
6
125 Lewisham High Street
0
8
0
0
8
8
123 Lewisham High Street
0
8
0
0
8
8
121 Lewisham High Street
0
6
0
0
6
6
117-119 Lewisham High Street
2
4
0
2
6
8
97-99 Lewisham High Street
19
6
0
0
6
25
93-95 Lewisham High Street
50
6
0
0
6
56
85-87 Lewisham High Street
66
5
0
0
5
71
110 Lewisham High Street
0
0
0
4
4
4
112 Lewisham High Street
0
0
0
3
3
3
114 Lewisham High Street
0
0
0
6
6
6
Total
2753
376
211
397
984
3737
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Table 12.17 – Cumulative NSL Summary with the Development in Place NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Rooms
Isabella Apartments, 102 Granville Park
28
0
0
0
0
28
25 Lewisham High Street
4
0
0
0
0
4
27 Lewisham High Street
4
0
0
0
0
4
29 Lewisham High Street
4
0
0
0
0
4
31 Lewisham High Street
6
0
0
0
0
6
1 Cressingham Road
7
0
0
0
0
7
3 Cressingham Road
4
0
0
0
0
4
5 Cressingham Road
4
0
0
0
0
4
7 Cressingham Road
4
0
0
0
0
4
9 Cressingham Road
4
0
0
0
0
4
11 Cressingham Road
4
0
0
0
0
4
13 Cressingham Road
4
0
0
0
0
4
15 Cressingham Road
4
0
0
0
0
4
17 Cressingham Road
5
0
0
0
0
5
19 Cressingham Road
4
0
0
0
0
4
21 Cressingham Road
10
0
0
0
0
10
23 Cressingham Road
4
0
0
0
0
4
16 Cressingham Road
6
0
0
0
0
6
14 Cressingham Road
6
0
0
0
0
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Rooms
12 Cressingham Road
6
0
0
0
0
6
10 Cressingham Road
6
0
0
0
0
6
8 Cressingham Road
6
0
0
0
0
6
6 Cressingham Road
6
0
0
0
0
6
4 Cressingham Road
6
0
0
0
0
6
2 Cressingham Road
6
0
0
0
0
6
St Stephens Church Vicarage, Cressingham Road
10
0
0
0
0
10
1 Stephens Grove
3
0
0
0
0
3
2 Stephens Grove
3
0
0
0
0
3
3 Stephens Grove
3
0
0
0
0
3
4 Stephens Grove
3
0
0
0
0
3
5 Stephens Grove
3
0
0
0
0
3
6 Stephens Grove
3
0
0
0
0
3
7 Stephens Grove
3
0
0
0
0
3
8 Stephens Grove
3
0
0
0
0
3
1 Lockmead Road
3
0
0
0
0
3
3 Lockmead Road
3
0
0
0
0
3
5 Lockmead Road
3
0
0
0
0
3
3 Boyne Road
3
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Rooms
1 Boyne Road
3
0
0
0
0
3
9 Stephens Grove
5
0
0
0
0
5
10 Stephens Grove
5
0
0
0
0
5
11 Stephens Grove
5
0
0
0
0
5
12 Stephens Grove
5
0
0
0
0
5
13 Stephens Grove
5
0
0
0
0
5
14 Stephens Grove
5
0
0
0
0
5
15 Stephens Grove
5
0
0
0
0
5
16 Stephens Grove
5
0
0
0
0
5
17 Stephens Grove
5
0
0
0
0
5
18 Stephens Grove
5
0
0
0
0
5
19 Stephens Grove
5
0
0
0
0
5
19 Granville Grove
3
0
0
0
0
3
20 Granville Grove
3
0
0
0
0
3
21 Granville Grove
3
0
0
0
0
3
22 Granville Grove
3
0
0
0
0
3
23 Granville Grove
3
0
0
0
0
3
24 Granville Grove
3
0
0
0
0
3
25 Granville Grove
3
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Rooms
27 Granville Grove
6
0
0
0
0
6
65-71 Lewisham High Street
20
0
0
0
0
20
85 Lewisham High Street, 1-3 Belmont Hill
4
0
0
0
0
4
5 Belmont Hill
2
0
0
0
0
2
7-9 Belmont Hill
2
0
0
0
0
2
2-4 Belmont Hill
14
0
0
0
0
14
1 Lee High Road
10
0
0
0
0
10
3-5 Lee High Road
3
0
0
0
0
3
7 Lee High Road
4
0
0
0
0
4
9 Lee High Road
1
0
0
0
0
1
11-13 Lee High Road
3
0
0
0
0
3
15 Lee High Road
1
0
0
0
0
1
17 Lee High Road
4
0
0
0
0
4
19 Lee High Road
4
0
0
0
0
4
21 Lee High Road
6
0
0
0
0
6
14-16 Lee High Road
10
0
0
0
0
10
4-6 Lee High Road
12
0
0
0
0
12
1 Lewis Grove
4
0
0
0
0
4
1 Mercia Grove
5
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Rooms
2 Mercia Grove
5
0
0
0
0
5
3 Mercia Grove
5
0
0
0
0
5
4 Mercia Grove
5
0
0
0
0
5
5 Mercia Grove
5
0
0
0
0
5
6 Mercia Grove
5
0
0
0
0
5
7 Mercia Grove
5
0
0
0
0
5
8 Mercia Grove
5
0
0
0
0
5
9 Mercia Grove
5
0
0
0
0
5
10 Mercia Grove
5
0
0
0
0
5
11 Mercia Grove
5
0
0
0
0
5
12 Mercia Grove
3
0
0
0
0
3
13 Mercia Grove
3
0
0
0
0
3
14 Mercia Grove
4
0
0
0
0
4
15 Mercia Grove
6
0
0
0
0
6
16 Mercia Grove
4
0
0
0
0
4
17 Mercia Grove
4
0
0
0
0
4
18 Mercia Grove
6
0
0
0
0
6
19 Mercia Grove
5
0
0
0
0
5
20 Mercia Grove
5
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Rooms
21 Mercia Grove
6
0
0
0
0
6
23 Merci Grove
29
0
0
0
0
29
4 Albion Way
6
0
0
0
0
6
2 Albion Way
7
0
0
0
0
7
8 Bonfield Road
3
0
0
0
0
3
7 Bonfield Road
4
0
0
0
0
4
6 Bonfield Road
4
0
0
0
0
4
5 Bonfield Road
5
0
0
0
0
5
4 Bonfield Road
5
0
0
0
0
5
3 Bonfield Road
6
0
0
0
0
6
2 Bonfield Road
6
0
0
0
0
6
1 Bonfield Road
6
0
0
0
0
6
131-133 Lewisham High Street
26
0
0
0
0
26
135 Lewisham High Street
1
1
0
0
1
2
137 Lewisham High Street
1
1
0
0
1
2
139-141 Lewisham High Street
8
2
0
0
2
10
153 Lewisham High Street
2
1
1
0
2
4
155 Lewisham High Street
10
3
0
0
3
13
161 Lewisham High Street
3
0
0
1
1
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Rooms
163 Lewisham High Street
1
1
0
1
2
3
165 Lewisham High Street
1
1
0
1
2
3
167 Lewisham High Street
1
1
0
1
2
3
169 Lewisham High Street
3
0
0
0
0
3
171 Lewisham High Street
1
2
0
1
3
4
St Saviours Church, 175 Lewisham High Street
7
2
3
1
6
13
187 Lewisham High Street
0
3
2
1
6
6
189 Lewisham High Street
2
3
0
0
3
5
191-193 Lewisham High Street
3
7
0
0
7
10
195 Lewisham High Street
3
2
0
0
2
5
197 Lewisham High Street
20
0
0
0
0
20
203 Lewisham High Street
6
0
0
0
0
6
205 Lewisham High Street
7
0
0
0
0
7
207 Lewisham High Street
3
0
0
0
0
3
209-211 Lewisham High Street
9
0
0
0
0
9
226-230 Lewisham High Street
52
0
0
0
0
52
Riverdale House, 68 Molesworth Street
98
38
18
33
89
187
Mill Apartments, 68 Molesworth Street
25
1
0
4
5
30
23 Odell Walk
2
0
0
0
0
2
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Rooms
21 Odell Walk
2
0
0
0
0
2
19 Odell Walk
2
0
0
0
0
2
17 Odell Walk
2
0
0
0
0
2
15 Odell Walk
2
0
0
0
0
2
13 Odell Walk
2
0
0
0
0
2
11 Odell Walk
2
0
0
0
0
2
9 Odell Walk
2
0
0
0
0
2
7 Odell Walk
2
0
0
0
0
2
5 Odell Walk
1
1
0
0
1
2
3 Odell Walk
1
1
0
0
1
2
1 Odell Walk
2
0
0
0
0
2
Bellflower Court, Odell Walk
12
0
0
0
0
12
14 Odell Walk
4
1
0
0
1
5
12 Odell Walk
3
2
0
0
2
5
10 Odell Walk
3
2
0
0
2
5
8 Odell Walk
4
1
0
0
1
5
6 Odell Walk
4
1
0
0
1
5
4 Odell Walk
4
1
0
0
1
5
2 Odell Walk
5
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Rooms
1 Bankside Avenue
2
2
0
0
2
4
2 Bankside Avenue
2
2
0
0
2
4
3 Bankside Avenue
2
2
0
0
2
4
4 Bankside Avenue
2
2
0
0
2
4
5 Bankside Avenue
3
1
0
0
1
4
6 Bankside Avenue
3
1
2
0
3
6
1 Yew Tree Close
4
0
0
0
0
4
3 Yew Tree Close
4
0
0
0
0
4
5 Yew Tree Close
4
0
0
0
0
4
7 Yew Tree Close
4
0
0
0
0
4
9 Yew Tree Close
4
0
0
0
0
4
11 Yew Tree Close
4
0
0
0
0
4
13 Yew Tree Close
3
1
0
0
1
4
10 Yew Tree Close
4
0
1
0
1
5
8 Yew Tree Close
4
1
0
0
1
5
6 Yew Tree Close
4
1
0
0
1
5
4 Yew Tree Close
5
0
0
0
0
5
2 Yew Tree Close
5
0
0
0
0
5
7 Bankside Avenue
4
1
1
0
2
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Rooms
8 Bankside Avenue
3
1
0
0
1
4
9 Bankside Avenue
0
2
1
1
4
4
10 Bankside Avenue
0
1
1
2
4
4
11 Bankside Avenue
0
1
1
2
4
4
12 Bankside Avenue
0
1
1
2
4
4
13 Bankside Avenue
0
2
0
2
4
4
14 Bankside Avenue
2
1
0
1
2
4
15 Bankside Avenue
2
2
0
2
4
6
1 Elder Walk
4
0
0
0
0
4
3 Elder Walk
4
0
0
0
0
4
5 Elder Walk
4
0
0
0
0
4
7 Elder Walk
4
0
0
0
0
4
Mill House, Elder Walk
91
4
0
0
4
95
Venice Corte, 2 Elmira Street
174
0
0
0
0
174
Torre Vista, 45 Loampit Vale
126
0
0
0
0
126
Sienna Alto, 2 Cornmill Lane
168
2
6
1
9
177
Glass Mill Leisure Centre, 41 Loampit Vale
1
0
0
0
0
1
Lewisham Gateway (Under Construction)
351
25
8
7
40
391
50 Lewisham High Street
0
2
1
2
5
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Rooms
52 Lewisham High Street
0
0
1
6
7
7
58-60 Lewisham High Street
2
1
1
2
4
6
66 Lewisham High Street
0
1
1
4
6
6
86-88 Lewisham High Street
2
1
1
10
12
14
90 Lewisham High Street
0
0
0
2
2
2
92 Lewisham High Street
0
0
1
2
3
3
94 Lewisham High Street
1
0
0
3
3
4
96 Lewisham High Street
0
0
0
2
2
2
98 Lewisham High Street
0
0
2
4
6
6
116-118 Lewisham High Street
1
0
0
10
10
11
174-176 Lewisham High Street
2
4
0
0
4
6
198-206 Lewisham High Street
0
0
0
11
11
11
129 Lewisham High Street
4
0
1
0
1
5
127 Lewisham High Street
2
0
1
0
1
3
125 Lewisham High Street
3
0
0
0
0
3
123 Lewisham High Street
3
0
0
0
0
3
121 Lewisham High Street
3
0
0
0
0
3
117-119 Lewisham High Street
0
0
0
4
4
4
97-99 Lewisham High Street
7
0
0
0
0
7
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
20-29% Loss
3039.9% Loss
>=40 % Loss
Total
Total No. of Rooms
93-95 Lewisham High Street
27
0
0
0
0
27
85-87 Lewisham High Street
10
0
0
0
0
10
110 Lewisham High Street
0
0
0
3
3
3
112 Lewisham High Street
1
1
0
0
1
2
114 Lewisham High Street
0
0
0
5
5
5
Total
1992
145
56
134
335
2327
12.11.11 The Cumulative Assessment technical findings of the VSC and NSL analysis (shown on Table 12.17 and Table 12.18) above record daylight effects and BRE transgressions that are consistent with those outlined within the Main Assessments. The significance classifications applied to the surrounding residential properties are therefore consistent with the Main Assessment. Cumulative Sunlight to Surrounding Properties 12.11.12 There are 2477 windows serving 1416 residential rooms surrounding the Site that are relevant for sunlight amenity assessment. These have all been assessed in terms of total and winter APSH. Full detailed results can be found at Appendix 12.3 and are summarised in Table 12.19.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Table 12.19 – Cumulative APSH Summary with the Development in Place APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>4 0%
Total
Total No. Rooms
Isabella Apartments, 102 Granville Park
28
0
0
0
0
0
0
0
0
28
25 Lewisham High Street
3
0
0
1
1
0
0
0
0
4
27 Lewisham High Street
3
0
0
1
1
0
0
0
0
4
29 Lewisham High Street
3
0
0
1
1
0
0
0
0
4
31 Lewisham High Street
6
0
0
0
0
0
0
0
0
6
1 Cressingham Road
7
0
0
0
0
0
0
0
0
7
3 Cressingham Road
4
0
0
0
0
0
0
0
0
4
5 Cressingham Road
4
0
0
0
0
0
0
0
0
4
7 Cressingham Road
4
0
0
0
0
0
0
0
0
4
9 Cressingham Road
4
0
0
0
0
0
0
0
0
4
11 Cressingham Road
4
0
0
0
0
0
0
0
0
4
13 Cressingham Road
4
0
0
0
0
0
0
0
0
4
15 Cressingham Road
4
0
0
0
0
0
0
0
0
4
17 Cressingham Road
5
0
0
0
0
0
0
0
0
5
19 Cressingham Road
4
0
0
0
0
0
0
0
0
4
21 Cressingham Road
10
0
0
0
0
0
0
0
0
10
23 Cressingham Road
4
0
0
0
0
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>4 0%
Total
Total No. Rooms
16 Cressingham Road
6
0
0
0
0
0
0
0
0
6
14 Cressingham Road
6
0
0
0
0
0
0
0
0
6
12 Cressingham Road
6
0
0
0
0
0
0
0
0
6
10 Cressingham Road
6
0
0
0
0
0
0
0
0
6
8 Cressingham Road
6
0
0
0
0
0
0
0
0
6
6 Cressingham Road
6
0
0
0
0
0
0
0
0
6
4 Cressingham Road
6
0
0
0
0
0
0
0
0
6
2 Cressingham Road
6
0
0
0
0
0
0
0
0
6
St Stephens Church Vicarage, Cressingham Road
10
0
0
0
0
0
0
0
0
10
1 Stephens Grove
3
0
0
0
0
0
0
0
0
3
2 Stephens Grove
3
0
0
0
0
0
0
0
0
3
3 Stephens Grove
3
0
0
0
0
0
0
0
0
3
4 Stephens Grove
3
0
0
0
0
0
0
0
0
3
5 Stephens Grove
3
0
0
0
0
0
0
0
0
3
6 Stephens Grove
3
0
0
0
0
0
0
0
0
3
7 Stephens Grove
3
0
0
0
0
0
0
0
0
3
8 Stephens Grove
3
0
0
0
0
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>4 0%
Total
Total No. Rooms
1 Lockmead Road
3
0
0
0
0
0
0
0
0
3
3 Lockmead Road
3
0
0
0
0
0
0
0
0
3
5 Lockmead Road
3
0
0
0
0
0
0
0
0
3
3 Boyne Road
3
0
0
0
0
0
0
0
0
3
1 Boyne Road
3
0
0
0
0
0
0
0
0
3
9 Stephens Grove
5
0
0
0
0
0
0
0
0
5
10 Stephens Grove
5
0
0
0
0
0
0
0
0
5
11 Stephens Grove
5
0
0
0
0
0
0
0
0
5
12 Stephens Grove
5
0
0
0
0
0
0
0
0
5
13 Stephens Grove
5
0
0
0
0
0
0
0
0
5
14 Stephens Grove
5
0
0
0
0
0
0
0
0
5
15 Stephens Grove
5
0
0
0
0
0
0
0
0
5
16 Stephens Grove
5
0
0
0
0
0
0
0
0
5
17 Stephens Grove
5
0
0
0
0
0
0
0
0
5
18 Stephens Grove
5
0
0
0
0
0
0
0
0
5
19 Stephens Grove
5
0
0
0
0
0
0
0
0
5
19 Granville Grove
3
0
0
0
0
0
0
0
0
3
20 Granville Grove
3
0
0
0
0
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>4 0%
Total
Total No. Rooms
21 Granville Grove
3
0
0
0
0
0
0
0
0
3
22 Granville Grove
3
0
0
0
0
0
0
0
0
3
23 Granville Grove
3
0
0
0
0
0
0
0
0
3
24 Granville Grove
3
0
0
0
0
0
0
0
0
3
25 Granville Grove
3
0
0
0
0
0
0
0
0
3
27 Granville Grove
6
0
0
0
0
0
0
0
0
6
65-71 Lewisham High Street
20
0
0
0
0
0
0
0
0
20
85 Lewisham High Street, 1-3 Belmont Hill
4
0
0
0
0
0
0
0
0
4
5 Belmont Hill
2
0
0
0
0
0
0
0
0
2
7-9 Belmont Hill
2
0
0
0
0
0
0
0
0
2
2-4 Belmont Hill
1
0
0
0
0
0
0
0
0
1
1 Lee High Road
3
0
0
0
0
0
0
0
0
3
3-5 Lee High Road
2
0
0
0
0
0
0
0
0
2
7 Lee High Road
4
0
0
0
0
0
0
0
0
4
9 Lee High Road
1
0
0
0
0
0
0
0
0
1
11-13 Lee High Road
3
0
0
0
0
0
0
0
0
3
15 Lee High Road
1
0
0
0
0
0
0
0
0
1
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>4 0%
Total
Total No. Rooms
17 Lee High Road
3
0
0
0
0
0
0
0
0
3
19 Lee High Road
3
0
0
0
0
0
0
0
0
3
21 Lee High Road
6
0
0
0
0
0
0
0
0
6
14-16 Lee High Road
9
0
0
0
0
0
0
0
0
9
4-6 Lee High Road
6
0
0
0
0
0
0
0
0
6
1 Lewis Grove
2
0
0
0
0
0
0
0
0
2
1 Mercia Grove
3
0
0
0
0
0
0
0
0
3
2 Mercia Grove
3
0
0
0
0
0
0
0
0
3
3 Mercia Grove
3
0
0
0
0
0
0
0
0
3
4 Mercia Grove
3
0
0
0
0
0
0
0
0
3
5 Mercia Grove
3
0
0
0
0
0
0
0
0
3
6 Mercia Grove
3
0
0
0
0
0
0
0
0
3
7 Mercia Grove
3
0
0
0
0
0
0
0
0
3
8 Mercia Grove
3
0
0
0
0
0
0
0
0
3
9 Mercia Grove
3
0
0
0
0
0
0
0
0
3
10 Mercia Grove
4
0
0
0
0
0
0
0
0
4
11 Mercia Grove
3
0
0
0
0
0
0
0
0
3
12 Mercia Grove
2
0
0
0
0
0
0
0
0
2
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>4 0%
Total
Total No. Rooms
13 Mercia Grove
2
0
0
0
0
0
0
0
0
2
14 Mercia Grove
2
0
0
0
0
0
0
0
0
2
15 Mercia Grove
2
0
0
0
0
0
0
0
0
2
16 Mercia Grove
2
0
0
0
0
0
0
0
0
2
17 Mercia Grove
2
0
0
0
0
0
0
0
0
2
18 Mercia Grove
4
0
0
0
0
0
0
0
0
4
19 Mercia Grove
2
0
0
0
0
0
0
0
0
2
20 Mercia Grove
2
0
0
0
0
0
0
0
0
2
21 Mercia Grove
3
0
0
0
0
0
0
0
0
3
23 Merci Grove
11
0
0
0
0
0
0
0
0
11
4 Albion Way
3
0
0
0
0
0
0
0
0
3
2 Albion Way
3
0
0
0
0
0
0
0
0
3
8 Bonfield Road
1
0
0
0
0
0
0
0
0
1
6 Bonfield Road
1
0
0
0
0
0
0
0
0
1
4 Bonfield Road
2
0
0
0
0
0
0
0
0
2
2 Bonfield Road
3
0
0
0
0
0
0
0
0
3
131-133 Lewisham High Street
12
0
0
0
0
0
0
0
0
12
139-141 Lewisham High Street
6
0
0
0
0
0
0
0
0
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>4 0%
Total
Total No. Rooms
155 Lewisham High Street
10
0
0
0
0
1
2
0
3
13
St Saviours Church, 175 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
197 Lewisham High Street
3
0
0
0
0
0
0
0
0
3
205 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
226-230 Lewisham High Street
25
0
0
0
0
0
0
0
0
25
Riverdale House, 68 Molesworth Street
34
0
0
0
0
0
0
0
0
34
Mill Apartments, 68 Molesworth Street
19
0
0
1
1
0
0
1
1
20
14 Odell Walk
3
0
0
0
0
0
0
0
0
3
12 Odell Walk
3
0
0
0
0
0
0
0
0
3
10 Odell Walk
3
0
0
0
0
0
0
0
0
3
8 Odell Walk
3
0
0
0
0
0
0
0
0
3
6 Odell Walk
3
0
0
0
0
0
0
0
0
3
4 Odell Walk
3
0
0
0
0
0
0
0
0
3
2 Odell Walk
3
0
0
0
0
0
0
0
0
3
1 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
2 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
3 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>4 0%
Total
Total No. Rooms
4 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
5 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
6 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
1 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
3 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
5 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
7 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
9 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
11 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
13 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
10 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
8 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
6 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
4 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
2 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
7 Bankside Avenue
6
0
0
0
0
0
0
0
0
6
8 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
9 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>4 0%
Total
Total No. Rooms
10 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
11 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
12 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
13 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
14 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
15 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
1 Elder Walk
2
0
0
0
0
0
0
0
0
2
3 Elder Walk
2
0
0
0
0
0
0
0
0
2
5 Elder Walk
2
0
0
0
0
0
0
0
0
2
7 Elder Walk
2
0
0
0
0
0
0
0
0
2
Mill House, Elder Walk
38
0
0
0
0
0
2
7
9
47
Venice Corte, 2 Elmira Street
60
0
0
0
0
0
0
0
0
60
Sienna Alto, 2 Cornmill Lane
152
0
0
14
14
12
6
7
25
177
Glass Mill Leisure Centre, 41 Loampit Vale
1
0
0
0
0
0
0
0
0
1
Lewisham Gateway (Under Construction)
379
0
0
6
6
3
1
8
12
391
50 Lewisham High Street
1
0
0
4
4
0
0
4
4
5
52 Lewisham High Street
1
0
0
4
4
0
0
6
6
7
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>4 0%
Total
Total No. Rooms
58-60 Lewisham High Street
1
0
0
5
5
0
0
4
4
6
66 Lewisham High Street
0
0
0
6
6
0
0
6
6
6
86-88 Lewisham High Street
3
0
0
1
1
0
9
2
11
14
90 Lewisham High Street
1
0
0
0
0
0
0
1
1
2
92 Lewisham High Street
2
0
0
0
0
0
0
1
1
3
129 Lewisham High Street
4
0
0
0
0
0
0
0
0
4
117-119 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
97-99 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
93-95 Lewisham High Street
11
0
0
0
0
0
0
0
0
11
85-87 Lewisham High Street
5
0
0
0
0
0
0
0
0
5
Total
1329
0
0
44
44
16
20
47
83
1416
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
12.11.13 Cumulative Assessment technical findings of the APSH analysis (shown on Table 12.19) above record daylight effects and BRE transgressions that are consistent with those outlined within the Main Assessments. The significance classifications applied to the surrounding residential properties are therefore consistent with the Main Assessment. Cumulative Sun on Ground
12.11.14 The cumulative proposed Sun on Ground assessment have not been undertaken given the extent of the cumulative scheme considered within the surrounding context. The Cumulative Open Market is low-rise and will not have a bearing on the surrounding amenity spaces included within the technical assessments. Illustrative Masterplan Scheme: Daylight to Surrounding Properties 12.11.15 The Illustrative Masterplan retains the hybrid nature of the proposal and comprises the detailed N1 and N2 building in conjunction with the outline masterplan scheme. The illustrative outline masterplan element of the scheme has been rationalised to represent a more realistic proposal that is likely to be captured within a reserved matters application in a future programme. 12.11.16 There are 3737 windows serving 2327 residential rooms within the assessed properties surrounding the Site. These have all been assessed in terms of both VSC and NSL. Full detailed results can be found at Appendices 12.2 and are summarised in Table 12.20 and Table 12.21 and the properties that record full BRE compliance, in respect of VSC and NSL, highlighted green. Table 12.20 - VSC Summary with the Development in Place (Illustrative Masterplan: Main Assessment) VSC SUMMARY Below BRE Guidelines Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40 % Loss
Tota l
Total No. of Window s
Isabella Apartments, 102 Granville Park
40
0
0
0
0
40
25 Lewisham High Street
7
0
0
0
0
7
27 Lewisham High Street
6
0
0
0
0
6
29 Lewisham High Street
6
0
0
0
0
6
31 Lewisham High Street
9
0
0
0
0
9
1 Cressingham Road
9
0
0
0
0
9
Address
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40 % Loss
Tota l
Total No. of Window s
3 Cressingham Road
5
0
0
0
0
5
5 Cressingham Road
5
0
0
0
0
5
7 Cressingham Road
5
0
0
0
0
5
9 Cressingham Road
5
0
0
0
0
5
11 Cressingham Road
5
0
0
0
0
5
13 Cressingham Road
5
0
0
0
0
5
15 Cressingham Road
5
0
0
0
0
5
17 Cressingham Road
6
0
0
0
0
6
19 Cressingham Road
5
0
0
0
0
5
21 Cressingham Road
10
0
0
0
0
10
23 Cressingham Road
6
0
0
0
0
6
16 Cressingham Road
8
0
0
0
0
8
14 Cressingham Road
9
0
0
0
0
9
12 Cressingham Road
9
0
0
0
0
9
10 Cressingham Road
9
0
0
0
0
9
8 Cressingham Road
8
0
0
0
0
8
6 Cressingham Road
8
0
0
0
0
8
4 Cressingham Road
8
0
0
0
0
8
2 Cressingham Road
8
0
0
0
0
8
Address
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40 % Loss
Tota l
Total No. of Window s
St Stephens Church Vicarage, Cressingham Road
23
0
0
0
0
23
1 Stephens Grove
5
0
0
0
0
5
2 Stephens Grove
4
0
0
1
1
5
3 Stephens Grove
5
0
0
0
0
5
4 Stephens Grove
4
0
0
1
1
5
5 Stephens Grove
5
0
0
0
0
5
6 Stephens Grove
4
0
0
1
1
5
7 Stephens Grove
5
0
0
0
0
5
8 Stephens Grove
4
0
1
0
1
5
1 Lockmead Road
5
0
0
0
0
5
3 Lockmead Road
5
0
0
0
0
5
5 Lockmead Road
7
0
0
0
0
7
3 Boyne Road
6
0
0
0
0
6
1 Boyne Road
9
0
0
0
0
9
9 Stephens Grove
8
0
0
0
0
8
10 Stephens Grove
5
0
0
0
0
5
11 Stephens Grove
5
0
0
0
0
5
12 Stephens Grove
5
0
0
0
0
5
13 Stephens Grove
5
0
0
0
0
5
Address
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40 % Loss
Tota l
Total No. of Window s
14 Stephens Grove
5
0
0
0
0
5
15 Stephens Grove
5
0
0
0
0
5
16 Stephens Grove
5
0
0
0
0
5
17 Stephens Grove
5
0
0
0
0
5
18 Stephens Grove
5
0
0
0
0
5
19 Stephens Grove
5
0
0
0
0
5
19 Granville Grove
5
0
0
0
0
5
20 Granville Grove
4
1
0
0
1
5
21 Granville Grove
5
0
0
0
0
5
22 Granville Grove
4
0
0
1
1
5
23 Granville Grove
5
0
0
0
0
5
24 Granville Grove
4
0
0
1
1
5
25 Granville Grove
5
0
0
0
0
5
27 Granville Grove
9
0
1
0
1
10
65-71 Lewisham High Street
44
0
0
0
0
44
85 Lewisham High Street, 1-3 Belmont Hill
13
0
0
0
0
13
5 Belmont Hill
2
0
0
0
0
2
7-9 Belmont Hill
2
0
0
0
0
2
2-4 Belmont Hill
29
0
0
0
0
29
Address
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40 % Loss
Tota l
Total No. of Window s
1 Lee High Road
21
0
0
0
0
21
3-5 Lee High Road
5
0
0
0
0
5
7 Lee High Road
6
0
0
0
0
6
9 Lee High Road
2
0
0
0
0
2
11-13 Lee High Road
3
0
0
0
0
3
15 Lee High Road
2
0
0
0
0
2
17 Lee High Road
9
0
0
0
0
9
19 Lee High Road
5
0
0
0
0
5
21 Lee High Road
7
0
0
0
0
7
14-16 Lee High Road
16
0
0
0
0
16
4-6 Lee High Road
16
0
0
0
0
16
1 Lewis Grove
6
0
0
0
0
6
1 Mercia Grove
7
0
0
0
0
7
2 Mercia Grove
7
0
0
0
0
7
3 Mercia Grove
8
0
0
0
0
8
4 Mercia Grove
7
0
0
0
0
7
5 Mercia Grove
7
0
0
0
0
7
6 Mercia Grove
7
0
0
0
0
7
7 Mercia Grove
7
0
0
0
0
7
Address
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40 % Loss
Tota l
Total No. of Window s
8 Mercia Grove
7
0
0
0
0
7
9 Mercia Grove
7
0
0
0
0
7
10 Mercia Grove
9
0
0
0
0
9
11 Mercia Grove
7
0
0
0
0
7
12 Mercia Grove
10
0
0
0
0
10
13 Mercia Grove
10
0
0
0
0
10
14 Mercia Grove
7
0
0
0
0
7
15 Mercia Grove
7
0
0
0
0
7
16 Mercia Grove
6
0
0
0
0
6
17 Mercia Grove
7
0
0
0
0
7
18 Mercia Grove
9
0
0
0
0
9
19 Mercia Grove
7
0
0
0
0
7
20 Mercia Grove
7
0
0
0
0
7
21 Mercia Grove
7
0
0
0
0
7
23 Merci Grove
65
0
0
0
0
65
4 Albion Way
10
0
0
0
0
10
2 Albion Way
12
0
0
0
0
12
8 Bonfield Road
4
0
0
0
0
4
7 Bonfield Road
9
0
0
0
0
9
Address
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40 % Loss
Tota l
Total No. of Window s
6 Bonfield Road
5
0
0
0
0
5
5 Bonfield Road
6
0
0
0
0
6
4 Bonfield Road
7
0
0
0
0
7
3 Bonfield Road
7
0
0
0
0
7
2 Bonfield Road
7
0
0
0
0
7
1 Bonfield Road
9
0
0
0
0
9
131-133 Lewisham High Street
43
0
0
0
0
43
135 Lewisham High Street
2
0
0
0
0
2
137 Lewisham High Street
2
0
0
0
0
2
139-141 Lewisham High Street
14
0
0
0
0
14
153 Lewisham High Street
2
6
0
0
6
8
155 Lewisham High Street
26
15
3
0
18
44
161 Lewisham High Street
3
4
0
0
4
7
163 Lewisham High Street
3
3
0
0
3
6
165 Lewisham High Street
3
1
1
1
3
6
167 Lewisham High Street
2
3
0
1
4
6
169 Lewisham High Street
2
2
0
0
2
4
171 Lewisham High Street
4
0
0
0
0
4
St Saviours Church, 175 Lewisham High Street
14
7
2
0
9
23
Address
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40 % Loss
Tota l
Total No. of Window s
187 Lewisham High Street
2
4
0
0
4
6
189 Lewisham High Street
1
4
0
0
4
5
191-193 Lewisham High Street
4
6
0
0
6
10
195 Lewisham High Street
5
0
0
0
0
5
197 Lewisham High Street
30
0
0
0
0
30
203 Lewisham High Street
9
0
0
0
0
9
205 Lewisham High Street
17
0
0
0
0
17
207 Lewisham High Street
9
0
0
0
0
9
209-211 Lewisham High Street
18
0
0
0
0
18
226-230 Lewisham High Street
52
0
0
0
0
52
Riverdale House, 68 Molesworth Street
119
9
97
61
167
286
Mill Apartments, 68 Molesworth Street
52
0
1
13
14
66
23 Odell Walk
3
0
0
0
0
3
21 Odell Walk
3
0
0
0
0
3
19 Odell Walk
3
0
0
0
0
3
17 Odell Walk
3
0
0
0
0
3
15 Odell Walk
3
0
0
0
0
3
13 Odell Walk
3
0
0
0
0
3
Address
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40 % Loss
Tota l
Total No. of Window s
11 Odell Walk
3
0
0
0
0
3
9 Odell Walk
3
0
0
0
0
3
7 Odell Walk
3
0
0
0
0
3
5 Odell Walk
3
0
0
0
0
3
3 Odell Walk
3
0
0
0
0
3
1 Odell Walk
2
1
0
0
1
3
Bellflower Court, Odell Walk
20
0
0
0
0
20
14 Odell Walk
5
3
0
0
3
8
12 Odell Walk
5
3
0
0
3
8
10 Odell Walk
7
1
0
0
1
8
8 Odell Walk
7
1
0
0
1
8
6 Odell Walk
8
0
0
0
0
8
4 Odell Walk
8
0
0
0
0
8
2 Odell Walk
8
0
0
0
0
8
1 Bankside Avenue
4
0
0
0
0
4
2 Bankside Avenue
4
0
0
0
0
4
3 Bankside Avenue
4
0
0
0
0
4
4 Bankside Avenue
4
0
0
0
0
4
5 Bankside Avenue
4
0
0
0
0
4
Address
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40 % Loss
Tota l
Total No. of Window s
6 Bankside Avenue
6
2
0
0
2
8
1 Yew Tree Close
6
0
0
0
0
6
3 Yew Tree Close
6
0
0
0
0
6
5 Yew Tree Close
5
1
0
0
1
6
7 Yew Tree Close
4
2
0
0
2
6
9 Yew Tree Close
4
2
0
0
2
6
11 Yew Tree Close
4
2
0
0
2
6
13 Yew Tree Close
3
3
0
0
3
6
10 Yew Tree Close
5
3
0
0
3
8
8 Yew Tree Close
5
3
0
0
3
8
6 Yew Tree Close
7
1
0
0
1
8
4 Yew Tree Close
7
1
0
0
1
8
2 Yew Tree Close
8
0
0
0
0
8
7 Bankside Avenue
6
2
0
0
2
8
8 Bankside Avenue
3
1
0
0
1
4
9 Bankside Avenue
1
3
0
0
3
4
10 Bankside Avenue
0
4
0
0
4
4
11 Bankside Avenue
0
4
0
0
4
4
12 Bankside Avenue
0
4
0
0
4
4
Address
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40 % Loss
Tota l
Total No. of Window s
13 Bankside Avenue
2
2
0
0
2
4
14 Bankside Avenue
2
2
0
0
2
4
15 Bankside Avenue
4
4
0
0
4
8
1 Elder Walk
6
0
0
0
0
6
3 Elder Walk
6
0
0
0
0
6
5 Elder Walk
6
0
0
0
0
6
7 Elder Walk
6
1
0
0
1
7
Mill House, Elder Walk
101
0
4
6
10
111
Venice Corte, 2 Elmira Street
224
1
1
0
2
226
Torre Vista, 45 Loampit Vale
147
3
0
0
3
150
Sienna Alto, 2 Cornmill Lane
365
48
11
0
59
424
Glass Mill Leisure Centre, 41 Loampit Vale
1
0
0
0
0
1
Lewisham Gateway (Under Construction)
486
23
66
82
171
657
50 Lewisham High Street
2
0
0
6
6
8
52 Lewisham High Street
0
0
0
7
7
7
58-60 Lewisham High Street
3
0
0
5
5
8
66 Lewisham High Street
0
0
0
8
8
8
86-88 Lewisham High Street
4
2
8
1
11
15
Address
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40 % Loss
Tota l
Total No. of Window s
90 Lewisham High Street
0
0
1
3
4
4
92 Lewisham High Street
1
1
2
0
3
4
94 Lewisham High Street
1
1
2
0
3
4
96 Lewisham High Street
0
0
0
2
2
2
98 Lewisham High Street
0
2
3
2
7
7
116-118 Lewisham High Street
1
0
0
10
10
11
174-176 Lewisham High Street
0
0
0
6
6
6
198-206 Lewisham High Street
0
0
5
6
11
11
129 Lewisham High Street
9
0
0
0
0
9
127 Lewisham High Street
3
3
0
0
3
6
125 Lewisham High Street
4
4
0
0
4
8
123 Lewisham High Street
0
8
0
0
8
8
121 Lewisham High Street
0
6
0
0
6
6
117-119 Lewisham High Street
2
4
0
2
6
8
97-99 Lewisham High Street
19
6
0
0
6
25
93-95 Lewisham High Street
52
4
0
0
4
56
85-87 Lewisham High Street
70
1
0
0
1
71
110 Lewisham High Street
0
0
0
4
4
4
112 Lewisham High Street
0
0
0
3
3
3
Address
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Total that Meet BRE Guidelines
20-29% Loss
30-39.9% Loss
>=40 % Loss
Tota l
Total No. of Window s
114 Lewisham High Street
0
0
0
6
6
6
Total
3050
238
209
240
687
3737
Address
Table 12.21 – NSL Summary with the Development in Place (Illustrative Masterplan: Main Assessment) NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
Isabella Apartments, 102 Granville Park
28
0
0
0
0
28
25 Lewisham High Street
4
0
0
0
0
4
27 Lewisham High Street
4
0
0
0
0
4
29 Lewisham High Street
4
0
0
0
0
4
31 Lewisham High Street
6
0
0
0
0
6
1 Cressingham Road
7
0
0
0
0
7
3 Cressingham Road
4
0
0
0
0
4
5 Cressingham Road
4
0
0
0
0
4
7 Cressingham Road
4
0
0
0
0
4
9 Cressingham Road
4
0
0
0
0
4
11 Cressingham Road
4
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
13 Cressingham Road
4
0
0
0
0
4
15 Cressingham Road
4
0
0
0
0
4
17 Cressingham Road
5
0
0
0
0
5
19 Cressingham Road
4
0
0
0
0
4
21 Cressingham Road
10
0
0
0
0
10
23 Cressingham Road
4
0
0
0
0
4
16 Cressingham Road
6
0
0
0
0
6
14 Cressingham Road
6
0
0
0
0
6
12 Cressingham Road
6
0
0
0
0
6
10 Cressingham Road
6
0
0
0
0
6
8 Cressingham Road
6
0
0
0
0
6
6 Cressingham Road
6
0
0
0
0
6
4 Cressingham Road
6
0
0
0
0
6
2 Cressingham Road
6
0
0
0
0
6
St Stephens Church Vicarage, Cressingham Road
10
0
0
0
0
10
1 Stephens Grove
3
0
0
0
0
3
2 Stephens Grove
3
0
0
0
0
3
3 Stephens Grove
3
0
0
0
0
3
4 Stephens Grove
3
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
5 Stephens Grove
3
0
0
0
0
3
6 Stephens Grove
3
0
0
0
0
3
7 Stephens Grove
3
0
0
0
0
3
8 Stephens Grove
3
0
0
0
0
3
1 Lockmead Road
3
0
0
0
0
3
3 Lockmead Road
3
0
0
0
0
3
5 Lockmead Road
3
0
0
0
0
3
3 Boyne Road
3
0
0
0
0
3
1 Boyne Road
3
0
0
0
0
3
9 Stephens Grove
5
0
0
0
0
5
10 Stephens Grove
5
0
0
0
0
5
11 Stephens Grove
5
0
0
0
0
5
12 Stephens Grove
5
0
0
0
0
5
13 Stephens Grove
5
0
0
0
0
5
14 Stephens Grove
5
0
0
0
0
5
15 Stephens Grove
5
0
0
0
0
5
16 Stephens Grove
5
0
0
0
0
5
17 Stephens Grove
5
0
0
0
0
5
18 Stephens Grove
5
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
19 Stephens Grove
5
0
0
0
0
5
19 Granville Grove
3
0
0
0
0
3
20 Granville Grove
3
0
0
0
0
3
21 Granville Grove
3
0
0
0
0
3
22 Granville Grove
3
0
0
0
0
3
23 Granville Grove
3
0
0
0
0
3
24 Granville Grove
3
0
0
0
0
3
25 Granville Grove
3
0
0
0
0
3
27 Granville Grove
6
0
0
0
0
6
65-71 Lewisham High Street
20
0
0
0
0
20
85 Lewisham High Street, 1-3 Belmont Hill
4
0
0
0
0
4
5 Belmont Hill
2
0
0
0
0
2
7-9 Belmont Hill
2
0
0
0
0
2
2-4 Belmont Hill
14
0
0
0
0
14
1 Lee High Road
10
0
0
0
0
10
3-5 Lee High Road
3
0
0
0
0
3
7 Lee High Road
4
0
0
0
0
4
9 Lee High Road
1
0
0
0
0
1
11-13 Lee High Road
3
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
15 Lee High Road
1
0
0
0
0
1
17 Lee High Road
4
0
0
0
0
4
19 Lee High Road
4
0
0
0
0
4
21 Lee High Road
6
0
0
0
0
6
14-16 Lee High Road
10
0
0
0
0
10
4-6 Lee High Road
12
0
0
0
0
12
1 Lewis Grove
4
0
0
0
0
4
1 Mercia Grove
5
0
0
0
0
5
2 Mercia Grove
5
0
0
0
0
5
3 Mercia Grove
5
0
0
0
0
5
4 Mercia Grove
5
0
0
0
0
5
5 Mercia Grove
5
0
0
0
0
5
6 Mercia Grove
5
0
0
0
0
5
7 Mercia Grove
5
0
0
0
0
5
8 Mercia Grove
5
0
0
0
0
5
9 Mercia Grove
5
0
0
0
0
5
10 Mercia Grove
5
0
0
0
0
5
11 Mercia Grove
5
0
0
0
0
5
12 Mercia Grove
3
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
13 Mercia Grove
3
0
0
0
0
3
14 Mercia Grove
4
0
0
0
0
4
15 Mercia Grove
6
0
0
0
0
6
16 Mercia Grove
4
0
0
0
0
4
17 Mercia Grove
4
0
0
0
0
4
18 Mercia Grove
6
0
0
0
0
6
19 Mercia Grove
5
0
0
0
0
5
20 Mercia Grove
5
0
0
0
0
5
21 Mercia Grove
6
0
0
0
0
6
23 Merci Grove
29
0
0
0
0
29
4 Albion Way
6
0
0
0
0
6
2 Albion Way
7
0
0
0
0
7
8 Bonfield Road
3
0
0
0
0
3
7 Bonfield Road
4
0
0
0
0
4
6 Bonfield Road
4
0
0
0
0
4
5 Bonfield Road
5
0
0
0
0
5
4 Bonfield Road
5
0
0
0
0
5
3 Bonfield Road
6
0
0
0
0
6
2 Bonfield Road
6
0
0
0
0
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
1 Bonfield Road
6
0
0
0
0
6
131-133 Lewisham High Street
26
0
0
0
0
26
135 Lewisham High Street
2
0
0
0
0
2
137 Lewisham High Street
2
0
0
0
0
2
139-141 Lewisham High Street
10
0
0
0
0
10
153 Lewisham High Street
3
1
0
0
1
4
155 Lewisham High Street
13
0
0
0
0
13
161 Lewisham High Street
3
0
0
1
1
4
163 Lewisham High Street
2
0
0
1
1
3
165 Lewisham High Street
2
0
0
1
1
3
167 Lewisham High Street
1
1
0
1
2
3
169 Lewisham High Street
3
0
0
0
0
3
171 Lewisham High Street
2
1
1
0
2
4
St Saviours Church, 175 Lewisham High Street
11
2
0
0
2
13
187 Lewisham High Street
2
3
0
1
4
6
189 Lewisham High Street
5
0
0
0
0
5
191-193 Lewisham High Street
10
0
0
0
0
10
195 Lewisham High Street
5
0
0
0
0
5
197 Lewisham High Street
20
0
0
0
0
20
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
203 Lewisham High Street
6
0
0
0
0
6
205 Lewisham High Street
7
0
0
0
0
7
207 Lewisham High Street
3
0
0
0
0
3
209-211 Lewisham High Street
9
0
0
0
0
9
226-230 Lewisham High Street
52
0
0
0
0
52
Riverdale House, 68 Molesworth Street
143
31
13
0
44
187
Mill Apartments, 68 Molesworth Street
25
1
0
4
5
30
23 Odell Walk
2
0
0
0
0
2
21 Odell Walk
2
0
0
0
0
2
19 Odell Walk
2
0
0
0
0
2
17 Odell Walk
2
0
0
0
0
2
15 Odell Walk
2
0
0
0
0
2
13 Odell Walk
2
0
0
0
0
2
11 Odell Walk
2
0
0
0
0
2
9 Odell Walk
2
0
0
0
0
2
7 Odell Walk
2
0
0
0
0
2
5 Odell Walk
2
0
0
0
0
2
3 Odell Walk
2
0
0
0
0
2
1 Odell Walk
2
0
0
0
0
2
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
Bellflower Court, Odell Walk
12
0
0
0
0
12
14 Odell Walk
4
1
0
0
1
5
12 Odell Walk
4
1
0
0
1
5
10 Odell Walk
4
1
0
0
1
5
8 Odell Walk
5
0
0
0
0
5
6 Odell Walk
5
0
0
0
0
5
4 Odell Walk
5
0
0
0
0
5
2 Odell Walk
5
0
0
0
0
5
1 Bankside Avenue
4
0
0
0
0
4
2 Bankside Avenue
4
0
0
0
0
4
3 Bankside Avenue
4
0
0
0
0
4
4 Bankside Avenue
4
0
0
0
0
4
5 Bankside Avenue
4
0
0
0
0
4
6 Bankside Avenue
5
1
0
0
1
6
1 Yew Tree Close
4
0
0
0
0
4
3 Yew Tree Close
4
0
0
0
0
4
5 Yew Tree Close
4
0
0
0
0
4
7 Yew Tree Close
4
0
0
0
0
4
9 Yew Tree Close
4
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
11 Yew Tree Close
4
0
0
0
0
4
13 Yew Tree Close
4
0
0
0
0
4
10 Yew Tree Close
5
0
0
0
0
5
8 Yew Tree Close
5
0
0
0
0
5
6 Yew Tree Close
5
0
0
0
0
5
4 Yew Tree Close
5
0
0
0
0
5
2 Yew Tree Close
5
0
0
0
0
5
7 Bankside Avenue
5
1
0
0
1
6
8 Bankside Avenue
4
0
0
0
0
4
9 Bankside Avenue
1
3
0
0
3
4
10 Bankside Avenue
3
1
0
0
1
4
11 Bankside Avenue
4
0
0
0
0
4
12 Bankside Avenue
4
0
0
0
0
4
13 Bankside Avenue
2
1
1
0
2
4
14 Bankside Avenue
3
1
0
0
1
4
15 Bankside Avenue
4
2
0
0
2
6
1 Elder Walk
4
0
0
0
0
4
3 Elder Walk
4
0
0
0
0
4
5 Elder Walk
4
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
7 Elder Walk
4
0
0
0
0
4
Mill House, Elder Walk
95
0
0
0
0
95
Venice Corte, 2 Elmira Street
174
0
0
0
0
174
Torre Vista, 45 Loampit Vale
126
0
0
0
0
126
Sienna Alto, 2 Cornmill Lane
175
2
0
0
2
177
Glass Mill Leisure Centre, 41 Loampit Vale
1
0
0
0
0
1
Lewisham Gateway (Under Construction)
365
12
8
6
26
391
50 Lewisham High Street
0
2
1
2
5
5
52 Lewisham High Street
0
0
1
6
7
7
58-60 Lewisham High Street
2
1
1
2
4
6
66 Lewisham High Street
0
1
1
4
6
6
86-88 Lewisham High Street
3
0
3
8
11
14
90 Lewisham High Street
0
0
0
2
2
2
92 Lewisham High Street
0
1
2
0
3
3
94 Lewisham High Street
1
0
1
2
3
4
96 Lewisham High Street
0
0
0
2
2
2
98 Lewisham High Street
0
1
2
3
6
6
116-118 Lewisham High Street
2
1
2
6
9
11
174-176 Lewisham High Street
6
0
0
0
0
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
198-206 Lewisham High Street
0
0
6
5
11
11
129 Lewisham High Street
5
0
0
0
0
5
127 Lewisham High Street
2
0
1
0
1
3
125 Lewisham High Street
3
0
0
0
0
3
123 Lewisham High Street
3
0
0
0
0
3
121 Lewisham High Street
3
0
0
0
0
3
117-119 Lewisham High Street
0
0
0
4
4
4
97-99 Lewisham High Street
7
0
0
0
0
7
93-95 Lewisham High Street
27
0
0
0
0
27
85-87 Lewisham High Street
10
0
0
0
0
10
110 Lewisham High Street
0
0
2
1
3
3
112 Lewisham High Street
1
1
0
0
1
2
114 Lewisham High Street
1
3
1
0
4
5
Total
2140
78
47
62
187
2327
12.11.17
The BRE Guidelines state that: “…the diffuse daylighting of the existing building may be adversely affected if either the VSC measured at the centre of an existing main window is less than 27% and less than 0.8 times its former value [or] the area of the working plane in a room which can receive direct skylight is reduced to less than 0.8 times its former value.”
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
12.11.18 In situations where the Development would result in fully BRE compliant VSC and NSL alterations to the windows and rooms within a property, the effect on the daylight amenity to that property is considered to be of negligible significance. 12.11.19 The following properties will experience alterations which, in accordance with the BRE Guidelines, will not be noticeable to the occupants and therefore classified as negligible:
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •
1 Bankside Avenue 1 Bonfield Road 1 Boyne Road 1 Cressingham Road 1 Elder Walk 1 Lee High Road 1 Lewis Grove 1 Lockmead Road 1 Mercia Grove 1 Stephens Grove 1 Yew Tree Close 10 Cressingham Road 10 Mercia Grove 10 Stephens Grove 11 Cressingham Road 11 Mercia Grove 11 Odell Walk 11 Stephens Grove 11-13 Lee High Road 12 Cressingham Road 12 Mercia Grove 12 Stephens Grove 129 Lewisham High Street 13 Cressingham Road 13 Mercia Grove 13 Odell Walk 13 Stephens Grove 131-133 Lewisham High Street 135 Lewisham High Street 137 Lewisham High Street 139-141 Lewisham High Street 14 Cressingham Road 14 Mercia Grove 14 Stephens Grove 14-16 Lee High Road 15 Cressingham Road
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •
15 Lee High Road 15 Mercia Grove 15 Odell Walk 15 Stephens Grove 16 Cressingham Road 16 Mercia Grove 16 Stephens Grove 17 Cressingham Road 17 Lee High Road 17 Mercia Grove 17 Odell Walk 17 Stephens Grove 18 Mercia Grove 18 Stephens Grove 19 Cressingham Road 19 Granville Grove 19 Lee High Road 19 Mercia Grove 19 Odell Walk 19 Stephens Grove 195 Lewisham High Street 197 Lewisham High Street 2 Albion Way 2 Bankside Avenue 2 Bonfield Road 2 Cressingham Road 2 Mercia Grove 2 Odell Walk 2 Yew Tree Close 20 Mercia Grove 203 Lewisham High Street 205 Lewisham High Street 207 Lewisham High Street 209-211 Lewisham High Street 21 Cressingham Road 21 Granville Grove Plowman Craven 46730 October 2024
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •
21 Lee High Road 21 Mercia Grove 21 Odell Walk 226-230 Lewisham High Street 23 Cressingham Road 23 Granville Grove 23 Merci Grove 23 Odell Walk 2-4 Belmont Hill 25 Granville Grove 25 Lewisham High Street 27 Lewisham High Street 29 Lewisham High Street 3 Bankside Avenue 3 Bonfield Road 3 Boyne Road 3 Cressingham Road 3 Elder Walk 3 Lockmead Road 3 Mercia Grove 3 Odell Walk 3 Stephens Grove 3 Yew Tree Close 31 Lewisham High Street 3-5 Lee High Road 4 Albion Way 4 Bankside Avenue 4 Bonfield Road 4 Cressingham Road 4 Mercia Grove 4 Odell Walk 4-6 Lee High Road 5 Bankside Avenue
• 5 Belmont Hill • 5 Bonfield Road • 5 Cressingham Road • 5 Elder Walk • 5 Lockmead Road • 5 Mercia Grove • 5 Odell Walk • 5 Stephens Grove • 6 Bonfield Road • 6 Cressingham Road • 6 Mercia Grove • 6 Odell Walk • 65-71 Lewisham High Street • 7 Bonfield Road • 7 Cressingham Road • 7 Lee High Road • 7 Mercia Grove • 7 Odell Walk • 7 Stephens Grove • 7-9 Belmont Hill • 8 Bonfield Road • 8 Cressingham Road • 8 Mercia Grove • 85 Lewisham High Street, 1-3 Belmont Hill • 9 Cressingham Road • 9 Lee High Road • 9 Mercia Grove • 9 Odell Walk • 9 Stephens Grove • Bellflower Court, Odell Walk • Glass Mill Leisure Centre, 41 Loampit Vale • Isabella Apartments, 102 Granville Park • St Stephens Church Vicarage, Cressingham Rd
12.11.20 The effect on the daylight amenity of a property in an urban context is considered to be minor negative in situations where both the VSC and NSL alterations applicable to the room are no greater than 30% of their baseline values and / or fall within the application of the alternative target value criteria.
12.11.21 The following properties are therefore considered to experience reductions which are of minor negative significance: Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
• • • • • • • • • • • • • • • • • • • • • • • • • • • •
1 Odell Walk 10 Bankside Avenue 10 Odell Walk 10 Yew Tree Close 11 Bankside Avenue 11 Yew Tree Close 117-119 Lewisham High Street 12 Bankside Avenue 12 Odell Walk 121 Lewisham High Street 123 Lewisham High Street 125 Lewisham High Street 127 Lewisham High Street 13 Bankside Avenue 13 Yew Tree Close 14 Bankside Avenue 14 Odell Walk 15 Bankside Avenue 153 Lewisham High Street 161 Lewisham High Street 163 Lewisham High Street 167 Lewisham High Street 169 Lewisham High Street 171 Lewisham High Street 187 Lewisham High Street 189 Lewisham High Street 2 Stephens Grove
• • • • • • • • • • • • • • • • • • • • • • • • • • •
20 Granville Grove 22 Granville Grove 24 Granville Grove 27 Granville Grove 4 Stephens Grove 4 Yew Tree Close 5 Yew Tree Close 6 Bankside Avenue 6 Stephens Grove 6 Yew Tree Close 7 Bankside Avenue 7 Elder Walk 7 Yew Tree Close 8 Bankside Avenue 8 Odell Walk 8 Stephens Grove 8 Yew Tree Close 85-87 Lewisham High Street 9 Bankside Avenue 9 Yew Tree Close 93-95 Lewisham High Street 97-99 Lewisham High Street St Saviours Church, 175 Lewisham High Street Torre Vista, 45 Loampit Vale Venice Corte, 2 Elmira Street 155 Lewisham High Street 191-193 Lewisham High Street
12.11.22 The following properties experience daylight alterations beyond those described as negligible or minor (i.e. experience an effect which is moderate or major negative) in accordance with Table 12.3 above and, therefore, are considered in more detail below:
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
100-104 Lewisham High Street
12.11.23 There are 28 windows serving 13 rooms within this building that have been considered in the technical assessments. 12.11.24 The result of the VSC test shows that 9 out of 28 windows will meet the strict application of the BRE Guidelines. The technical assessment shows that 6 windows will record retained VSC >15%; retained values in the mid-teens are considered an acceptable alternative target value for an urban location. There are 10 different windows that record an absolute VSC change <8%, with 5 of these windows recording an absolute VSC change <4%, a margin that is considered minor in nature, in that it is unlikely the alteration is perceptible by an occupier. The windows most affected by the Proposed Development are located on the lower floors (ground) and are commonly acknowledged to be challenged for daylight. This is supported by the low existing VSC values that translate into disproportionate percentage change from former value. 12.11.25 The result of the NSL test shows that 7 out of 13 rooms will meet the strict application of the BRE Guidelines. The results of the technical assessment show 1 room (room ref: R1/7200) records a light change marginally beyond the BRE’s permissible 20% from former value. The remaining affected windows record light alteration of 30% from former value. 12.11.26 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant. 110 Lewisham High Street
12.11.27 There are 4 windows serving 3 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.11.28 The VSC test shows that 0 out of 4 windows will meet the strict application of the BRE Guidelines. Each window serves a Living-Kitchen-Diner (LKD). The affected windows record light change >40% from former value. 12.11.29 The NSL test shows that 0 out of 3 rooms will meet the strict application of the BRE Guidelines. Each affected room records a light change >30% from former value. 12.11.30 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
112 Lewisham High Street
12.11.31 There are 3 windows serving 2 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.11.32 The result of the VSC test shows that 0 out of 3 windows will meet the strict application of the BRE Guidelines. Each affected room records a light change >40%, although the retained VSC values record 11%-15.3%. The isolated window (window ref: W1/8201) that records the lower retained VSC value serves a bedroom. It is acknowledged by the BRE Guidelines that this room classification does not carry the same expectation for natural light when compared to a living room. 12.11.33 The result of the NSL test shows that 1 out of 2 rooms will meet the strict application of the BRE Guidelines. The isolated affected room (room ref: R1/8201) record a light change of 21.3% from former value and is considered a minor alteration. This room is also a bedroom and is acknowledged to carry less expectation for natural light when compared to a living room.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
114 Lewisham High Street
12.11.34 There are 6 windows serving 5 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.11.35 The result of the VSC test shows that 0 out of 6 windows will meet the strict application of the BRE Guidelines. Each affected window records a light change >40% from former value. Of the affected windows, 3 record retained VSC >10%. 12.11.36 The result of the NSL test shows that 1 out of 5 rooms will meet the strict application of the BRE Guidelines. Of the affected rooms, 3 record light alteration between 22.3%-25.2% from former value, slightly beyond the BRE’s permissible 20% change form former value. 12.11.37 The NSL test shows that each room records exceptionally high existing daylight values, considered uncharacteristic for an urban location. This is borne out of the existing Lewisham Shopping Centre being low-lying in nature. 12.11.38 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant. 12.11.39 There are no windows/rooms with an orientation 90 degrees of due south that warrant sunlight consideration. 116-118 Lewisham High Street
12.11.40 There are 11 windows serving 11 rooms within this building that have been considered in the technical assessments. 12.11.41 The VSC test shows that 1 out of 11 windows will meet the strict application of the BRE Guidelines. The assessment shows that the 10 affected windows record light change >40% from former value. 12.11.42 The NSL test shows that 2 out of 11 rooms will meet the strict application of the BRE Guidelines. The assessment shows that 1 room (room ref: R3/11031) records a lighter alteration marginally beyond the BRE’s permissible 20% change from former value, and the remaining affected 8 rooms will record a light change >30% from former value. 12.11.43 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
165 Lewisham High Street
12.11.44 There 6 windows serving 3 rooms within this building that have been considered in the technical assessments. 12.11.45 The VSC test shows that 3 out of 6 windows will meet the strict application of the BRE Guidelines. The assessment shows that 1 affected window (window ref: R1/1181) will retain a VSC value that exceeds >24% (and record light change <20.01% from former value) and is considered excellent for an urban location. The two remaining affected windows (window ref: W1/1182 & W2/1182) record retained VSC values of 5.06% and 17.02% respectively. 12.11.46 The NSL test shows that 2 out of 3 rooms will meet the strict application of the BRE Guidelines. The affected room (room ref: R1/1183) records light change >40% from former value. 12.11.47 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters)) is considered direct, permanent, Moderate Adverse and therefore significant. 174-176 Lewisham High Street
12.11.48 There are 6 windows serving 6 rooms within this building that have been considered in the technical assessments. 12.11.49 The VSC test shows that 0 out of 6 windows will meet the strict application of the BRE Guidelines. The results show that each affected window retains VSC values >10% but records a light change >40% from former value. 12.11.50
The NSL test records full BRE compliance (100%).
12.11.51 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters)) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
198-206 Lewisham Shopping Centre
12.11.52 There are 12 windows serving 12 rooms within this building that have been considered in the technical assessments. This property is located on the southern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.11.53 The VSC test shows that 0 out of 12 windows will meet the strict application of the BRE Guidelines. The assessment shows that 10 windows will retain a VSC value >16% and is not uncommon for an urban location, with 7 windows retaining >20VSC. Each affected window records a light change >40% from former value. 12.11.54 The NSL test shows that 0 out of 12 rooms will meet the strict application of the BRE Guidelines. The assessment shows that all affected rooms record existing NSL values >93% and is considered uncharacteristic for an urban location. Of the affected rooms, 11 rooms retained NSL >50% and is considered an indication for daylight values. The recorded percentage change from former value for each room is >30%. 12.11.55 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant. 50 Lewisham High Street
12.11.56 There are 8 windows serving 5 rooms within this building that have been considered in the technical assessments. This property is located on the north-eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.11.57 The VSC test shows that 2 out of 8 windows will meet the strict application of the BRE Guidelines. Of the affected windows, 2 (window ref: W1/7003 & W2/7003) record retained VSC values >22% which is considered to be good for an urban setting. Each affected window records light change >40% from former value. 12.11.58 The NSL test shows that 0 out of 5 rooms will meet the strict application of the BRE Guidelines. A bedroom and a living kitchen diner record a light change of 27.4% and 24% from former value, respectively. The remaining rooms record a change >30% from former value. 12.11.59 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
52 Lewisham High Street
12.11.60 There are 7 windows serving 7 rooms within this building that have been considered in the technical assessments. This property is located on the north-eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.11.61 The VSC test shows that 0 out of 7 windows will meet the strict application of the BRE Guidelines. The assessment shows that 2 windows (window ref: W1/7013 & W2/7013) record retained VSC values >21% and is considered good for an urban environment. All affected windows record >40% change from former value. 12.11.62 The NSL test shows that 0 out of 7 rooms will meet the strict application of the BRE Guidelines. Each affected room records a light change >40% from former value. 12.11.63 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters)) is considered direct, permanent, Major Adverse and therefore significant. 58-60 Lewisham High Street
12.11.64 There are 8 windows serving 6 rooms within this building have been considered in the technical assessments. This property is located on the north-eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.11.65 The VSC test shows that 3 out of 8 windows will meet the strict application of the BRE Guidelines. Each affected window records a change in light >40% from former value. 12.11.66 The NSL test shows that 2 out of 6 rooms will meet the strict application of the BRE Guidelines. Of the affected rooms, 2 (room ref: R2/7031 & R2/7032) record a retained NSL value of 73% and 67% and is considered good and not uncommon for an urban setting. The remaining affected rooms record a light change >40% from former value. 12.11.67 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters)) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
66 Lewisham High Street
12.11.68 There are 8 windows serving 6 rooms within this building that have been considered in the technical assessments. This property is located on the north-eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.11.69 The VSC test shows that 0 out of 8 windows will meet the strict application of the BRE Guidelines. Each affected window records a light change >40% from former value. 12.11.70 The NSL test shows that 0 out of 6 rooms will meet the strict application of the BRE Guidelines. Each affected room records a light change >40% from former value. 12.11.71 Overall, the daylight effect to this property as a result of the Proposed Development Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant. 86-88 Lewisham High Street
12.11.72 There are 15 windows serving 14 rooms within this property that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.11.73 The VSC test shows that 4 out of 15 windows will meet the strict application of the BRE Guidelines. The assessment shows that the average retained VSC across all the considered windows is 16.18%. The analysis also shows that 9 affected windows record an absolute VSC change <8 with 3 of these windows recorded <4% absolute change. 12.11.74 The NSL test shows that 3 out of 14 rooms will meet the strict application of the BRE Guidelines. The assessment shows that each 8 out of 12 affected rooms record light change >40% from former value. 12.11.75 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
90 Lewisham High Street
12.11.76 There are 4 windows serving 2 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.11.77 The VSC test shows that 0 out of 4 windows will meet the strict application of the BRE Guidelines. The assessment shows that the affected windows will record a light change >40% from former value and an average retained VSC of 14.13% is recorded. 12.11.78 The NSL test shows that 0 out of 2 rooms will meet the strict application of the BRE Guidelines. The assessment shows that both affected rooms, being a living room and a bedroom records light change >40% from former value. 12.11.79 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant. 92 Lewisham High Street
12.11.80 There are 4 windows serving 3 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.11.81 The VSC test shows that 1 out of 4 windows will meet the strict application of the BRE Guidelines. The average retained VSC across the assessed windows is 25%. 2 affected windows (window ref: W4/7132 & W3/7133) record retained values >17% and is considered good daylight availability within an urban context. 12.11.82 The NSL test shows that 0 out of 3 rooms will meet the strict application of the BRE Guidelines. The assessment shows that the affected rooms will record light change 28.3%38.8% from former value. 12.11.83 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Moderate Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
94 Lewisham High Street
12.11.84 There are 4 windows serving 4 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.11.85 The VSC test shows that 1 out of 4 windows will meet the strict application of the BRE Guidelines. The assessment shows that the average retained VSC across the assessed windows is 24%, with affected windows W1/7152 & W1/7162 recording retained values >15%. 12.11.86 The NSL test shows that 1 out of 4 rooms will meet the strict application of the BRE Guidelines. The assessment shows that each affected room records a light change >40% from former value. 12.11.87 Overall, the daylight effect to this property as a result of the Proposed Development Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant. 96 Lewisham High Street
12.11.88 There are 2 windows serving 2 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.11.89 The VSC test shows that 0 out of 2 windows will meet the strict application of the BRE Guidelines. Window W1/7171 records an existing VSC of 2.5% and therefore any slight alteration from the baseline is likely to trigger a disproportionate change in light. The remaining affected window records a light change >40% from former value. 12.11.90 The NSL test shows that 0 out of 2 rooms will meet the strict application of the BRE Guidelines. The assessment shows that both rooms will records >40% change from former value. 12.11.91 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
98 Lewisham High Street
12.11.92 There are 7 windows serving 6 rooms within this building that have been considered in the technical assessments. This property is located on the eastern boundary of the Proposed Development within a close proximity. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment, it is considered prudent to apply alternative target values and the guidelines flexibly. 12.11.93 The VSC test shows that 0 out of 7 windows will meet the strict application of the BRE Guidelines. The assessment shows that the affected windows retain an average VSC of 11.92% with 3 windows retaining daylight values between 13%-17.2%. 12.11.94 The NSL test shows that 0 out of 6 rooms will meet the strict application of the BRE Guidelines. The assessment shows that all affected rooms will record >40% change from former value. 12.11.95 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Lewisham Gateway
12.11.96 There are 657 windows serving 391 rooms within this building that have been considered in the technical assessments. It is noted that there are a number of windows / rooms that are served by projecting balconies and render the windows below the features sensitive to a change in their outlook. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment it is appropriate to apply alternative, less stringent, guidelines for windows that have an overhang (balconies above). 12.11.97 The VSC test shows that 486 out of 657 windows will meet the strict application of the BRE Guidelines. It is noted that The technical assessment shows that of the affected windows there are 113 windows that retain VSC values >15% (ranging to 26.74%) and is considered acceptable for an urban location. Of the 113 windows that retain VSC >15%, 96 windows retained >18%. The VSC test also shows that there a number of affected windows that record low existing values (<12%) and will be sensitive to minor alterations in their outlook and trigger disproportionate percentage changes in light. 12.11.98 The NSL test shows that 365 out of 391 rooms will meet the strict application of the BRE Guidelines. The technical assessment shows that a large number (13 rooms of transgressions (record minor alterations beyond the permissible 20% change from former value and fall within 10% beyond the threshold. The majority of the remaining affected rooms (13 rooms) are bedrooms and is acknowledged by the BRE that this room classification does not carry the same expectation for natural light when compared to a living room. 12.11.99 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant. 12.11.100 However, when taking into account the sub-categories outlined in para 12.4.52 by reference to presence of projecting balconies, the light changes and subsequent retained values are considered acceptable for the context of the Site and urban setting.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Mill Apartments, 68 Molesworth Street
12.11.101 There are 66 windows serving 30 rooms within this building that have been considered in the technical assessments. 12.11.102 The VSC test shows that 52 out of 66 windows will meet the strict application of the BRE Guidelines. The technical analysis also confirms that of the 10 BRE transgressions, 10 rooms are bedrooms and is a classification acknowledged by the BRE Guidelines to carry the same expectation for natural light when compared to a living room. 12.11.103 The NSL test shows that 25 out of 30 rooms will meet the strict application of the BRE Guidelines. The assessment shows that 4 out of the 5 affected rooms are bedrooms; this classification is acknowledged to carry less expectation for natural light when compared to a living room. The remaining affected room is a kitchen, that records exceptionally high existing NSL value and records a light change >40% from former value. 12.11.104 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant. Mill House, Elder Walk
12.11.105 There are 111 windows serving 95 rooms within this building that have been considered in the technical assessments. 12.11.106 The VSC test shows that 101 out of 111 windows will meet the strict application of the BRE Guidelines. The technical assessment shows that all 10 affected windows will retain >15% VSC and is considered a value deemed acceptable for an urban setting. 12.11.107
The NSL test records full BRE compliance (100%).
12.11.108 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Moderate Adverse and therefore significant 12.11.109 The sunlight test considers 47 rooms within the building that have an orientation 90 degrees of due south.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Riverdale House, 68 Molesworth
12.11.110 There are 286 windows serving 187 rooms within this building that have been considered in the technical assessments. 12.11.111 The VSC test shows that 119 out of 286 windows will meet the strict application of the BRE Guidelines. The test shows that 119 out of 167 affected windows record retained VSC values >15%, 67 of which retained VSC values >18%. 12.11.112 The analysis shows that 167 affected rooms record existing light values >27% (up to 39%) and is considered uncharacteristically high for an urban location. For reference, the maximum VSC that can be achieved is just shy 40%. 12.11.113 The NSL test shows that 143 out of 187 rooms will meet the strict application of the BRE Guidelines. The technical assessment shows that 31 affected rooms will record a percentage <29.9% from former value. The remaining affected rooms record change >30% from former value. 12.11.114 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant Sienna Alto, 2 Cornmill Lane
12.11.115 There are 424 windows serving 177 rooms within this building that have been considered in the technical assessment. By reference to the BRE Guidelines Appendix H: Environmental Impact Assessment it is appropriate to apply alternative, less stringent, guidelines for windows that have an overhang (balconies above). 12.11.116 The VSC test shows that 365 out of 424 windows will meet the strict application of the BRE Guidelines. The assessment shows that 32 of the affected windows record an absolute VSC change <4% from former value and is considered a minor alteration. In respect of the remaining affected windows, the absolute VSC change to these windows do not exceed 5% from former value. 12.11.117 The NSL test shows that 175 out of 177 rooms will meet the strict application of the BRE Guidelines. The 2 affected rooms (room ref: R4/2506 & R4/2504) record light alteration of 23% and 26% from former value, respectively. 12.11.118 Overall, the daylight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Moderate Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Table 12.22 – APSH Summary with the Development in Place APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>40 %
Total
Total No. Rooms
Isabella Apartments, 102 Granville Park
28
0
0
0
0
0
0
0
0
28
25 Lewisham High Street
3
0
0
1
1
0
0
0
0
4
27 Lewisham High Street
4
0
0
0
0
0
0
0
0
4
29 Lewisham High Street
4
0
0
0
0
0
0
0
0
4
31 Lewisham High Street
6
0
0
0
0
0
0
0
0
6
1 Cressingham Road
7
0
0
0
0
0
0
0
0
7
3 Cressingham Road
4
0
0
0
0
0
0
0
0
4
5 Cressingham Road
4
0
0
0
0
0
0
0
0
4
7 Cressingham Road
4
0
0
0
0
0
0
0
0
4
9 Cressingham Road
4
0
0
0
0
0
0
0
0
4
11 Cressingham Road
4
0
0
0
0
0
0
0
0
4
13 Cressingham Road
4
0
0
0
0
0
0
0
0
4
15 Cressingham Road
4
0
0
0
0
0
0
0
0
4
17 Cressingham Road
5
0
0
0
0
0
0
0
0
5
19 Cressingham Road
4
0
0
0
0
0
0
0
0
4
21 Cressingham Road
10
0
0
0
0
0
0
0
0
10
23 Cressingham Road
4
0
0
0
0
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>40 %
Total
Total No. Rooms
16 Cressingham Road
6
0
0
0
0
0
0
0
0
6
14 Cressingham Road
6
0
0
0
0
0
0
0
0
6
12 Cressingham Road
6
0
0
0
0
0
0
0
0
6
10 Cressingham Road
6
0
0
0
0
0
0
0
0
6
8 Cressingham Road
6
0
0
0
0
0
0
0
0
6
6 Cressingham Road
6
0
0
0
0
0
0
0
0
6
4 Cressingham Road
6
0
0
0
0
0
0
0
0
6
2 Cressingham Road
6
0
0
0
0
0
0
0
0
6
St Stephens Church Vicarage, Cressingham Road
10
0
0
0
0
0
0
0
0
10
1 Stephens Grove
3
0
0
0
0
0
0
0
0
3
2 Stephens Grove
3
0
0
0
0
0
0
0
0
3
3 Stephens Grove
3
0
0
0
0
0
0
0
0
3
4 Stephens Grove
3
0
0
0
0
0
0
0
0
3
5 Stephens Grove
3
0
0
0
0
0
0
0
0
3
6 Stephens Grove
3
0
0
0
0
0
0
0
0
3
7 Stephens Grove
3
0
0
0
0
0
0
0
0
3
8 Stephens Grove
3
0
0
0
0
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>40 %
Total
Total No. Rooms
1 Lockmead Road
3
0
0
0
0
0
0
0
0
3
3 Lockmead Road
3
0
0
0
0
0
0
0
0
3
5 Lockmead Road
3
0
0
0
0
0
0
0
0
3
3 Boyne Road
3
0
0
0
0
0
0
0
0
3
1 Boyne Road
3
0
0
0
0
0
0
0
0
3
9 Stephens Grove
5
0
0
0
0
0
0
0
0
5
10 Stephens Grove
5
0
0
0
0
0
0
0
0
5
11 Stephens Grove
5
0
0
0
0
0
0
0
0
5
12 Stephens Grove
5
0
0
0
0
0
0
0
0
5
13 Stephens Grove
5
0
0
0
0
0
0
0
0
5
14 Stephens Grove
5
0
0
0
0
0
0
0
0
5
15 Stephens Grove
5
0
0
0
0
0
0
0
0
5
16 Stephens Grove
5
0
0
0
0
0
0
0
0
5
17 Stephens Grove
5
0
0
0
0
0
0
0
0
5
18 Stephens Grove
5
0
0
0
0
0
0
0
0
5
19 Stephens Grove
5
0
0
0
0
0
0
0
0
5
19 Granville Grove
3
0
0
0
0
0
0
0
0
3
20 Granville Grove
3
0
0
0
0
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>40 %
Total
Total No. Rooms
21 Granville Grove
3
0
0
0
0
0
0
0
0
3
22 Granville Grove
3
0
0
0
0
0
0
0
0
3
23 Granville Grove
3
0
0
0
0
0
0
0
0
3
24 Granville Grove
3
0
0
0
0
0
0
0
0
3
25 Granville Grove
3
0
0
0
0
0
0
0
0
3
27 Granville Grove
6
0
0
0
0
0
0
0
0
6
65-71 Lewisham High Street
20
0
0
0
0
0
0
0
0
20
85 Lewisham High Street, 1-3 Belmont Hill
4
0
0
0
0
0
0
0
0
4
5 Belmont Hill
2
0
0
0
0
0
0
0
0
2
7-9 Belmont Hill
2
0
0
0
0
0
0
0
0
2
2-4 Belmont Hill
1
0
0
0
0
0
0
0
0
1
1 Lee High Road
3
0
0
0
0
0
0
0
0
3
3-5 Lee High Road
2
0
0
0
0
0
0
0
0
2
7 Lee High Road
4
0
0
0
0
0
0
0
0
4
9 Lee High Road
1
0
0
0
0
0
0
0
0
1
11-13 Lee High Road
3
0
0
0
0
0
0
0
0
3
15 Lee High Road
1
0
0
0
0
0
0
0
0
1
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>40 %
Total
Total No. Rooms
17 Lee High Road
3
0
0
0
0
0
0
0
0
3
19 Lee High Road
3
0
0
0
0
0
0
0
0
3
21 Lee High Road
6
0
0
0
0
0
0
0
0
6
14-16 Lee High Road
9
0
0
0
0
0
0
0
0
9
4-6 Lee High Road
6
0
0
0
0
0
0
0
0
6
1 Lewis Grove
2
0
0
0
0
0
0
0
0
2
1 Mercia Grove
3
0
0
0
0
0
0
0
0
3
2 Mercia Grove
3
0
0
0
0
0
0
0
0
3
3 Mercia Grove
3
0
0
0
0
0
0
0
0
3
4 Mercia Grove
3
0
0
0
0
0
0
0
0
3
5 Mercia Grove
3
0
0
0
0
0
0
0
0
3
6 Mercia Grove
3
0
0
0
0
0
0
0
0
3
7 Mercia Grove
3
0
0
0
0
0
0
0
0
3
8 Mercia Grove
3
0
0
0
0
0
0
0
0
3
9 Mercia Grove
3
0
0
0
0
0
0
0
0
3
10 Mercia Grove
4
0
0
0
0
0
0
0
0
4
11 Mercia Grove
3
0
0
0
0
0
0
0
0
3
12 Mercia Grove
2
0
0
0
0
0
0
0
0
2
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>40 %
Total
Total No. Rooms
13 Mercia Grove
2
0
0
0
0
0
0
0
0
2
14 Mercia Grove
2
0
0
0
0
0
0
0
0
2
15 Mercia Grove
2
0
0
0
0
0
0
0
0
2
16 Mercia Grove
2
0
0
0
0
0
0
0
0
2
17 Mercia Grove
2
0
0
0
0
0
0
0
0
2
18 Mercia Grove
4
0
0
0
0
0
0
0
0
4
19 Mercia Grove
2
0
0
0
0
0
0
0
0
2
20 Mercia Grove
2
0
0
0
0
0
0
0
0
2
21 Mercia Grove
3
0
0
0
0
0
0
0
0
3
23 Merci Grove
11
0
0
0
0
0
0
0
0
11
4 Albion Way
3
0
0
0
0
0
0
0
0
3
2 Albion Way
3
0
0
0
0
0
0
0
0
3
8 Bonfield Road
1
0
0
0
0
0
0
0
0
1
6 Bonfield Road
1
0
0
0
0
0
0
0
0
1
4 Bonfield Road
2
0
0
0
0
0
0
0
0
2
2 Bonfield Road
3
0
0
0
0
0
0
0
0
3
131-133 Lewisham High Street
12
0
0
0
0
0
0
0
0
12
139-141 Lewisham High Street
6
0
0
0
0
0
0
0
0
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>40 %
Total
Total No. Rooms
155 Lewisham High Street
12
0
0
0
0
1
0
0
1
13
St Saviours Church, 175 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
197 Lewisham High Street
3
0
0
0
0
0
0
0
0
3
205 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
226-230 Lewisham High Street
25
0
0
0
0
0
0
0
0
25
Riverdale House, 68 Molesworth Street
34
0
0
0
0
0
0
0
0
34
Mill Apartments, 68 Molesworth Street
19
0
0
1
1
0
0
0
0
20
14 Odell Walk
3
0
0
0
0
0
0
0
0
3
12 Odell Walk
3
0
0
0
0
0
0
0
0
3
10 Odell Walk
3
0
0
0
0
0
0
0
0
3
8 Odell Walk
3
0
0
0
0
0
0
0
0
3
6 Odell Walk
3
0
0
0
0
0
0
0
0
3
4 Odell Walk
3
0
0
0
0
0
0
0
0
3
2 Odell Walk
3
0
0
0
0
0
0
0
0
3
1 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
2 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
3 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>40 %
Total
Total No. Rooms
4 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
5 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
6 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
1 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
3 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
5 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
7 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
9 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
11 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
13 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
10 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
8 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
6 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
4 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
2 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
7 Bankside Avenue
6
0
0
0
0
0
0
0
0
6
8 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
9 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>40 %
Total
Total No. Rooms
10 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
11 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
12 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
13 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
14 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
15 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
1 Elder Walk
2
0
0
0
0
0
0
0
0
2
3 Elder Walk
2
0
0
0
0
0
0
0
0
2
5 Elder Walk
2
0
0
0
0
0
0
0
0
2
7 Elder Walk
2
0
0
0
0
0
0
0
0
2
Mill House, Elder Walk
44
0
0
0
0
0
3
0
3
47
Venice Corte, 2 Elmira Street
60
0
0
0
0
0
0
0
0
60
Sienna Alto, 2 Cornmill Lane
164
0
0
5
5
9
4
0
13
177
Glass Mill Leisure Centre, 41 Loampit Vale
1
0
0
0
0
0
0
0
0
1
Lewisham Gateway (Under Construction)
381
0
0
6
6
2
1
7
10
391
50 Lewisham High Street
1
0
0
4
4
0
0
4
4
5
52 Lewisham High Street
1
0
0
4
4
0
0
6
6
7
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Below Threshold for Winter APSH
Meet BRE Guidelines
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Total
2030 %
3040 %
>40 %
Total
Total No. Rooms
58-60 Lewisham High Street
1
0
0
5
5
0
0
4
4
6
66 Lewisham High Street
0
0
0
6
6
0
0
6
6
6
86-88 Lewisham High Street
9
0
0
0
0
2
2
1
5
14
90 Lewisham High Street
1
0
0
0
0
0
0
1
1
2
92 Lewisham High Street
2
0
0
0
0
0
0
1
1
3
129 Lewisham High Street
4
0
0
0
0
0
0
0
0
4
117-119 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
97-99 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
93-95 Lewisham High Street
11
0
0
0
0
0
0
0
0
11
85-87 Lewisham High Street
5
0
0
0
0
0
0
0
0
5
Total
1359
0
0
32
32
14
10
30
54
1416
12.11.119
The BRE Guidelines state that: “…the sunlighting of the existing building may be adversely affected…if the centre of the window receives less than 25% of annual probable sunlight hours, or less than 5% of annual probable sunlight hours between 21 September and 21 March and receives less than 0.8 times its former sunlight hours during either period and has a reduction in sunlight received over the whole year greater than 4% of annual probable sunlight hours.”
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
12.11.120
For existing residential properties, the BRE Guidelines state in Section 3.2.3 that: “all main living rooms of dwellings…should be checked if they have a window facing within 90° of due south, kitchens and bedrooms are less important, although care should be taken not to block too much sun.”
12.11.121
Section 3.2.4 continues: “If the main living room to a dwelling has a main window facing within 90° of due north, but a secondary window facing within 90° of due south, sunlight to the secondary window should be checked.”
12.11.122 The following properties have the following number of Site-facing rooms that are within 90 degrees of due south and will experience alterations which, in accordance with the BRE Guidelines, will not be noticeable to the occupants and therefore negligible:
• • • • • • • • • • • • • • • • • • • • • • • •
Isabella Apartments, 102 Granville Park 27 Lewisham High Street 29 Lewisham High Street 31 Lewisham High Street 1 Cressingham Road 3 Cressingham Road 5 Cressingham Road 7 Cressingham Road 9 Cressingham Road 11 Cressingham Road 13 Cressingham Road 15 Cressingham Road 17 Cressingham Road 19 Cressingham Road 21 Cressingham Road 23 Cressingham Road 16 Cressingham Road 14 Cressingham Road 12 Cressingham Road 10 Cressingham Road 8 Cressingham Road 6 Cressingham Road 4 Cressingham Road 2 Cressingham Road
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
• • • • • • • • • • • • • • • • • • • • • • • • •
St Stephens Church Vicarage, Cressingham Road 1 Stephens Grove 2 Stephens Grove 3 Stephens Grove 4 Stephens Grove 5 Stephens Grove 6 Stephens Grove 7 Stephens Grove 8 Stephens Grove 1 Lockmead Road 3 Lockmead Road 5 Lockmead Road 3 Boyne Road 1 Boyne Road 9 Stephens Grove 10 Stephens Grove 11 Stephens Grove 12 Stephens Grove 13 Stephens Grove 14 Stephens Grove 15 Stephens Grove 16 Stephens Grove 17 Stephens Grove 18 Stephens Grove 19 Stephens Grove Plowman Craven 46730 October 2024
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •
19 Granville Grove 20 Granville Grove 21 Granville Grove 22 Granville Grove 23 Granville Grove 24 Granville Grove 25 Granville Grove 27 Granville Grove 65-71 Lewisham High Street 85 Lewisham High Street, 1-3 Belmont Hill 5 Belmont Hill 7-9 Belmont Hill 2-4 Belmont Hill 1 Lee High Road 3-5 Lee High Road 7 Lee High Road 9 Lee High Road 11-13 Lee High Road 15 Lee High Road 17 Lee High Road 19 Lee High Road 21 Lee High Road 14-16 Lee High Road 4-6 Lee High Road 1 Lewis Grove 1 Mercia Grove 2 Mercia Grove 3 Mercia Grove 4 Mercia Grove 5 Mercia Grove 6 Mercia Grove 7 Mercia Grove 8 Mercia Grove 9 Mercia Grove 10 Mercia Grove 11 Mercia Grove 12 Mercia Grove 13 Mercia Grove 14 Mercia Grove 15 Mercia Grove 16 Mercia Grove
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •
17 Mercia Grove 18 Mercia Grove 19 Mercia Grove 20 Mercia Grove 21 Mercia Grove 23 Merci Grove 4 Albion Way 2 Albion Way 8 Bonfield Road 6 Bonfield Road 4 Bonfield Road 2 Bonfield Road 131-133 Lewisham High Street 139-141 Lewisham High Street St Saviours Church, 175 Lewisham High Street 197 Lewisham High Street 205 Lewisham High Street 226-230 Lewisham High Street Riverdale House, 68 Molesworth Street 14 Odell Walk 12 Odell Walk 10 Odell Walk 8 Odell Walk 6 Odell Walk 4 Odell Walk 2 Odell Walk 1 Bankside Avenue 2 Bankside Avenue 3 Bankside Avenue 4 Bankside Avenue 5 Bankside Avenue 6 Bankside Avenue 1 Yew Tree Close 3 Yew Tree Close 5 Yew Tree Close 7 Yew Tree Close 9 Yew Tree Close 11 Yew Tree Close 13 Yew Tree Close 10 Yew Tree Close Plowman Craven 46730 October 2024
• • • • • • • • • • • •
8 Yew Tree Close 6 Yew Tree Close 4 Yew Tree Close 2 Yew Tree Close 7 Bankside Avenue 8 Bankside Avenue 9 Bankside Avenue 10 Bankside Avenue 11 Bankside Avenue 12 Bankside Avenue 13 Bankside Avenue 14 Bankside Avenue
• • • • • • • • • • • •
15 Bankside Avenue 1 Elder Walk 3 Elder Walk 5 Elder Walk 7 Elder Walk Venice Corte, 2 Elmira Street Glass Mill Leisure Centre, 41 Loampit Vale 129 Lewisham High Street 117-119 Lewisham High Street 97-99 Lewisham High Street 93-95 Lewisham High Street 85-87 Lewisham High Street
12.11.123 The following properties are therefore considered to experience reductions which are of minor negative significance:
• • • • • •
25 Lewisham High Street 155 Lewisham High Street Mill Apartments, 68 Molesworth Street Mill House, Elder Walk 86-88 Lewisham High Street 90 Lewisham High Street
12.11.124 Site-facing rooms, located within the following properties, will experience APSH alterations that are beyond those described above and so will be considered in more detail: •
Lewisham Gateway (Under Construction)
•
50 Lewisham High Street
•
52 Lewisham High Street
•
58-60 Lewisham High Street
•
66 Lewisham High Street
•
Sienna Alto, 2 Cornmill Lane
•
92 Lewisham High Street
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
50 Lewisham High Street
12.11.125 The sunlight test considers 5 rooms within the building that have an orientation 90 degrees of due south. 12.11.126 The result of the APSH assessment shows that 1 of out 5 rooms will meet the strict application of the BRE Guidelines. Each affected room (4) records >40% change from former value, although 2 rooms (room ref: R1/7002 & R2/7003) record retained annual sunlight values of 16% and 21% respectively. 12.11.127 Overall, the sunlight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant. 52 Lewisham High Street
12.11.128 The sunlight test considers 7 rooms within the building that have an orientation 90 degrees of due south. 12.11.129 The result of the APSH assessment shows that 1 out of 7 rooms will meet the strict application of the BRE guidelines. The sunlight test shows that 3 rooms record retained sunlight values >20% and is considered good for an urban location. The remaining rooms record change >40% from former value. 12.11.130 Overall, the sunlight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant. 58-60 Lewisham High Street
12.11.131 The sunlight test considers 6 rooms within the building that have an orientation 90 degrees of due south. 12.11.132 The APSH test shows that 1 out of 6 rooms will meet the strict application of the BRE Guidelines. Notably, 3 affected rooms record retained annual sunlight values 17%-39%. The bigger daylight challenges are recorded within the winter months when sunlight availability is inherently more challenged by virtue of the low sun path. 12.11.133 Overall, the sunlight effect to this property as a result of the Proposed Development (Illustrative Parameters)) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
66 Lewisham High Street
12.11.134 The sunlight test considers 6 rooms within the building that have an orientation 90 degrees of due south. 12.11.135 The APSH test shows that 0 out of 6 rooms will meet the strict application of the BRE Guidelines. Each affected room records a light change >40% from former value with retained annual sunlight values ranging from 3%-10%. 12.11.136 Overall, the sunlight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant. Lewisham Gateway
12.11.137 The sunlight test considers 391 rooms within the building that have an orientation 90 degrees of due south. 12.11.138 The APSH test shows that 381 out of 391 rooms will meet the strict application of the BRE Guidelines. The technical assessment shows that 3 affected rooms will retain annual sunlight values >15%, with 2 record >20% and considered very good for an urban setting. The remaining affected rooms record >40% change from former value during the annual months. 12.11.139 Overall, the sunlight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant. Sienna Alto, 2 Cornmill Lane
12.11.140 The sunlight test considers 177 rooms within the building that have an orientation 90 degrees of due south. 12.11.141 The APSH test shows that 164 out of 177 rooms will meet the strict application of the BRE Guidelines. The assessment shows that 9 rooms record a percentage change <29.9% from former value during the annual sunlight analysis. The majority of assessed rooms record <38% change from former value. The remaining 7 rooms record a change >40% from former value. 12.11.142 Overall, the sunlight effect to this property as a result of the Proposed Development (Illustrative Parameters) is considered direct, permanent, Major Adverse and therefore significant.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Illustrative Parameters: Cumulative Assessment
12.11.143 The cumulative assessment includes the Lewisham Open Market consent and is considered in conjunction with the Proposed Development against the existing baseline. The assessment baseline conditions will therefore be consistent with the Illustrative Scheme: Main Assessment. 12.11.144 The cumulative scheme is located to the east of the Lewisham Shopping Centre site and adjoin Lewisham High Street. The cumulative scheme is low rise, and it is unlikely to have a material effect when compared to the main assessment. Cumulative Assessment of Effects
Cumulative Daylight to Surrounding Properties 12.11.145 There are 3737 windows serving 2327 residential rooms within the assessed properties surrounding the Site. These have all been assessed in terms of both VSC and NSL. Full detailed results can be found at Appendices 12.3 and 12.3 and are summarised in Table 12.23 and Table 12.24 and shows those properties that record full BRE compliance, in respect of VSC and NSL, highlighted in green. Table 12. 23 - VSC Summary with the Development in Place (Illustrative Masterplan: Cumulative Assessment) VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Windows
Isabella Apartments, 102 Granville Park
40
0
0
0
0
40
25 Lewisham High Street
7
0
0
0
0
7
27 Lewisham High Street
6
0
0
0
0
6
29 Lewisham High Street
6
0
0
0
0
6
31 Lewisham High Street
9
0
0
0
0
9
1 Cressingham Road
9
0
0
0
0
9
3 Cressingham Road
5
0
0
0
0
5
5 Cressingham Road
5
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Windows
7 Cressingham Road
5
0
0
0
0
5
9 Cressingham Road
5
0
0
0
0
5
11 Cressingham Road
5
0
0
0
0
5
13 Cressingham Road
5
0
0
0
0
5
15 Cressingham Road
5
0
0
0
0
5
17 Cressingham Road
6
0
0
0
0
6
19 Cressingham Road
5
0
0
0
0
5
21 Cressingham Road
10
0
0
0
0
10
23 Cressingham Road
6
0
0
0
0
6
16 Cressingham Road
8
0
0
0
0
8
14 Cressingham Road
9
0
0
0
0
9
12 Cressingham Road
9
0
0
0
0
9
10 Cressingham Road
9
0
0
0
0
9
8 Cressingham Road
8
0
0
0
0
8
6 Cressingham Road
8
0
0
0
0
8
4 Cressingham Road
8
0
0
0
0
8
2 Cressingham Road
8
0
0
0
0
8
St Stephens Church Vicarage, Cressingham Road
23
0
0
0
0
23
1 Stephens Grove
5
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Windows
2 Stephens Grove
4
0
0
1
1
5
3 Stephens Grove
5
0
0
0
0
5
4 Stephens Grove
4
0
0
1
1
5
5 Stephens Grove
5
0
0
0
0
5
6 Stephens Grove
4
0
0
1
1
5
7 Stephens Grove
5
0
0
0
0
5
8 Stephens Grove
4
0
1
0
1
5
1 Lockmead Road
5
0
0
0
0
5
3 Lockmead Road
5
0
0
0
0
5
5 Lockmead Road
7
0
0
0
0
7
3 Boyne Road
6
0
0
0
0
6
1 Boyne Road
9
0
0
0
0
9
9 Stephens Grove
8
0
0
0
0
8
10 Stephens Grove
5
0
0
0
0
5
11 Stephens Grove
5
0
0
0
0
5
12 Stephens Grove
5
0
0
0
0
5
13 Stephens Grove
5
0
0
0
0
5
14 Stephens Grove
5
0
0
0
0
5
15 Stephens Grove
5
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Windows
16 Stephens Grove
5
0
0
0
0
5
17 Stephens Grove
5
0
0
0
0
5
18 Stephens Grove
5
0
0
0
0
5
19 Stephens Grove
5
0
0
0
0
5
19 Granville Grove
5
0
0
0
0
5
20 Granville Grove
4
1
0
0
1
5
21 Granville Grove
5
0
0
0
0
5
22 Granville Grove
4
0
0
1
1
5
23 Granville Grove
5
0
0
0
0
5
24 Granville Grove
4
0
0
1
1
5
25 Granville Grove
5
0
0
0
0
5
27 Granville Grove
9
0
1
0
1
10
65-71 Lewisham High Street
44
0
0
0
0
44
85 Lewisham High Street, 1-3 Belmont Hill
13
0
0
0
0
13
5 Belmont Hill
2
0
0
0
0
2
7-9 Belmont Hill
2
0
0
0
0
2
2-4 Belmont Hill
29
0
0
0
0
29
1 Lee High Road
21
0
0
0
0
21
3-5 Lee High Road
5
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Windows
7 Lee High Road
6
0
0
0
0
6
9 Lee High Road
2
0
0
0
0
2
11-13 Lee High Road
3
0
0
0
0
3
15 Lee High Road
2
0
0
0
0
2
17 Lee High Road
9
0
0
0
0
9
19 Lee High Road
5
0
0
0
0
5
21 Lee High Road
7
0
0
0
0
7
14-16 Lee High Road
16
0
0
0
0
16
4-6 Lee High Road
16
0
0
0
0
16
1 Lewis Grove
6
0
0
0
0
6
1 Mercia Grove
7
0
0
0
0
7
2 Mercia Grove
7
0
0
0
0
7
3 Mercia Grove
8
0
0
0
0
8
4 Mercia Grove
7
0
0
0
0
7
5 Mercia Grove
7
0
0
0
0
7
6 Mercia Grove
7
0
0
0
0
7
7 Mercia Grove
7
0
0
0
0
7
8 Mercia Grove
7
0
0
0
0
7
9 Mercia Grove
7
0
0
0
0
7
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Windows
10 Mercia Grove
9
0
0
0
0
9
11 Mercia Grove
7
0
0
0
0
7
12 Mercia Grove
10
0
0
0
0
10
13 Mercia Grove
10
0
0
0
0
10
14 Mercia Grove
7
0
0
0
0
7
15 Mercia Grove
7
0
0
0
0
7
16 Mercia Grove
6
0
0
0
0
6
17 Mercia Grove
7
0
0
0
0
7
18 Mercia Grove
9
0
0
0
0
9
19 Mercia Grove
7
0
0
0
0
7
20 Mercia Grove
7
0
0
0
0
7
21 Mercia Grove
7
0
0
0
0
7
23 Merci Grove
65
0
0
0
0
65
4 Albion Way
10
0
0
0
0
10
2 Albion Way
12
0
0
0
0
12
8 Bonfield Road
4
0
0
0
0
4
7 Bonfield Road
9
0
0
0
0
9
6 Bonfield Road
5
0
0
0
0
5
5 Bonfield Road
6
0
0
0
0
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Windows
4 Bonfield Road
7
0
0
0
0
7
3 Bonfield Road
7
0
0
0
0
7
2 Bonfield Road
7
0
0
0
0
7
1 Bonfield Road
9
0
0
0
0
9
131-133 Lewisham High Street
43
0
0
0
0
43
135 Lewisham High Street
2
0
0
0
0
2
137 Lewisham High Street
2
0
0
0
0
2
139-141 Lewisham High Street
14
0
0
0
0
14
153 Lewisham High Street
2
6
0
0
6
8
155 Lewisham High Street
26
15
3
0
18
44
161 Lewisham High Street
3
4
0
0
4
7
163 Lewisham High Street
3
3
0
0
3
6
165 Lewisham High Street
3
1
1
1
3
6
167 Lewisham High Street
2
3
0
1
4
6
169 Lewisham High Street
2
2
0
0
2
4
171 Lewisham High Street
4
0
0
0
0
4
St Saviours Church, 175 Lewisham High Street
14
7
2
0
9
23
187 Lewisham High Street
2
4
0
0
4
6
189 Lewisham High Street
1
4
0
0
4
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Windows
191-193 Lewisham High Street
4
6
0
0
6
10
195 Lewisham High Street
5
0
0
0
0
5
197 Lewisham High Street
30
0
0
0
0
30
203 Lewisham High Street
9
0
0
0
0
9
205 Lewisham High Street
17
0
0
0
0
17
207 Lewisham High Street
9
0
0
0
0
9
209-211 Lewisham High Street
18
0
0
0
0
18
226-230 Lewisham High Street
52
0
0
0
0
52
Riverdale House, 68 Molesworth Street
119
9
97
61
167
286
Mill Apartments, 68 Molesworth Street
52
0
1
13
14
66
23 Odell Walk
3
0
0
0
0
3
21 Odell Walk
3
0
0
0
0
3
19 Odell Walk
3
0
0
0
0
3
17 Odell Walk
3
0
0
0
0
3
15 Odell Walk
3
0
0
0
0
3
13 Odell Walk
3
0
0
0
0
3
11 Odell Walk
3
0
0
0
0
3
9 Odell Walk
3
0
0
0
0
3
7 Odell Walk
3
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Windows
5 Odell Walk
3
0
0
0
0
3
3 Odell Walk
3
0
0
0
0
3
1 Odell Walk
2
1
0
0
1
3
Bellflower Court, Odell Walk
20
0
0
0
0
20
14 Odell Walk
5
3
0
0
3
8
12 Odell Walk
5
3
0
0
3
8
10 Odell Walk
7
1
0
0
1
8
8 Odell Walk
7
1
0
0
1
8
6 Odell Walk
8
0
0
0
0
8
4 Odell Walk
8
0
0
0
0
8
2 Odell Walk
8
0
0
0
0
8
1 Bankside Avenue
4
0
0
0
0
4
2 Bankside Avenue
4
0
0
0
0
4
3 Bankside Avenue
4
0
0
0
0
4
4 Bankside Avenue
4
0
0
0
0
4
5 Bankside Avenue
4
0
0
0
0
4
6 Bankside Avenue
6
2
0
0
2
8
1 Yew Tree Close
6
0
0
0
0
6
3 Yew Tree Close
6
0
0
0
0
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Windows
5 Yew Tree Close
5
1
0
0
1
6
7 Yew Tree Close
4
2
0
0
2
6
9 Yew Tree Close
4
2
0
0
2
6
11 Yew Tree Close
4
2
0
0
2
6
13 Yew Tree Close
3
3
0
0
3
6
10 Yew Tree Close
5
3
0
0
3
8
8 Yew Tree Close
5
3
0
0
3
8
6 Yew Tree Close
7
1
0
0
1
8
4 Yew Tree Close
7
1
0
0
1
8
2 Yew Tree Close
8
0
0
0
0
8
7 Bankside Avenue
6
2
0
0
2
8
8 Bankside Avenue
3
1
0
0
1
4
9 Bankside Avenue
1
3
0
0
3
4
10 Bankside Avenue
0
4
0
0
4
4
11 Bankside Avenue
0
4
0
0
4
4
12 Bankside Avenue
0
4
0
0
4
4
13 Bankside Avenue
2
2
0
0
2
4
14 Bankside Avenue
2
2
0
0
2
4
15 Bankside Avenue
4
4
0
0
4
8
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Windows
1 Elder Walk
6
0
0
0
0
6
3 Elder Walk
6
0
0
0
0
6
5 Elder Walk
6
0
0
0
0
6
7 Elder Walk
6
1
0
0
1
7
Mill House, Elder Walk
101
0
4
6
10
111
Venice Corte, 2 Elmira Street
224
1
1
0
2
226
Torre Vista, 45 Loampit Vale
147
3
0
0
3
150
Sienna Alto, 2 Cornmill Lane
365
48
11
0
59
424
Glass Mill Leisure Centre, 41 Loampit Vale
1
0
0
0
0
1
Lewisham Gateway (Under Construction)
486
23
66
82
171
657
50 Lewisham High Street
2
0
0
6
6
8
52 Lewisham High Street
0
0
0
7
7
7
58-60 Lewisham High Street
3
0
0
5
5
8
66 Lewisham High Street
0
0
0
8
8
8
86-88 Lewisham High Street
4
2
8
1
11
15
90 Lewisham High Street
0
0
1
3
4
4
92 Lewisham High Street
1
1
2
0
3
4
94 Lewisham High Street
1
1
2
0
3
4
96 Lewisham High Street
0
0
0
2
2
2
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
VSC SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Windows
98 Lewisham High Street
0
2
3
2
7
7
116-118 Lewisham High Street
1
0
0
10
10
11
174-176 Lewisham High Street
0
0
0
6
6
6
198-206 Lewisham High Street
0
0
5
6
11
11
129 Lewisham High Street
9
0
0
0
0
9
127 Lewisham High Street
0
6
0
0
6
6
125 Lewisham High Street
0
8
0
0
8
8
123 Lewisham High Street
0
8
0
0
8
8
121 Lewisham High Street
0
6
0
0
6
6
117-119 Lewisham High Street
2
4
0
2
6
8
97-99 Lewisham High Street
19
6
0
0
6
25
93-95 Lewisham High Street
52
4
0
0
4
56
85-87 Lewisham High Street
70
1
0
0
1
71
110 Lewisham High Street
0
0
0
4
4
4
112 Lewisham High Street
0
0
0
3
3
3
114 Lewisham High Street
0
0
0
6
6
6
Total
3043
245
209
240
694
3737
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Table 12. 24 - NSL Summary with the Development in Place (Illustrative Masterplan: Cumulative Assessment) NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
Isabella Apartments, 102 Granville Park
28
0
0
0
0
28
25 Lewisham High Street
4
0
0
0
0
4
27 Lewisham High Street
4
0
0
0
0
4
29 Lewisham High Street
4
0
0
0
0
4
31 Lewisham High Street
6
0
0
0
0
6
1 Cressingham Road
7
0
0
0
0
7
3 Cressingham Road
4
0
0
0
0
4
5 Cressingham Road
4
0
0
0
0
4
7 Cressingham Road
4
0
0
0
0
4
9 Cressingham Road
4
0
0
0
0
4
11 Cressingham Road
4
0
0
0
0
4
13 Cressingham Road
4
0
0
0
0
4
15 Cressingham Road
4
0
0
0
0
4
17 Cressingham Road
5
0
0
0
0
5
19 Cressingham Road
4
0
0
0
0
4
21 Cressingham Road
10
0
0
0
0
10
23 Cressingham Road
4
0
0
0
0
4
16 Cressingham Road
6
0
0
0
0
6
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
14 Cressingham Road
6
0
0
0
0
6
12 Cressingham Road
6
0
0
0
0
6
10 Cressingham Road
6
0
0
0
0
6
8 Cressingham Road
6
0
0
0
0
6
6 Cressingham Road
6
0
0
0
0
6
4 Cressingham Road
6
0
0
0
0
6
2 Cressingham Road
6
0
0
0
0
6
St Stephens Church Vicarage, Cressingham Road
10
0
0
0
0
10
1 Stephens Grove
3
0
0
0
0
3
2 Stephens Grove
3
0
0
0
0
3
3 Stephens Grove
3
0
0
0
0
3
4 Stephens Grove
3
0
0
0
0
3
5 Stephens Grove
3
0
0
0
0
3
6 Stephens Grove
3
0
0
0
0
3
7 Stephens Grove
3
0
0
0
0
3
8 Stephens Grove
3
0
0
0
0
3
1 Lockmead Road
3
0
0
0
0
3
3 Lockmead Road
3
0
0
0
0
3
5 Lockmead Road
3
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
3 Boyne Road
3
0
0
0
0
3
1 Boyne Road
3
0
0
0
0
3
9 Stephens Grove
5
0
0
0
0
5
10 Stephens Grove
5
0
0
0
0
5
11 Stephens Grove
5
0
0
0
0
5
12 Stephens Grove
5
0
0
0
0
5
13 Stephens Grove
5
0
0
0
0
5
14 Stephens Grove
5
0
0
0
0
5
15 Stephens Grove
5
0
0
0
0
5
16 Stephens Grove
5
0
0
0
0
5
17 Stephens Grove
5
0
0
0
0
5
18 Stephens Grove
5
0
0
0
0
5
19 Stephens Grove
5
0
0
0
0
5
19 Granville Grove
3
0
0
0
0
3
20 Granville Grove
3
0
0
0
0
3
21 Granville Grove
3
0
0
0
0
3
22 Granville Grove
3
0
0
0
0
3
23 Granville Grove
3
0
0
0
0
3
24 Granville Grove
3
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
25 Granville Grove
3
0
0
0
0
3
27 Granville Grove
6
0
0
0
0
6
65-71 Lewisham High Street
20
0
0
0
0
20
85 Lewisham High Street, 1-3 Belmont Hill
4
0
0
0
0
4
5 Belmont Hill
2
0
0
0
0
2
7-9 Belmont Hill
2
0
0
0
0
2
2-4 Belmont Hill
14
0
0
0
0
14
1 Lee High Road
10
0
0
0
0
10
3-5 Lee High Road
3
0
0
0
0
3
7 Lee High Road
4
0
0
0
0
4
9 Lee High Road
1
0
0
0
0
1
11-13 Lee High Road
3
0
0
0
0
3
15 Lee High Road
1
0
0
0
0
1
17 Lee High Road
4
0
0
0
0
4
19 Lee High Road
4
0
0
0
0
4
21 Lee High Road
6
0
0
0
0
6
14-16 Lee High Road
10
0
0
0
0
10
4-6 Lee High Road
12
0
0
0
0
12
1 Lewis Grove
4
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
1 Mercia Grove
5
0
0
0
0
5
2 Mercia Grove
5
0
0
0
0
5
3 Mercia Grove
5
0
0
0
0
5
4 Mercia Grove
5
0
0
0
0
5
5 Mercia Grove
5
0
0
0
0
5
6 Mercia Grove
5
0
0
0
0
5
7 Mercia Grove
5
0
0
0
0
5
8 Mercia Grove
5
0
0
0
0
5
9 Mercia Grove
5
0
0
0
0
5
10 Mercia Grove
5
0
0
0
0
5
11 Mercia Grove
5
0
0
0
0
5
12 Mercia Grove
3
0
0
0
0
3
13 Mercia Grove
3
0
0
0
0
3
14 Mercia Grove
4
0
0
0
0
4
15 Mercia Grove
6
0
0
0
0
6
16 Mercia Grove
4
0
0
0
0
4
17 Mercia Grove
4
0
0
0
0
4
18 Mercia Grove
6
0
0
0
0
6
19 Mercia Grove
5
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
20 Mercia Grove
5
0
0
0
0
5
21 Mercia Grove
6
0
0
0
0
6
23 Merci Grove
29
0
0
0
0
29
4 Albion Way
6
0
0
0
0
6
2 Albion Way
7
0
0
0
0
7
8 Bonfield Road
3
0
0
0
0
3
7 Bonfield Road
4
0
0
0
0
4
6 Bonfield Road
4
0
0
0
0
4
5 Bonfield Road
5
0
0
0
0
5
4 Bonfield Road
5
0
0
0
0
5
3 Bonfield Road
6
0
0
0
0
6
2 Bonfield Road
6
0
0
0
0
6
1 Bonfield Road
6
0
0
0
0
6
131-133 Lewisham High Street
26
0
0
0
0
26
135 Lewisham High Street
2
0
0
0
0
2
137 Lewisham High Street
2
0
0
0
0
2
139-141 Lewisham High Street
10
0
0
0
0
10
153 Lewisham High Street
3
1
0
0
1
4
155 Lewisham High Street
13
0
0
0
0
13
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
161 Lewisham High Street
3
0
0
1
1
4
163 Lewisham High Street
2
0
0
1
1
3
165 Lewisham High Street
2
0
0
1
1
3
167 Lewisham High Street
1
1
0
1
2
3
169 Lewisham High Street
3
0
0
0
0
3
171 Lewisham High Street
2
1
1
0
2
4
St Saviours Church, 175 Lewisham High Street
11
2
0
0
2
13
187 Lewisham High Street
2
3
0
1
4
6
189 Lewisham High Street
5
0
0
0
0
5
191-193 Lewisham High Street
10
0
0
0
0
10
195 Lewisham High Street
5
0
0
0
0
5
197 Lewisham High Street
20
0
0
0
0
20
203 Lewisham High Street
6
0
0
0
0
6
205 Lewisham High Street
7
0
0
0
0
7
207 Lewisham High Street
3
0
0
0
0
3
209-211 Lewisham High Street
9
0
0
0
0
9
226-230 Lewisham High Street
52
0
0
0
0
52
Riverdale House, 68 Molesworth Street
143
31
13
0
44
187
Mill Apartments, 68 Molesworth Street
25
1
0
4
5
30
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
23 Odell Walk
2
0
0
0
0
2
21 Odell Walk
2
0
0
0
0
2
19 Odell Walk
2
0
0
0
0
2
17 Odell Walk
2
0
0
0
0
2
15 Odell Walk
2
0
0
0
0
2
13 Odell Walk
2
0
0
0
0
2
11 Odell Walk
2
0
0
0
0
2
9 Odell Walk
2
0
0
0
0
2
7 Odell Walk
2
0
0
0
0
2
5 Odell Walk
2
0
0
0
0
2
3 Odell Walk
2
0
0
0
0
2
1 Odell Walk
2
0
0
0
0
2
Bellflower Court, Odell Walk
12
0
0
0
0
12
14 Odell Walk
4
1
0
0
1
5
12 Odell Walk
4
1
0
0
1
5
10 Odell Walk
4
1
0
0
1
5
8 Odell Walk
5
0
0
0
0
5
6 Odell Walk
5
0
0
0
0
5
4 Odell Walk
5
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
2 Odell Walk
5
0
0
0
0
5
1 Bankside Avenue
4
0
0
0
0
4
2 Bankside Avenue
4
0
0
0
0
4
3 Bankside Avenue
4
0
0
0
0
4
4 Bankside Avenue
4
0
0
0
0
4
5 Bankside Avenue
4
0
0
0
0
4
6 Bankside Avenue
5
1
0
0
1
6
1 Yew Tree Close
4
0
0
0
0
4
3 Yew Tree Close
4
0
0
0
0
4
5 Yew Tree Close
4
0
0
0
0
4
7 Yew Tree Close
4
0
0
0
0
4
9 Yew Tree Close
4
0
0
0
0
4
11 Yew Tree Close
4
0
0
0
0
4
13 Yew Tree Close
4
0
0
0
0
4
10 Yew Tree Close
5
0
0
0
0
5
8 Yew Tree Close
5
0
0
0
0
5
6 Yew Tree Close
5
0
0
0
0
5
4 Yew Tree Close
5
0
0
0
0
5
2 Yew Tree Close
5
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
7 Bankside Avenue
5
1
0
0
1
6
8 Bankside Avenue
4
0
0
0
0
4
9 Bankside Avenue
1
3
0
0
3
4
10 Bankside Avenue
3
1
0
0
1
4
11 Bankside Avenue
4
0
0
0
0
4
12 Bankside Avenue
4
0
0
0
0
4
13 Bankside Avenue
2
1
1
0
2
4
14 Bankside Avenue
3
1
0
0
1
4
15 Bankside Avenue
4
2
0
0
2
6
1 Elder Walk
4
0
0
0
0
4
3 Elder Walk
4
0
0
0
0
4
5 Elder Walk
4
0
0
0
0
4
7 Elder Walk
4
0
0
0
0
4
Mill House, Elder Walk
95
0
0
0
0
95
Venice Corte, 2 Elmira Street
174
0
0
0
0
174
Torre Vista, 45 Loampit Vale
126
0
0
0
0
126
Sienna Alto, 2 Cornmill Lane
175
2
0
0
2
177
Glass Mill Leisure Centre, 41 Loampit Vale
1
0
0
0
0
1
Lewisham Gateway (Under Construction)
365
12
8
6
26
391
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
50 Lewisham High Street
0
2
1
2
5
5
52 Lewisham High Street
0
0
1
6
7
7
58-60 Lewisham High Street
2
1
1
2
4
6
66 Lewisham High Street
0
1
1
4
6
6
86-88 Lewisham High Street
3
0
3
8
11
14
90 Lewisham High Street
0
0
0
2
2
2
92 Lewisham High Street
0
1
2
0
3
3
94 Lewisham High Street
1
0
1
2
3
4
96 Lewisham High Street
0
0
0
2
2
2
98 Lewisham High Street
0
1
2
3
6
6
116-118 Lewisham High Street
2
1
2
6
9
11
174-176 Lewisham High Street
6
0
0
0
0
6
198-206 Lewisham High Street
0
0
6
5
11
11
129 Lewisham High Street
5
0
0
0
0
5
127 Lewisham High Street
2
0
1
0
1
3
125 Lewisham High Street
3
0
0
0
0
3
123 Lewisham High Street
3
0
0
0
0
3
121 Lewisham High Street
3
0
0
0
0
3
117-119 Lewisham High Street
0
0
0
4
4
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
NSL SUMMARY Below BRE Guidelines Address
Total that Meet BRE Guidelines
2029% Loss
3039.9% Loss
>=40% Loss
Total
Total No. of Rooms
97-99 Lewisham High Street
7
0
0
0
0
7
93-95 Lewisham High Street
27
0
0
0
0
27
85-87 Lewisham High Street
10
0
0
0
0
10
110 Lewisham High Street
0
0
2
1
3
3
112 Lewisham High Street
1
1
0
0
1
2
114 Lewisham High Street
1
3
1
0
4
5
Total
2140
78
47
62
187
2327
12.11.146 The Cumulative Assessment technical findings of the VSC and NSL analysis (shown on Table 12.23 and Table 12.24) above record daylight effects and BRE transgressions that are consistent with those outlined within the Illustrative Main Assessments. The VSC result of the Illustrative Cumulative Scenario shows that there are isolated differences when compared to the Main Assessment: Illustrative Scenario. The differences are contained to properties on the Lewisham High Street that have a direct outlook over the individual cumulative scheme – the Lewisham High Street Open Market. The affected properties are listed below. • •
127 Lewisham High Street 125 Lewisham High Street
12.11.147 The affected properties listed above record additional BRE transgressions in relation to the VSC test. However, the transgressions recorded as a result of the cumulative scenario do not render a change in significance classification that has been applied in the Main Assessment: Illustrative Scenario. The result of the NSL test for these properties remain unchanged from the Main Assessment: Illustrative Scenario.
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
Sunlight to Surrounding Properties 12.11.148 There are 2351 windows serving 1416 residential rooms surrounding the Site that are relevant for sunlight amenity assessment. These have all been assessed in terms of total and winter APSH. Full detailed results can be found at Appendix 12.3 and are summarised in Table 12.25 that show those properties that record full BRE compliance, in respect of APSH, highlighted in green. Table 12.25 - APSH Summary with the Development in Place (Illustrative Masterplan: Cumulative Scenario) APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guideline s
Below Threshold for Winter APSH
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Tota l
2030 %
3040 %
>40 %
Tota l
Total No. Room s
Isabella Apartments, 102 Granville Park
28
0
0
0
0
0
0
0
0
28
25 Lewisham High Street
3
0
0
1
1
0
0
0
0
4
27 Lewisham High Street
4
0
0
0
0
0
0
0
0
4
29 Lewisham High Street
4
0
0
0
0
0
0
0
0
4
31 Lewisham High Street
6
0
0
0
0
0
0
0
0
6
1 Cressingham Road
7
0
0
0
0
0
0
0
0
7
3 Cressingham Road
4
0
0
0
0
0
0
0
0
4
5 Cressingham Road
4
0
0
0
0
0
0
0
0
4
7 Cressingham Road
4
0
0
0
0
0
0
0
0
4
9 Cressingham Road
4
0
0
0
0
0
0
0
0
4
11 Cressingham Road
4
0
0
0
0
0
0
0
0
4
13 Cressingham Road
4
0
0
0
0
0
0
0
0
4
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guideline s
Below Threshold for Winter APSH
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Tota l
2030 %
3040 %
>40 %
Tota l
Total No. Room s
15 Cressingham Road
4
0
0
0
0
0
0
0
0
4
17 Cressingham Road
5
0
0
0
0
0
0
0
0
5
19 Cressingham Road
4
0
0
0
0
0
0
0
0
4
21 Cressingham Road
10
0
0
0
0
0
0
0
0
10
23 Cressingham Road
4
0
0
0
0
0
0
0
0
4
16 Cressingham Road
6
0
0
0
0
0
0
0
0
6
14 Cressingham Road
6
0
0
0
0
0
0
0
0
6
12 Cressingham Road
6
0
0
0
0
0
0
0
0
6
10 Cressingham Road
6
0
0
0
0
0
0
0
0
6
8 Cressingham Road
6
0
0
0
0
0
0
0
0
6
6 Cressingham Road
6
0
0
0
0
0
0
0
0
6
4 Cressingham Road
6
0
0
0
0
0
0
0
0
6
2 Cressingham Road
6
0
0
0
0
0
0
0
0
6
St Stephens Church Vicarage, Cressingham Road
10
0
0
0
0
0
0
0
0
10
1 Stephens Grove
3
0
0
0
0
0
0
0
0
3
2 Stephens Grove
3
0
0
0
0
0
0
0
0
3
3 Stephens Grove
3
0
0
0
0
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guideline s
Below Threshold for Winter APSH
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Tota l
2030 %
3040 %
>40 %
Tota l
Total No. Room s
4 Stephens Grove
3
0
0
0
0
0
0
0
0
3
5 Stephens Grove
3
0
0
0
0
0
0
0
0
3
6 Stephens Grove
3
0
0
0
0
0
0
0
0
3
7 Stephens Grove
3
0
0
0
0
0
0
0
0
3
8 Stephens Grove
3
0
0
0
0
0
0
0
0
3
1 Lockmead Road
3
0
0
0
0
0
0
0
0
3
3 Lockmead Road
3
0
0
0
0
0
0
0
0
3
5 Lockmead Road
3
0
0
0
0
0
0
0
0
3
3 Boyne Road
3
0
0
0
0
0
0
0
0
3
1 Boyne Road
3
0
0
0
0
0
0
0
0
3
9 Stephens Grove
5
0
0
0
0
0
0
0
0
5
10 Stephens Grove
5
0
0
0
0
0
0
0
0
5
11 Stephens Grove
5
0
0
0
0
0
0
0
0
5
12 Stephens Grove
5
0
0
0
0
0
0
0
0
5
13 Stephens Grove
5
0
0
0
0
0
0
0
0
5
14 Stephens Grove
5
0
0
0
0
0
0
0
0
5
15 Stephens Grove
5
0
0
0
0
0
0
0
0
5
16 Stephens Grove
5
0
0
0
0
0
0
0
0
5
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guideline s
Below Threshold for Winter APSH
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Tota l
2030 %
3040 %
>40 %
Tota l
Total No. Room s
17 Stephens Grove
5
0
0
0
0
0
0
0
0
5
18 Stephens Grove
5
0
0
0
0
0
0
0
0
5
19 Stephens Grove
5
0
0
0
0
0
0
0
0
5
19 Granville Grove
3
0
0
0
0
0
0
0
0
3
20 Granville Grove
3
0
0
0
0
0
0
0
0
3
21 Granville Grove
3
0
0
0
0
0
0
0
0
3
22 Granville Grove
3
0
0
0
0
0
0
0
0
3
23 Granville Grove
3
0
0
0
0
0
0
0
0
3
24 Granville Grove
3
0
0
0
0
0
0
0
0
3
25 Granville Grove
3
0
0
0
0
0
0
0
0
3
27 Granville Grove
6
0
0
0
0
0
0
0
0
6
65-71 Lewisham High Street
20
0
0
0
0
0
0
0
0
20
85 Lewisham High Street, 1-3 Belmont Hill
4
0
0
0
0
0
0
0
0
4
5 Belmont Hill
2
0
0
0
0
0
0
0
0
2
7-9 Belmont Hill
2
0
0
0
0
0
0
0
0
2
2-4 Belmont Hill
1
0
0
0
0
0
0
0
0
1
1 Lee High Road
3
0
0
0
0
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guideline s
Below Threshold for Winter APSH
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Tota l
2030 %
3040 %
>40 %
Tota l
Total No. Room s
3-5 Lee High Road
2
0
0
0
0
0
0
0
0
2
7 Lee High Road
4
0
0
0
0
0
0
0
0
4
9 Lee High Road
1
0
0
0
0
0
0
0
0
1
11-13 Lee High Road
3
0
0
0
0
0
0
0
0
3
15 Lee High Road
1
0
0
0
0
0
0
0
0
1
17 Lee High Road
3
0
0
0
0
0
0
0
0
3
19 Lee High Road
3
0
0
0
0
0
0
0
0
3
21 Lee High Road
6
0
0
0
0
0
0
0
0
6
14-16 Lee High Road
9
0
0
0
0
0
0
0
0
9
4-6 Lee High Road
6
0
0
0
0
0
0
0
0
6
1 Lewis Grove
2
0
0
0
0
0
0
0
0
2
1 Mercia Grove
3
0
0
0
0
0
0
0
0
3
2 Mercia Grove
3
0
0
0
0
0
0
0
0
3
3 Mercia Grove
3
0
0
0
0
0
0
0
0
3
4 Mercia Grove
3
0
0
0
0
0
0
0
0
3
5 Mercia Grove
3
0
0
0
0
0
0
0
0
3
6 Mercia Grove
3
0
0
0
0
0
0
0
0
3
7 Mercia Grove
3
0
0
0
0
0
0
0
0
3
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Plowman Craven 46730 October 2024
APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guideline s
Below Threshold for Winter APSH
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Tota l
2030 %
3040 %
>40 %
Tota l
Total No. Room s
8 Mercia Grove
3
0
0
0
0
0
0
0
0
3
9 Mercia Grove
3
0
0
0
0
0
0
0
0
3
10 Mercia Grove
4
0
0
0
0
0
0
0
0
4
11 Mercia Grove
3
0
0
0
0
0
0
0
0
3
12 Mercia Grove
2
0
0
0
0
0
0
0
0
2
13 Mercia Grove
2
0
0
0
0
0
0
0
0
2
14 Mercia Grove
2
0
0
0
0
0
0
0
0
2
15 Mercia Grove
2
0
0
0
0
0
0
0
0
2
16 Mercia Grove
2
0
0
0
0
0
0
0
0
2
17 Mercia Grove
2
0
0
0
0
0
0
0
0
2
18 Mercia Grove
4
0
0
0
0
0
0
0
0
4
19 Mercia Grove
2
0
0
0
0
0
0
0
0
2
20 Mercia Grove
2
0
0
0
0
0
0
0
0
2
21 Mercia Grove
3
0
0
0
0
0
0
0
0
3
23 Merci Grove
11
0
0
0
0
0
0
0
0
11
4 Albion Way
3
0
0
0
0
0
0
0
0
3
2 Albion Way
3
0
0
0
0
0
0
0
0
3
8 Bonfield Road
1
0
0
0
0
0
0
0
0
1
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APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guideline s
Below Threshold for Winter APSH
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Tota l
2030 %
3040 %
>40 %
Tota l
Total No. Room s
6 Bonfield Road
1
0
0
0
0
0
0
0
0
1
4 Bonfield Road
2
0
0
0
0
0
0
0
0
2
2 Bonfield Road
3
0
0
0
0
0
0
0
0
3
131-133 Lewisham High Street
12
0
0
0
0
0
0
0
0
12
139-141 Lewisham High Street
6
0
0
0
0
0
0
0
0
6
155 Lewisham High Street
12
0
0
0
0
1
0
0
1
13
St Saviours Church, 175 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
197 Lewisham High Street
3
0
0
0
0
0
0
0
0
3
205 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
226-230 Lewisham High Street
25
0
0
0
0
0
0
0
0
25
Riverdale House, 68 Molesworth Street
34
0
0
0
0
0
0
0
0
34
Mill Apartments, 68 Molesworth Street
19
0
0
1
1
0
0
0
0
20
14 Odell Walk
3
0
0
0
0
0
0
0
0
3
12 Odell Walk
3
0
0
0
0
0
0
0
0
3
10 Odell Walk
3
0
0
0
0
0
0
0
0
3
8 Odell Walk
3
0
0
0
0
0
0
0
0
3
6 Odell Walk
3
0
0
0
0
0
0
0
0
3
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APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guideline s
Below Threshold for Winter APSH
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Tota l
2030 %
3040 %
>40 %
Tota l
Total No. Room s
4 Odell Walk
3
0
0
0
0
0
0
0
0
3
2 Odell Walk
3
0
0
0
0
0
0
0
0
3
1 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
2 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
3 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
4 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
5 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
6 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
1 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
3 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
5 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
7 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
9 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
11 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
13 Yew Tree Close
2
0
0
0
0
0
0
0
0
2
10 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
8 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
6 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
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APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guideline s
Below Threshold for Winter APSH
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Tota l
2030 %
3040 %
>40 %
Tota l
Total No. Room s
4 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
2 Yew Tree Close
3
0
0
0
0
0
0
0
0
3
7 Bankside Avenue
6
0
0
0
0
0
0
0
0
6
8 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
9 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
10 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
11 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
12 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
13 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
14 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
15 Bankside Avenue
4
0
0
0
0
0
0
0
0
4
1 Elder Walk
2
0
0
0
0
0
0
0
0
2
3 Elder Walk
2
0
0
0
0
0
0
0
0
2
5 Elder Walk
2
0
0
0
0
0
0
0
0
2
7 Elder Walk
2
0
0
0
0
0
0
0
0
2
Mill House, Elder Walk
44
0
0
0
0
0
3
0
3
47
Venice Corte, 2 Elmira Street
60
0
0
0
0
0
0
0
0
60
Sienna Alto, 2 Cornmill Lane
164
0
0
5
5
9
4
0
13
177
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APSH ROOM SUMMARY No. of rooms below the APSH stated in BRE Guidelines
Address
Meet BRE Guideline s
Below Threshold for Winter APSH
Below Threshold for Annual APSH
2030 %
3040 %
>40 %
Tota l
2030 %
3040 %
>40 %
Tota l
Total No. Room s
Glass Mill Leisure Centre, 41 Loampit Vale
1
0
0
0
0
0
0
0
0
1
Lewisham Gateway (Under Construction)
381
0
0
6
6
2
1
7
10
391
50 Lewisham High Street
1
0
0
4
4
0
0
4
4
5
52 Lewisham High Street
1
0
0
4
4
0
0
6
6
7
58-60 Lewisham High Street
1
0
0
5
5
0
0
4
4
6
66 Lewisham High Street
0
0
0
6
6
0
0
6
6
6
86-88 Lewisham High Street
9
0
0
0
0
2
2
1
5
14
90 Lewisham High Street
1
0
0
0
0
0
0
1
1
2
92 Lewisham High Street
2
0
0
0
0
0
0
1
1
3
129 Lewisham High Street
4
0
0
0
0
0
0
0
0
4
117-119 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
97-99 Lewisham High Street
2
0
0
0
0
0
0
0
0
2
93-95 Lewisham High Street
11
0
0
0
0
0
0
0
0
11
85-87 Lewisham High Street
5
0
0
0
0
0
0
0
0
5
Total
1359
0
0
32
32
14
10
30
54
1416
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12.11.149 The Cumulative Assessment technical findings of the APSH analysis (shown on Table 12.25) above record daylight effects and BRE transgressions that are consistent with those outlined within the Illustrative Main Assessments. The result of the APSH technical assessment records a BRE compliance and subsequent transgressions that are consistent with those reported in the Illustrative Masterplan: Main Assessment.
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Table 12.26 Summary of Effects DESCRIPTION RECEPTOR OF SIGNIFICANT EFFECTS
SIGNIFICANCE OF EFFECTS MAJOR / POSITIV P / T D ST / MODERATE / E / / MT / MINOR / NEGATIV I LT NEGLIGIBLE E
SUMMARY OF MITIGATION / ENHANCEMENT MEASURES
SIGNIFICANCE OF RESIDUAL EFFECTS RELEVANT MAJOR / POSITIVE / P / T D ST / POLICY MODERATE / NEGATIVE / I MT / MINOR / LT NEGLIGIBLE
Existing adjacent residential properties Existing adjacent residential properties Existing adjacent areas of open space Surrounding road junctions and train approaches Existing adjacent residential properties
Negligible to Major
Negative Temporary
LT
None Required
Negligible to Major Negative
Temporary
LT
Negligible to Major
Negative Temporary
LT
None Required
Negligible to Major Negative
Temporary
LT
Negligible
Positive
Temporary
LT
None Required
Negligible
Positive
Temporary
LT
Negligible to Minor
Negative Temporary
LT
None Required
Negligible to Minor Negative
Temporary
LT
Negligible
Positive
Temporary
LT
None Required
Negligible
Positive
Temporary
LT
Existing adjacent residential properties Existing adjacent residential properties Existing adjacent areas of open space
Negligible to Major
Negative Permanent
LT
None Required
Negligible to Major Negative
Permanent
LT
Negligible to Major
Negative Permanent
LT
None Required
Negligible to Major Negative
Permanent
LT
Negligible to Major
Positive
LT
None Required
Negligible to Major Negative
Permanent
LT
Demolition & Construction Daylight
Sunlight
Overshadowing
Solar Glare
Light Pollution
Operation Daylight
Sunlight
Overshadowing
Permanent
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RELEVANT LEGISLATION
Solar Glare
Light Pollution
Surrounding road junctions and train approaches Existing adjacent residential properties
Negligible to Minor
Negative Permanent
LT
None Required
Negligible to Minor Negative
Permanent
LT
Negligible
Positive
LT
None Required
Negligible
Temporary
LT
Temporary
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 12: Daylight. Sunlight
Positive
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12.12 Executive Non-Technical Summary 12.12.1 The Lewisham Shopping Centre site represents a significant regeneration opportunity for the London Borough of Lewisham, within a town centre that is currently undergoing considerable redevelopment in line with the aspirations of the Local Plan. 12.12.2 The current site is comprised of a large series of relatively low-medium rise commercial buildings and as such, where residential buildings are located in nearby proximity to the site and relevant for assessment, 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. 12.12.3 It is therefore inevitable, particularly in major regeneration and opportunity areas, that if redevelopment proposals are to deliver in accordance with local planning policy aspirations and make efficient use of land in line with the National Planning Policy Framework, a noticeable degree of change in daylight and sunlight levels will naturally be experienced. 12.12.4 Notwithstanding this, the detailed technical assessments for the Operational Phase of the development (for both the Outline Maximum Parameters and Detailed Blocks N1 and N2) undertaken and set out within this Chapter, demonstrate that the compliance levels when measured against the BRE Guidelines (2022) recommendations are very good for an urban town-centre location. 12.12.5 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 Daylight Distribution criteria. For sunlight, 94% of all southerly orientated habitable rooms will exceed the BRE recommendations for Annual Probable Sunlight Hours. This demonstrates that a high proportion of the sensitive receptors around the site will experience daylight and sunlight effects of negligible significance. 12.12.6 From a sun on ground (overshadowing perspective) whilst there will naturally be some gardens/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 experience a negligible effect. 12.12.7 It is, however, also important to note that the Illustrative Masterplan for the Site has also been assessed, which complies with the maximum parameter plans and represents a more ‘realistic’ future development proposal for the Outline element of the site. The technical assessments indicate a further reduced daylight and sunlight effect upon the sensitive receptors by comparison to the Maximum Parameter massing, 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 Element of the Masterplan can be positively reduced, mitigated and, in many cases, designed out at future detailed reserved matters stage, by adopting the principles defined by the Illustrative Masterplan. 12.12.8 Finally, there will be no significant effects upon both light pollution and solar glare effects of the detailed elements of the Operational Phase of the Development.
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13.0 Wind Microclimate Executive Summary This Chapter reports the likely significant effects of the Proposed Development on the Site and the surrounding area in terms of Wind Microclimate matters. Where appropriate, it also identifies proposed mitigation measures to prevent, minimise or control likely negative effects arising from the Proposed Development and the subsequent anticipated residual effects. The 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 in Appendix 13.1. 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. The wind tunnel assessment comprises 5 scenarios as specified in the Scoping Opinion. The assessment of the wind microclimate impacts, using the wind tunnel, comprises the following scenarios: •
Scenario 1 Existing Baseline: Assessment of the existing buildings on the Site with the existing surrounding context. Includes buildings under construction.
•
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 Element): Assessment of the Detailed elements of the Proposed Development on the Site with the existing surrounding context.
•
Scenario 4 Proposed Scenario (Combined): Assessment of the Proposed Detailed and Outline elements (Max Parameters) of the Proposed Development combined, with existing surroundings.
•
Scenario 5 Cumulative Effects: Assessment of the Proposed Detailed and Outline elements of the Proposed Development (Max Parameters), in combination with future (consented and under consideration) schemes in the surrounding area.
Each scenario is discussed in detail in this chapter. As a summary it can be stated that Scenario 3 when mitigation is included, results in negligible wind effects in all areas of the site both at ground and elevated levels. This has been achieved through a series mitigation workshops in the RWDI wind tunnel with contributions from the landscape and architectural design teams. As expected, the windiest conditions are seen in Scenarios 4 and 5 that include the Outline Elements which have assessed the Maximum Parameters that represent the tallest and densest massing tested. This is because high-level high-speed winds downwash along the western facades of the masterplan, accelerating around the base of Plots C5 and C4 onto the podium park, and around the north and south corners of N3, causing safety exceedances in these areas. However, it is important to note that Scenarios 4 and 5 comprising the Detailed and Outline Elements combined represent an unrealistic worst-case scenario since the individual Plots within
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the outline element will be developed further in detail and the building form and massing will be refined. The Max Parameters are a robust assessment, but represents an unrealistic form of development, when compared to the form of development that is more likely to come forward, being more akin to the illustrative masterplan. It is expected that the developed detailed design for each of the Plots will provide improved wind conditions. This is demonstrated comparatively within the CFD modelling work carried out to support the design along its evolution and to provide an early understanding of the wind implications on the Site. The CFD study consisted of computational numerical simulations for a full range of wind directions, with relative wind speeds sampled and combined with long-term historical wind data. A comparative study in the CFD study was used to identify the expected improvements caused by the Illustrative Masterplan. The study showed that it is evident that the reduced massing of the Illustrative Masterplan which incorporates more detail in the building form for each Plot, results in higher air permeability to the Site, especially from the prevailing south-westerly and westerly prevailing winds, slowing wind speeds down. This effect is less apparent in the Max Parameters where a larger proportion of the prevailing south-westerly wind is deflected downwards towards ground level at the north of the site and into the podium levels creating some exceedances. The CFD study shows that some of these exceedances disappear completely, and some reduce substantially in size. It is worth adding that this exercise was undertaken in the absence of mitigation aiming to compare the effect of the massing only. The above comparisons illustrate the point that with a carefully developed design, an Illustrative Masterplan design would provide significant improvements to the wind conditions over an unrealistic maximum parameters scenario where buildings are modelled as simple extrusions with no particular design or shape intended. It is also envisaged that once the detailed design of the various Plots of the Outline Element progress towards detailed planning, there will be further opportunity for the mitigation options explored so far to be further developed as part of the reserved matters stages. The CFD analyses discussed above demonstrate that with a carefully developed design, a detailed design would provide significant improvements to the wind conditions, allowing a solution to be found during the detailed planning stages.
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13.1 Introduction 13.1.1 This Chapter reports the likely significant effects of the Proposed Development on the Site and the surrounding area in terms of Wind Microclimate matters. Where appropriate, it also identifies proposed mitigation measures to prevent, minimise or control likely negative effects arising from the Proposed Development and the subsequent anticipated residual effects. 13.1.2 The effects of the Proposed Development are considered over both the demolition & construction and operational phases. 13.1.3 The main issues covered in this Chapter include the following: • • •
Assessment of Pedestrian comfort and safety at ground and elevated levels; Assessment of 5 different configurations / scenarios discussed later in this chapter; and Assessment of mitigation measures where required.
13.1.4 This Chapter (and its associated figures and appendices) should be read together with the Introductory Chapters of this ES (Chapters 1 – 5), as well as Chapter 17: Effect Interactions. 13.1.5 This Chapter is accompanied by the following appendices: • •
Lewisham Shopping Centre Pedestrian Level Wind Microclimate Report (RWDI) (Appendix 13.1). Lewisham Shopping Centre CFD Pedestrian Level Wind Assessment (WSP) (Appendix 13.2).
Competence 13.1.6 The effects reported in the chapter are based on the results of the wind tunnel testing undertaken by RWDI and reported within RWDI’s Pedestrian Level Wind Microclimate report (Appendix 13.1). 13.1.7 This ES chapter has been prepared by Camilo Diaz and Hamza Alhalabi of WSP. Camilo is a Technical Director at WSP with over 24 years’ experience in environmental design drawn out from his involvement in a wide range of sustainable development projects both in the UK and abroad. Camilo has extensive experience in all aspects relating to the impact of buildings on the local microclimate and advises property clients on associated risks for a wide range of projects from early concept through to planning and beyond. At WSP Camilo leads the Microclimate team, a dedicated team of environmental design specialists providing expert advice on projects in several sectors including residential, commercial, education, rail, aviation, health care and solar energy sectors, both in the UK and internationally. 13.1.8 Hamza is a Principal microclimate consultant at WSP, holding an MSc degree in Architecture and Environmental Design from the University of Westminster, London (Graduated with Distinction). Hamza is a part of a team of environmental design specialists at WSP providing specialist advice to WSP’s property clients in the residential, retail, aviation, commercial, health care, and industrial sectors, both in the UK and internationally. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 13: Wind Microclimate
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13.2 Legislation, Planning Policy and Guidance 13.2.1 There is no specific national legislation or planning policy guidance dealing with wind microclimate in terms of pedestrian comfort. However, the Lawson Comfort Criteria are commonly used nationally to benchmark the pedestrian wind microclimate.
Planning Policy Context National 13.2.2 The following national level policy and guidance documents are of relevance to the Proposed Development: National Planning Policy Framework (2023) 13.2.3 The National Planning Policy Framework was revised in July 2021 by the Department of Communities and Local Government. The relevant paragraphs are as follows: Paragraph 135 of the National Planning Policy Framework states that: “Planning policies and decisions should ensure that developments: a) will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development. b) are visually attractive as a result of good architecture, layout and appropriate and effective landscaping. c) are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change (such as increased densities); d) establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit. e) optimise the potential of the site to accommodate and sustain an appropriate amount and mix of development (including green and other public space) and support local facilities and transport networks; and f) create places that are safe, inclusive and accessible and which promote health and wellbeing, with a high standard of amenity for existing and future users; and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience.” In addition, this Chapter has been prepared in accordance with the Government’s National Planning Practice Guidance.
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Regional London Plan 2021 13.2.4 Paragraph 3.9.7 of The London Plan outlines that: 13.2.5 “The middle of a tall building has an important effect on how much sky is visible from surrounding streets and buildings, as well as on wind flow, privacy and the amount of sunlight and shadowing there is in the public realm and by surrounding properties.” 13.2.6 Paragraph 3.3.8 of The London Plan states that: 13.2.7 “Buildings should be of high quality and enhance, activate and appropriately frame the public realm. Their massing, scale and layout should help make public spaces coherent and 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 sunlight, shade, wind, and shelter from precipitation is important.” 13.2.8 Policy D8 Public Realm states that Development Plans and development proposals should: “g) ensure buildings are of a design that activates and defines the public realm and provides natural surveillance. Consideration should also be given to the local microclimate created by buildings, and the impact of service entrances and facades on the public realm. j) ensure that appropriate shade, shelter, seating and, where possible, areas of direct sunlight are provided, with other microclimatic considerations, including temperature and wind, taken into account in order to encourage people to spend time in a place.” Policy D9 Tall Buildings suggests that Development proposals should address the following environmental impacts: “a) wind, daylight, sunlight penetration and temperature conditions 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.” Local Lewisham Local Plan: Proposed Submission Document, Regulation 19 Stage (January 2023). 13.2.9 The plan addresses microclimatic factors, including the need for shading and shelter to protect people from weather elements like wind and sun. This is essential for pedestrian comfort and public realm usability. This can be found under the Policy QD3 (Public realm and connecting places): “Development proposals should deliver a vibrant public realm that promotes opportunities for relaxation, social interaction and physical activity for people of all ages and abilities. They should seek to create welcoming environments...including consideration for shading and shelter to protect and provide comfort from direct sunlight, rain and wind" 13.2.10 The plan promotes the Healthy Streets Approach, emphasizing public realm improvements to support active travel, including walking and cycling. This is vital for creating Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 13: Wind Microclimate
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safe environments for all road users. This is covered under Policy TR3 (Healthy streets as part of healthy neighbourhoods): "High quality public realm is integral to the delivery of the Healthy Streets Approach... Development proposals must be designed to maximise the contribution that public realm makes to encourage and enable active modes of travel. This includes measures to reduce vehicle dominance and enhance access, permeability and connectivity to and within sites by maintaining or integrating safe and legible routes for walking and cycling." Guidance 13.2.11 The following guidance documents have been used during the preparation of this Chapter: The Lawson Criteria (2001) 13.2.12 The Lawson Criteria are a widely accepted method in the UK and internationally for assessing pedestrian comfort and safety related to wind conditions around buildings. While not a formal UK standard, these criteria are often used by local authorities as a valuable benchmark for wind microclimate assessments. This assessment adopts the Lawson Criteria to evaluate wind comfort and safety at the Site. City of London Wind Microclimate Guidance (2019) 13.2.13 The City of London Wind Microclimate Guidance provides specific guidance for development within the City of London, however some aspects of the guidance such as the significance of effects for EIA assessments, are applicable to sites elsewhere in the UK.
13.3 Consultation 13.3.1 As discussed in Chapter 2: Approach to Assessment, consideration has been given to the formal EIA Scoping Opinion provided by LBL and consultees and any additional consultation that may have occurred during the design period of the Proposed Development. Table 13.1: Consultation Feedback Where is this addressed?
Consultee
Comment
London Borough of Lewisham
It is not clear whether new receptors will be introduced on Site as part of the phased development. If new receptors are introduced on Site whilst the remainder of the site is undergoing construction, an interim scenario should be considered.
Sensitive Receptors Section 13.7
London Borough of Lewisham
Given the height of the Proposed Development, the assessment should consider wind speeds at elevated levels of the Proposed Development
Section Assessment of Effects, Mitigation and Residual Effects, Operational Phase, Scenarios, 3, 4 and 5
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London Borough of Lewisham
The assessment is to assess the wind microclimate to be experienced on any balconies, open spaces and roof terraces as appropriate, including those provided within the Proposed Development, as well as within surrounding buildings, as required. The Applicant should review whether any such spaces are within the study area for assessment, and this should be confirmed in the ES.
Section Assessment of Effects, Mitigation and Residual Effects, Operational Phase, Scenarios, 3, 4 and 5
London Borough of Lewisham
The ES should provide assessment of wind effects during construction utilising the worst-case scenario, such as with cranes in-situ. It should be clear where professional judgement has been applied.
Section Assessment of Effects, Mitigation and Residual Effects, Demolition and Construction Phase, Scenarios, 3, 4 and 5
London Borough of Lewisham
The assessment scenarios to be used within the wind tunnel testing have been updated following advice issued by Temple and now read as:
Section Assessment of Effects, Mitigation and Residual Effects, Operational Phase, Scenarios, 1, 2, 3, 4 and 5
• Scenario 1: Baseline, the existing site condition, including buildings presently under construction; • Scenario 2: Baseline and Cumulative Schemes; • Scenario 3: Detailed elements of the Proposed Development with existing surroundings; • Scenario 4: Detailed and Outline elements of the Proposed Development with existing surroundings; • Scenario 5: Detailed and Outline elements of the Proposed Development with Cumulative Schemes. London Borough of Lewisham
Scenarios 2 and 5 should ensure to include both cumulative (consented) schemes and future schemes submitted for planning consent but not yet consented. This should be explicitly stated within the ES.
Section Assessment of Effects, Mitigation and Residual Effects, Operational Phase, Scenario 5
London Borough of Lewisham
The Applicant should note that if landscaping measures are relied upon in mitigation configurations, to achieve acceptable wind conditions, the landscaping tested should match that submitted for planning or a consideration of the differences between the tested and submitted landscaping plans should be provided.
Section Assessment of Effects, Mitigation and Residual Effects, Operational Phase, Scenarios 3, 4 and 5
London Borough of Lewisham
If mitigation measures are required to ensure wind conditions are suitable for their intended use, wind tunnel testing of these measures is to be undertaken and any results provided in the ES.
Section Assessment of Effects, Mitigation and Residual Effects, Operational Phase,
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Scenarios 3, 4 and 5 London Borough of Lewisham
The following plans should be included in the ES: • The intended uses of the Application Site (e.g. the open spaces, thoroughfares, entrances); • What conditions are being targeted (e.g. open space should be suitable for sitting); and • The mitigation measures relied upon.
Table 13.7. Target Wind Conditions; Section Assessment of Effects, Mitigation and Residual Effects, Operational Phase, Scenarios 3, 4 and 5
London Borough of Lewisham
Any spaces that are proposed as part of the Proposed Development, and that are relied upon by the Applicant to provide amenity, should have wind conditions suitable for this use.
Section Assessment of Effects, Mitigation and Residual Effects, Operational Phase, Scenarios 3, 4 and 5
London Borough of Lewisham
The location of any strong winds should be clearly annotated on a plan, noting that all strong winds are to be mitigated to safe levels.
Section Assessment of Effects, Mitigation and Residual Effects, Operational Phase, Scenarios 3, 4 and 5
London Borough of Lewisham
For on-site locations, where the target comfort criteria are not met, or the safety threshold for strong winds is exceeded, this should be considered an adverse and significant effect and require mitigation;
Section Assessment of Effects, Mitigation and Residual Effects, Operational Phase, Scenarios 3, 4 and 5
London Borough of Lewisham
For off-site locations, where the target comfort criteria are not met, or the safety threshold for strong winds is exceeded, and comparison to the baseline shows that the Proposed Development has caused these unacceptable conditions, this should be considered an adverse and significant effect and require mitigation;
Section Assessment of Effects, Mitigation and Residual Effects, Operational Phase, Scenarios 3, 4 and 5
London Borough of Lewisham
Beneficial effects should not be considered significant, unless they lead to acceptable conditions off-site where conditions were previously not acceptable.
Section Assessment of Effects, Mitigation and Residual Effects, Operational Phase, Scenario 3.
London Borough of Lewisham
The assessment should demonstrate how climate change has been considered within the Wind Microclimate aspect chapter of the ES
Section 13.12
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13.4 Assessment Methodology and Significance Criteria 13.4.1 The following section outlines the methodologies applied to identify and assess the potential impacts and likely effects to result from the Proposed Development. Scope of the Assessment 13.4.2 An EIA Scoping Report was issued to LBL in January 2024 (Appendix 2.1). LBL’s formal Scoping Opinion was issued in June 2024 (Appendix 2.2). 13.4.3 The following potential effects were scoped into the assessment: •
Potential effects to existing pedestrian street-level and open amenity spaces (off-site receptors) at Ground Level.
•
Potential effects to pedestrian street-level and open amenity spaces within the site as part of the Proposed Development.
•
Potential effects to open spaces within the site as part of the Proposed Development.at Elevated Level e.g. balconies, roof terraces and new amenity spaces
•
Potential effects to existing open spaces at Elevated Level e.g. existing balconies and roof terraces.
•
Cumulative effects with future schemes within a 400m distance from the Site including consented and future schemes submitted for planning consent but not yet consented.
•
Mitigation Studies.
Likely Significant Effects Demolition and Construction Phase 13.4.4 The potential effects on wind microclimate at the Site during the demolition and construction stages have not been quantified as part of the assessment as these are expected to continuously vary as demolition and construction progresses. As such the effects during these stages would be temporary. Based on professional experience, it can be qualitatively stated that: •
Given the Site location and the massing of the Proposed Development, the potential effects on the wind microclimate at the Site during demolition and construction would be of lesser significance than those that would be experienced once the development has been completed.
•
Wind microclimate during this transitional stage will progressively vary as demolition and construction progresses, and it is not practical to quantitatively assess. However, it is expected that, given the Site location and the massing of the Proposed Development, the potential effects on the wind microclimate at the Site during demolition and construction would be of lesser significance than those that would be experienced once the development has been completed.
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•
The completed development scenario represents the worst case, and this has been fully quantified as part of the Operational Phase assessment and discussed later in this chapter.
Operational Phase 13.4.5 The wind microclimate around an urban context such as this is affected by terrain, buildings, and other obstructions. The introduction of the development is expected to affect local wind speeds and flow patterns. These changes could produce an uncomfortable or unsafe wind environment at pedestrian level in the absence of carefully controlled building design coupled with mitigation measures. When taller buildings are introduced into an area, effects such as downdrafts accelerating around low-level corners can cause relatively high wind speeds. This study assesses the potential for these effects arising from the Proposed Development, and sets out a framework for appropriate mitigation measures to be developed at Reserved Matters stage. 13.4.6 The study assesses the wind conditions at all outdoor areas on and off-Site with reference to the pedestrian safety and comfort criteria to determine the suitability of the various spaces for the expected uses such as frequent and occasional sitting, standing and walking. 13.4.7 Section 13.9 describes the effects of the Proposed Development on the identified receptors both within and off-Site. Extent of The Study Area 13.4.8 The study area modelled for this analysis includes the Site and the surrounding existing and future properties likely to be affected by the Proposed Development. 13.4.9 The extent of the 3D model for the wind assessment includes the built area within a radius of approximately 400m around the Site. Figure 13.1 shows a view of the wind model and the extent of the study area.
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Figure 13.1: Extent of the wind study area
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Method of Baseline Collection 13.4.10 The Baseline assessment has been conducted to establish the existing wind conditions of the Site and the surrounding study area. This assessment considers any buildings currently under construction within a 400m radius from the centre of the Site as completed structures. 13.4.11 The Baseline assessment serves as a reference condition against which the changes resulting from the Proposed Development are assessed. 13.4.12 Information for defining the Baseline has been sourced from various available resources, including existing drawings, topographic surveys, mapping data, aerial photography, and documents within the Lewisham Planning portal. Method of Assessment Demolition & Construction Phase 13.4.13 The potential effects on wind microclimate at the Site during the demolition and construction stages have not been quantified as part of the assessment. The potential effects on wind microclimate are expected to continuously vary as demolition and construction progresses, therefore all effects during these stages would be temporary. Based on professional experience, it can be qualitatively stated that given the Site location and the massing of the Proposed Development, the potential effects on the wind microclimate at the Site during demolition and construction would be of lesser significance than those that would be experienced once the development has been completed. These have been fully quantified and described in the following sections Operational Phase 13.4.14 The method of assessment for the pedestrian level wind microclimate at the Operational Phase 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 in Appendix 13.1. The assessment considers both the Detailed Element and the Outline Elements of the masterplan which was based on the Maximum Parameters. 13.4.15 The wind microclimate assessment has been undertaken by means of boundary layer wind tunnel testing. A physical model of the Site and surrounding buildings (approximately 400m radius covering existing buildings and consented schemes) has been used for the assessment. The model initially excluded both soft and hard landscaping (trees, street furniture etc.), which is a representation of the worst-case scenario since landscaping would generally improve the wind environment, which is standard practice. However, relevant elements of the landscape, both proposed and existing have been added in subsequent assessments and scenarios, as discussed in Section 13.9.
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Figure 13.2: RWDI Wind tunnel
13.4.16 The wind tunnel testing, carried out in September and October 2024, was aimed at measuring the local fluctuating wind speeds in the vicinity of the Proposed Development at street level and at Elevated Level (e.g., balconies and terraces). This was done for a full range of wind directions (36, in 10deg increments) identifying the suitability of use and pedestrian safety results based on the Lawson Comfort Criteria, both on and off-Site. 13.4.17 The assessment was also supported by a series of preliminary wind studies using Computational Fluid Dynamics (CFD). These preliminary studies provided an overview of the potential effects and the likely location of the impacts and included the exploration of initial mitigation concepts to inform the design during its evolving stages. The CFD model was also used to run a comparative analysis to assess the difference between the Max Parameters model of the outline element and the illustrative masterplan. The CFD analysis is discussed later in this chapter. 13.4.18 The assessment of the wind microclimate impacts, using the wind tunnel, comprises the following scenarios: •
Scenario 1 Existing Baseline: Assessment of the existing buildings on the Site with the existing surrounding context. Includes buildings under construction.
•
Scenario 2 Future Baseline: Assessment of the existing buildings on the Site in combination with future (consented and under consideration) schemes.
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•
Scenario 3 Proposed Scenario (Detailed Element): Assessment of the Detailed elements of the Proposed Development on the Site with the existing surrounding context.
•
Scenario 4 Proposed Scenario (Combined): Assessment of the Proposed Detailed and Outline elements (Max Parameters) of the Proposed Development combined, with existing surroundings.
•
Scenario 5 Cumulative Effects: Assessment of the Proposed Detailed and Outline elements of the Proposed Development (Max Parameters), in combination with future (consented and under consideration) schemes in the surrounding area.
Wind Assessment Criteria 13.4.19 The Lawson criteria has been used in this study and have been reproduced in Tables 13.2 and 13.3. The criteria which are used in assessments of pedestrian wind conditions, relate a threshold wind speed and a threshold frequency to the suitability of an activity. The frequency threshold for each criterion is 5% - (about three weeks per year), i.e. if wind speeds exceed the given threshold for more than 5% of the time, in other words a space does not meet the criteria for at least 95% of the time, it is deemed unsuitable for the given activity. It is also useful to assess the frequency thresholds on a seasonal basis. For example, an outdoor seating area may require wind conditions suitable for sitting or standing in summer, but not in winter when the seating is unlikely to be used. For season-specific results, the criteria are based on 5% of hours across the months in that season.
Table 13.2: Lawson’s Comfort Assessment Criteria Key
Comfort Category
Threshold
Description
Sitting
0-4 m/s
Light breezes desired for outdoor restaurants and seating areas where one can read a paper or comfortably sit for long periods
Standing
4-6 m/s
Gentle breezes acceptable for main building entrances, pick-up/drop-off points and bus stops
Strolling
6-8 m/s
Moderate breezes that would be appropriate for leisure walking along a city/town street, plaza or park
Walking
8-10 m/s
Relatively high speeds that can be tolerated if one’s objective is to walk, run or cycle without lingering
>10 m/s
Winds of this magnitude are considered a nuisance for most activities, and wind mitigation is typically recommended
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Uncomfortable
13.4.20 The Lawson Criteria method also identifies a safety criterion based on 2.2 hours’ exceedance per year. These are areas where someone could find walking difficult or even lose their footing. These criteria are reproduced in Table 13.3 below. Table 13.3: Lawson’s Safety Assessment Criteria Criteria
Threshold
Description
S15
15 m/s
Unsuitable for frail persons, cyclists etc
S20
20 m/s
Threshold not to be exceeded in areas with limited public access, e.g. maintenance areas and carparks.
13.5 Significance Criteria 13.5.1 The assessment of the potential impacts and likely effects as a result of the Proposed Development has taken into account both the Demolition and Construction Phases and Operational phases. The significance level attributed to each effect has been assessed based on the magnitude of change due to the Proposed Development and the sensitivity of the affected receptor/receiving environmental to change, as well as a number of other factors that are outlined in more detail in Chapter 2: Approach to Assessment. 13.5.2 Magnitude of change and the sensitivity of the affected receptor/receiving environmental are both assessed on a scale of high, medium, low and negligible (as shown in Chapter 2: Approach to Assessment). Effect Significance 13.5.3 The following terms have been used as general reference to define the significance of effects identified:
• • • •
Major positive or negative effect – where the Proposed Development would cause a large improvement (or deterioration) to the existing environment; Moderate positive or negative effect – where the Proposed Development would cause a noticeable improvement (or deterioration) to the existing environment; Minor positive or negative effect – where the Proposed Development would cause a small improvement (or deterioration) to the existing environment; and Negligible – no discernible improvement or deterioration to the existing environment as a result of the development will occur.
13.5.4 In addition, a wind-specific significance criteria have been adopted based on the City of London Guidelines, as reproduced below:
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Table 13.4 Effect Significance of On-Site Receptor
Significance
Trigger
Mitigation required?
Major Adverse
Conditions are ‘unsafe’
Yes
Moderate Adverse
Conditions are ‘unsuitable’ (in terms of comfort) for the intended pedestrian use.
Yes
Negligible
Conditions are ‘suitable’ for the intended pedestrian use.
No
Moderate Beneficial
Conditions are calmer than required for the intended pedestrian use (by at least one comfort category).
No
13.5.5 The significance of off-site measurement locations is defined not only by comparing the wind safety or comfort levels with the intended pedestrian activity, but also by comparing the conditions to those experienced prior to the introduction of the Proposed Development (Baseline), using the table below. Table 13.5 Effect Significance of Off-Site Receptor Trigger
Mitigation required?
Conditions that were ‘safe’ in the baseline scenario become ‘unsafe’ as a result of the Proposed Development. OR Conditions that were ‘suitable’ in terms of comfort in the baseline scenario become ‘unsuitable’ as a result of the Proposed Development. OR Conditions that were ‘unsafe’ in the baseline scenario are made worse as a result of the Proposed Development.
Yes
Conditions that were ‘suitable’ in terms of comfort in the baseline scenario are made windier (by at least one comfort category) as a result of the Proposed Development but remain ‘suitable’ for the intended pedestrian activity.
No
Negligible
Conditions remain the same as in the baseline scenario.
No
Major Beneficial
Conditions that were ‘unsafe’ in the baseline scenario become ‘safe’ as a result of the Proposed Development.
No
Significance Major Adverse
Moderate Adverse
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Trigger
Mitigation required?
Conditions that were ‘unsuitable’ in terms of comfort in the baseline scenario become ‘suitable’ as a result of the Proposed Development. OR Conditions that were ‘unsafe’ in the baseline scenario are made better as a result of the Proposed Development (but not so as to make them ‘safe’).
No
Significance Moderate Beneficial
13.6 Baseline Conditions 13.6.1 This section describes the existing baseline conditions of the Site. The Existing Baseline assessment has been carried out as a representation of the existing wind conditions on the Site. The Baseline assumes the existing building configuration i.e., Lewisham Shopping Centre, including the multi-storey carpark, retail units, the leisure box, Lewisham House and several properties on Lewisham High Street. The baseline model of the existing site is set out within the existing surrounding context, including roads, walkways and relevant topography. Buildings under construction within a 400m distance from the Site have been considered as completed and have also been included in the Existing Baseline. 13.6.2 The Baseline assessment has been used as a reference from which the magnitude of change has been derived at each receptor, to quantify the impacts of the Proposed Development for all scenarios assessed. 13.6.3 The assessment of the Existing Baseline has also been used to determine whether any impacts identified in the Proposed Scenario are caused by the Proposed Development or whether these impacts are already present in the Existing Baseline. 13.6.4 The information used to define the Baseline Conditions was collected from a combination of sources including OS maps of the Site and the surrounding area, drawings of recently constructed schemes within the Lewisham Planning Portal and supplemented by photographic/mapping information of the Site. 13.6.5 The assessment of the Baseline Conditions is discussed later in this Chapter and details of the results are presented in RWDI’s Pedestrian Level Wind Microclimate report in Appendix 13.1.
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13.7 Future Baseline 13.7.1 A Future Baseline has been included as part of the scenarios assessed. The Future Baseline consists of a scenario where all the committed developments within the study area are included together with the existing surroundings, without the Proposed Development, i.e., with the existing Lewisham Shopping Centre Site. This scenario is necessary for determining whether any impacts identified in the Proposed scenario are caused by the Proposed Development or whether these impacts are already present in the Future Baseline and caused by buildings other than the Proposed Development. The list of committed developments included in the Future Baseline are provided in Table 13.6 Table 13.6: Committed Developments Scheme
Lewisham Retail Park
Lewisham Market
Description The comprehensive redevelopment of the Lewisham Retail Park and Nos. 66 76 Loampit Vale including the demolition of all buildings on site to facilitate the provision of 4,343sqm of non-residential floorspace comprising (A1) Shops, (A2) Financial & Professional Services, (A3) Restaurants & Cafés, (B1) Business,
Planning Reference
Status
DC/16/097629
Approved: 28th March 2019 Construction status unknown - No precommencement conditions discharged
(D1) Non-Residential Institutions and (D2) Assembly & Leisure uses and 536 residential units in buildings ranging from 4 - 24 storeys in height with private and communal open spaces, on-site energy centre, car and cycle parking, and associated landscaping and public realm works. Development comprising a market house and canopy structure to cover Lewisham Open Market and provide additional civic function together with associated public realm at Lewisham Open Market, Lewisham High Street SE13
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DC/24/136236
Approved 30th July 2024
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13.7.2 The Lewisham Market scheme has been consented recently and whilst it has not been included in the wind model, it can be stated that due to its relative small size and its position on the downwind side of the Site, it is not expected to affect the results. The assessment of the Future Baseline is discussed later in this Chapter and details of the results are presented RWDI’s Pedestrian Level Wind Microclimate report in Appendix 13.1.
13.8 Sensitive Receptors 13.8.1 The sensitivity of receptors considers the activity of pedestrians as this affects their tolerance to wind speeds. For instance, during sedentary activities such as sitting, pedestrians are highly sensitive to variations to wind speeds while pedestrians in more transient activities, such as walking, would tolerate higher wind speeds. In line with these considerations, sensitive receptors for the wind assessment are all pedestrian circulation routes, building entrances and leisure open areas within the Site and in neighbouring adjacent areas. Balconies and roof terraces within the Proposed Development and adjacent properties where occupants are expected to use as outdoor spaces are also considered sensitive receptors. 13.8.2 The sensitive receptors identified for the assessment have been arranged around four categories: •
On-Site and Off-Site Receptors – Ground Level
•
On-Site Receptors – Elevated (Podium) Level
•
On-Site Receptors – Elevated Level (Balconies and Terraces)
•
Off-Site Receptors – Elevated Level (Balconies and Terraces)
13.8.3 The receptors identified for this assessment are shown in Figures 13.3 – 13.6 and are listed in Table 13.4. Figure 13.3 On-Site and Off-Site Receptors – Ground Level – Maximum Parameters for the Outline Elements and Detailed Elements (N1, N2 and 1a Finish Works)
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Figure 13.4 On-Site Receptors – Elevated Level (Podium) Maximum Parameters for the Outline Elements
Figure 13.5 On-Site Receptors – Elevated Level (Balconies) – Detailed Elements N1, N2 and 1a Finish Works Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 13: Wind Microclimate
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Figure 13.6 Off-Site Receptors – Elevated Level
Target Wind Conditions at Receptor Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 13: Wind Microclimate
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13.8.4 The wind conditions for each scenario have been assessed based on the above criteria and considering the season to derive the suitability of each receptor. The assessment followed the general target wind conditions below: •
Outdoor seating areas: ‘Sitting’ during the summer season.
•
Mixed use amenity: ‘Sitting’ or ‘Standing’ during the summer season.
•
Building entrances, bus stops, drop off areas: Sitting’ or ‘Standing’ in windiest season.
•
Pedestrian thoroughfares: ‘Sitting’, ‘Standing’ or ‘Strolling in windiest season
13.8.5 The specific target for each receptor is identified in Table 13.7. Table 13.7: Receptors, Usage and Target Wind Conditions Receptor No
Usage
Target Wind Conditions
1, 2, 10, 17, 18, 77, 84, 112, 113, 145, 177, 181.
Crossing
Sitting, Standing, Strolling or Walking
6, 7, 15, 16, 20, 25, 27, 38, 41, 42, 44, 45, 48, 49, 73, 88, 111, 123, 128, 140, 141, 144, 162, 176, 179, 185.
Road
Sitting, Standing, Strolling or Walking
87, 89, 137, 143, 158, 159, 173 189-207, 209-222, 255.
Bus stop
Sitting or Standing
Podium/terrace level amenity – mixed use
Sitting or Standing
Balconies
Sitting or Standing
223, 224, 228-230, 248-254. 233-247
Roof Terraces
Not accessible
13.9 Assessment of Effects, Mitigation and Residual Effects Demolition & Construction Phase 13.9.1 The potential effects on wind microclimate at the Site during the demolition and construction stages have not been quantified as part of the assessment as these are expected to continuously vary as demolition and construction progresses. As such the effects during these stages would be temporary. Based on professional experience, it can be qualitatively stated that: •
Given the Site location and the massing of the Proposed Development, the potential effects on the wind microclimate at the Site during demolition and construction would
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be of lesser significance than those that would be experienced once the development has been completed. •
Wind microclimate during this transitional stage will progressively vary as demolition and construction progresses, and it is not practical to quantitatively assess. However, it is expected that, given the Site location and the massing of the Proposed Development, the potential effects on the wind microclimate at the Site during demolition and construction would be of lesser significance than those that would be experienced once the development has been completed.
•
The completed development scenario represents the worst case, and this has been fully quantified as part of the Operational Phase assessment and discussed later in this chapter.
Operational Phase 13.9.2 This section identifies and assesses the scale and nature of the main effects arising from the Proposed Development during the operational phase. The study assesses the wind conditions at all outdoor areas both on and off-Site with reference to the pedestrian safety and comfort criteria to determine the suitability of the various spaces for the expected uses such as sitting, standing, strolling and walking. The assessment of effects is discussed for each of the 5 scenarios assessed.
Assessment Results Scenario 1 Existing Baseline - Pedestrian Safety Ground Level 13.9.3 The results of the Existing Baseline safety assessment at Ground Level indicated that the wind environment of the Site and its surroundings is generally within the recommended criteria for safety. This is on the basis that wind speeds do not exceed the upper threshold of 15m/s for more than 2.2 hours, in line with the recommended guidelines. The exception to the above is receptor 37 located at the north of the Site where the safety criteria is exceeded. The results of the pedestrian safety assessment for the Existing Baseline are shown in Figure 13.7. Figure 13.7 Existing Baseline Assessment - Pedestrian Safety Ground Level
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Scenario 1 Existing Baseline - Pedestrian Comfort (Windiest Season) Ground Level 13.9.4 The results of the comfort assessment for the windiest season at Ground Level indicated that the wind environment of the Site and its surroundings is generally within the recommended criteria for the designated uses. 13.9.5 Wind conditions in the existing surroundings are mostly suitable for sitting and standing with some areas suitable for ‘Strolling’, especially to the north of the Site. The results showed that all existing entrances and bus stops have suitable wind conditions for their uses i.e. suitable at most for ‘Standing’. The results at pedestrian walkways and thoroughfares indicated suitability for their usage i.e. suitable at most for ‘Strolling’. The results of the windiest season for the Existing Baseline are shown in Figure 13.8.
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Figure 13.8 Existing Baseline Assessment - Pedestrian Comfort Windiest Season Ground Level
Scenario 1 Existing Baseline - Pedestrian Comfort (Summer Season) 13.9.6 During summer season, wind conditions are calmer mostly showing suitability for ‘Sitting’ and ‘Standing’ and, to a lesser extent, ‘Strolling’ at the north of the Site on Rennell Street. The results of the summer season for the Existing Baseline are shown in Figure 13.9.
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Figure 13.9 Existing Baseline Assessment - Pedestrian Comfort Summer Season Ground Level
Scenario 1 Existing Baseline - Pedestrian Safety Elevated Level 13.9.7 The results of the Existing Baseline safety assessment at Elevated Level indicated that the wind conditions for all existing receptors surrounding the Site are within the pedestrian safety criteria and in line with the guidelines. The results of the Existing Baseline safety assessment at Elevated Level are shown in Figure 13.10.
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Figure 13.10 Existing Baseline Assessment - Pedestrian Safety Elevated Level Off Site
Scenario 1 Existing Baseline - Pedestrian Comfort (Summer Season) Elevated Level 13.9.8 The results of the comfort assessment for the summer season at Elevated Level indicated that the wind conditions are within the required levels in most existing receptors. The exception is at a balcony at high level of The Lewisham Gateway Block D2 (receptor 249), where the wind conditions are suitable for strolling, therefore exceeding by one category the recommended criteria. The results of the Existing Baseline summer comfort assessment at Elevated Level are shown in Figure 13.11.
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Figure 13.11 Existing Baseline Assessment - Pedestrian Summer Comfort Elevated Level Off Site
Scenario 2 Future Baseline - Pedestrian Safety Ground Level 13.9.9 The results of the Future Baseline safety assessment indicated that the wind environment of the Site and its surroundings at Ground Level is broadly similar to the Existing Baseline condition, i.e. mostly in alignment with the guidelines, although with some exceptions. The inclusion of nearby cumulative schemes would make conditions windier to the north of the Site, specifically at crossing locations (receptors 37 and 38) reporting an exceedance of the safety criteria. Even though the consented Lewisham Retail Park is relatively far from the Site, some of the wind reaching this future development, which in its absence would flow relatively unobstructed above the site, would be deflected sideways around the scheme gradually transferring some of this wind onto the surroundings and creating this small difference on the Site. The results of the pedestrian safety assessment for the Existing Baseline are shown in Figure 13.12.
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Figure 13.12 Future Baseline Assessment - Pedestrian Safety Ground Level
Scenario 2 Future Baseline - Pedestrian Comfort Summer Season Ground Level 13.9.10 The results of the Future Baseline comfort assessment for the windiest season at Ground Level indicated that the wind environment of the Site and its surroundings is broadly similar to the Existing Baseline condition. However, the inclusion of nearby cumulative schemes would make conditions windier to the north of the Site, specifically at crossing locations (receptors 37 and 38) reporting ‘walking’ conditions. The results of the pedestrian safety assessment for the Existing Baseline are shown in Figure 13.13.
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Figure 13.13 Future Baseline Assessment - Pedestrian Comfort Windiest Season Ground Level
Scenario 2 Future Baseline Assessment - Pedestrian Comfort Summer Season Ground Level 13.9.11 The results of the Future Baseline comfort assessment for the summer season at Ground Level indicated that the wind environment of the Site and its surroundings is broadly similar to the Existing Baseline condition., i.e. in alignment with the guidelines. All receptors remain within the guidelines and suitable for the current uses. The results of the pedestrian safety assessment for the Future Baseline are shown in Figure 13.14.
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Figure 13.14 Future Baseline Assessment - Pedestrian Comfort Summer Season Ground Level
Scenario 2 Future Baseline - Pedestrian Safety Elevated Level 13.9.12 The results of the Future Baseline safety assessment at Elevated Level indicated that the wind conditions for all existing receptors surrounding the Site are within the pedestrian safety criteria and in line with the guidelines. The results of the Future Baseline safety assessment at Elevated Level are shown in Figure 13.15.
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Figure 13.15 Future Baseline Assessment - Pedestrian Safety Elevated Level Off Site
Scenario 2 Future Baseline - Pedestrian Comfort (Summer Season) Elevated Level 13.9.13 The results of the comfort assessment for the summer season at Elevated Level indicated that the wind conditions in the Future Baseline remain the same as the Existing Baseline, with wind conditions within the required levels in most existing receptors. The exception is at the balcony at high level of The Lewisham Gateway Block D2 (receptor 249), where the wind conditions are suitable for strolling, therefore exceeding by one category the recommended criteria. The results of the Future Baseline summer comfort assessment at Elevated Level are shown in Figure 13.16.
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Figure 13.16 Future Baseline Assessment - Pedestrian Summer Comfort Elevated Level Off Site
Scenario 3 Proposed Scenario (Detailed Element) - Pedestrian Safety Ground Level 13.9.14 This scenario comprises the Detailed Element of the masterplan within the existing surroundings. 13.9.15 The results of the pedestrian safety assessment for Scenario 3 Proposed Scenario (Detailed Element) indicated that the wind environment of the Site and its surroundings is within the recommended criteria for safety. The results indicate that in this scenario there would be no locations with annual strong wind exceedances. This represents an improvement on Scenario 1 Existing Baseline, where safety exceedances are expected at location 37, as discussed in the Existing Baseline section. The results of the pedestrian safety assessment for at Ground Level Scenario 3 are shown in Figure 13.17.
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Figure 13.17 Scenario 3 Proposed Scenario (Detailed Element) - Pedestrian Safety Assessment Ground Level
Scenario 3 Proposed Scenario (Detailed Element) - Pedestrian Comfort Windiest Season Ground Level 13.9.16 The results of the windiest season comfort assessment for Scenario 3 Proposed Scenario (Detailed Element), indicated that the wind environment of the Site and its surroundings is mostly affected on the north side of the Site. The results indicate that the introduction of the Proposed Development (Detailed Element) would result in walking conditions at thoroughfare receptors 9 and 14, one category too windy for the current use and would require mitigation measures. Additionally, wind conditions suitable for ‘strolling’ were identified at the northern entrance of N1 (receptor 32) which would be one category too windy and would require mitigation measures. Mitigation strategies are discussed later in this section. Thoroughfare Receptor 37 increased by one comfort category to ‘walking’ in this scenario, although this is still suitable for the current use. The results of the pedestrian comfort assessment windiest season at Ground Level for Scenario 3 are shown in Figure 13.18.
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Figure 13.18 Scenario 3 Proposed Scenario (Detailed Element) - Pedestrian Comfort Windiest Season Ground Level
Scenario 3 Proposed Scenario (Detailed Element) - Pedestrian Comfort Summer Season Ground Level 13.9.17 The results of the summer season comfort assessment for Scenario 3 Proposed Scenario (Detailed Element), indicated that the wind environment would be suitable for a mixture of ‘sitting’ and ‘standing’ use around the Detailed Element of the Proposed Development, which would be suitable for mixed amenity use. Outdoor seating areas require wind conditions suitable for ‘sitting’, therefore, mitigation measures may be required. Mitigation strategies are discussed later in this section. The results of the pedestrian comfort assessment summer season at Ground Level for Scenario 3 are shown in Figure 13.19.
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Figure 13.19 Scenario 3 Proposed Scenario (Detailed Element) - Pedestrian Comfort Summer Season Ground Level
Scenario 3 Proposed Scenario (Detailed Element) - Pedestrian Safety Elevated Level On Site 13.9.18 The results of the pedestrian safety assessment for Scenario 3 Proposed Scenario (Detailed Element) indicated that the wind environment at Elevated Level at receptors On Site are within the recommended criteria with wind speeds not exceeding the upper threshold of 15m/s for more than 2.2 hours, in line with the recommended guidelines. The results of the pedestrian safety assessment at Elevated Level On Site for Scenario 3, are shown in Figure 13.20.
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Figure 13.20 Scenario 3 Proposed Scenario (Detailed Element) - Pedestrian Safety Elevated Levels On Site
Scenario 3 Proposed Scenario (Detailed Element) - Pedestrian Comfort (Summer Season) Elevated Level On Site 13.9.19 The results of the comfort assessment for the summer season at Elevated Level for receptors On Site indicated that there would mostly be a mixture of sitting and standing use wind conditions at the Elevated Levels of the Detailed Element, suitable for mixed amenity use. Outdoor seating areas should have wind conditions suitable for ‘sitting’ and therefore, mitigation measures may be required. Mitigation strategies are discussed later in this section. Wind conditions suitable for ‘standing’ would be acceptable in private use amenity. The results of the pedestrian summer comfort assessment at Elevated Level On Site for Scenario 3 are shown in Figure 13.21.
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Figure 13.21 Scenario 3 Proposed Scenario (Detailed Element) - Pedestrian Comfort Elevated Levels On Site
Scenario 3 Proposed Scenario (Detailed Element) - Pedestrian Safety Elevated Level Off Site 13.9.20 The results of the pedestrian safety assessment for Scenario 3 Proposed Scenario (Detailed Element) indicated that the wind environment at Elevated Level at receptors off site are within the recommended criteria with wind speeds not exceeding the upper threshold of 15m/s for more than 2.2 hours, in line with the recommended guidelines. The results of the pedestrian safety assessment at Elevated Level Off Site for Scenario 3 are shown in Figure 13.22.
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Figure 13.22 Scenario 3 Proposed Scenario (Detailed Element) - Pedestrian Safety Elevated Levels Off Site
Scenario 3 Proposed Scenario (Detailed Element) - Pedestrian Comfort (Summer Season) Elevated Level Off Site 13.9.21 The results of the comfort assessment for the summer season at Elevated Level for receptors Off Site indicated that the wind conditions in this scenario remain the same as the Existing Baseline, with wind conditions within the required levels in most existing receptors. The exception is at the balcony at high level of The Lewisham Gateway Block D2 (receptor 249), where the wind conditions are suitable for strolling, therefore exceeding by one category the recommended criteria. These conditions would appear in the Existing Baseline, as discussed in Scenario 1 Existing Baseline, therefore no mitigation would be required. The results of the summer comfort assessment at Elevated Level Off Site for Scenario 3 are shown in Figure 13.23.
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Figure 13.23 Scenario 3 Proposed Scenario (Detailed Element) - Pedestrian Comfort (Summer Season) Elevated Level Off Site
First Effect Scenario 3 Proposed Scenario (Detailed Element) Ground Level 13.9.22 At Ground Level the results identified no receptors exceeding the safety criteria, and one location (receptor 37) which does not meet the criteria in the Existing Baseline showed an improvement such that this receptor moves within the recommended safety criteria in this scenario. However, in terms of pedestrian comfort the results indicate that the introduction of the Proposed Development (Detailed Element) would result in walking conditions at thoroughfare receptors 9 and 14, one category too windy for the current use and would require mitigation. Additionally, wind conditions suitable for ‘strolling’ was identified at the northern entrance of N1 (receptor 32) would be one category too windy and would require mitigation. In the absence of mitigation, the effect of Scenario 3 Proposed Scenario (Detailed Element) at Ground Level would be Moderate Negative.
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First Effect Scenario 3 Proposed Scenario (Detailed Element) Elevated Level 13.9.23 The wind assessment at Elevated Level On Site identified wind conditions suitable for ‘sitting’ or ‘standing’ which would be acceptable in private use amenity. Wind Conditions Off Site remained the same as the Existing Baseline, therefore no mitigation would be required. In the absence of mitigation, the effect of Scenario 3 Proposed Scenario (Detailed Element) at Elevated Level would be Negligible. Mitigation Scenario 3 13.9.24 A series of mitigation tests were undertaken in the wind tunnel to address the areas identified to be exceeding the criteria both at ground and Elevated Levels. At Ground Level, the introduction of the landscape consisting of baseline trees in place, including 2 trees to the north of Renell Street included as part of the Lewisham Gateway (now actually planted). The mitigation strategy also includes some of the landscaping at Ground Level associated with Phase 1a in the Northern Square and around Plots N1 and N2. 13.9.25 Additional wind tunnel mitigation tests to improve the conditions around receptors 9 & 14 involved the positioning of additional trees, hedges and screens on the northern side of Renell Street. Low level hedges and planters and positioning of a tree to the west of receptor 14 and to the west of receptor 9, both led to an improvement in the wind conditions to be suitable for ‘strolling’ which is suitable for the current use. This is in alignment with the findings in the Wind Assessment for the Lewisham Gateway Development (Reserved Matters approval for Phase 2 (Blocks C, D1, D2 and E) (ref. DC/18/109819), (Ref 6), where the equivalent location for receptor 9 reported ‘strolling’ conditions which was deemed acceptable and approved by the London Borough of Lewisham. 13.9.26 Landscaping was also introduced at Elevated Levels on Blocks N1 and N2. This resulted in minor variations in the wind conditions with all receptors On Site remaining suitable for ‘sitting’ or ‘standing’ which would be acceptable in private use amenity. 13.9.27 At Elevated Level Off Site, the exceedances identified at the balconies of the Lewisham Gateway were improved resulting in suitable conditions for ‘sitting’ or ‘standing’ which are acceptable wind conditions for the current uses. One of the balconies (receptor 249) that showed suitability for ‘strolling’ in the Existing Baseline i.e. above the acceptable comfort threshold, improved such that it became suitable for ‘sitting’ which is an improvement from the Existing Baseline. Residual Effect 13.9.28 The introduction of mitigation measures would result in a Residual Effect of Negligible Significance at Ground Level and Moderate Positive at Elevated Level.
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Scenario 4: Detailed and Outline Elements 13.9.29 This scenario comprises the Detailed and Outline Elements of the Proposed Development with the existing surroundings. Scenario 4: Detailed and Outline Elements - Pedestrian Safety Ground Level 13.9.30 The results of the pedestrian safety assessment for Scenario 4 Proposed Scenario (Detailed and Outline Elements) indicated that in this scenario there would be several receptors to the north and south of the Site with strong winds in exceedance of the safety criteria. These effects would require mitigation measures. The results of the pedestrian safety assessment for at Ground Level for Scenario 4 are shown in Figure 13.24. Figure 13.24 Scenario 4 Proposed Scenario (Detailed and Outline Elements) - Pedestrian Safety Assessment Ground Level
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Scenario 4 Proposed Scenario (Detailed and Outline Elements) - Pedestrian Comfort Windiest Season Ground Level 13.9.31 The results of the windiest season comfort assessment for Scenario 4 Proposed Scenario (Detailed and Outline Elements), indicated that the introduction of the Outline Elements would make conditions overall windier, particularly to the north and south of the Site. Receptors 8, 9, 14, 40, 43, 46, 47, 108, 148, 152, 168 classified as thoroughfare have been identified to have ‘walking’ conditions which would be one category too windy. Receptors 38 and 169 are identified to have wind conditions rated as ‘uncomfortable’ which would also be too windy for their usage. Additionally, wind conditions suitable for ‘strolling’ were identified at the northern entrance of N1 (receptor 32) which would be one category too windy for an entrance. Furthermore, wind conditions identified as suitable for ‘strolling’ and ‘walking’ around the Outline Elements would be too windy for entrance use. 13.9.32 The receptors identified as exceeding the criteria would require mitigation measures. Mitigation strategies are discussed later in this section. The results of the pedestrian comfort assessment windiest season at Ground Level for Scenario 4 are shown in Figure 13.25. Figure 13.25 Scenario 4 Proposed Scenario (Detailed and Outline Elements) - Pedestrian Comfort Windiest Season Ground Level
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Scenario 4 Proposed Scenario (Detailed and Outline Elements) - Pedestrian Comfort Summer Season Ground Level 13.9.33 The results of the summer season comfort assessment for Scenario 4 Proposed Scenario (Detailed and Outline Elements) at Ground Level, indicated that there would be a number of areas identified as suitable for ‘strolling’ around the Outline Elements of the Proposed Development, which would be one to two categories windier than required at mixed use amenity areas. Therefore, for spaces where pedestrians would be expected to sit or stand, mitigation measures will be required. Mitigation strategies are discussed later in this section. The results of the pedestrian comfort assessment summer season at Ground Level for Scenario 4 are shown in Figure 13.26. Figure 13.26 Scenario 4 Proposed Scenario (Detailed Element) - Pedestrian Comfort Summer Season Ground Level
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Scenario 4 Proposed Scenario (Detailed and Outline Elements) - Pedestrian Safety Elevated (Podium) Level On Site 13.9.34 The results of the pedestrian safety assessment for Scenario 4 Proposed Scenario (Detailed and Outline Element) at Elevated (Podium) Level On Site indicated that the podium level space within the outline element would have seven receptors exceeding the safety criteria for all pedestrians, i.e. the 15m/s strong winds threshold (receptors 194, 195, 198, 202, 204, 208, 222). In addition, one receptor was identified to exceed the 20m/s threshold (receptor 196). Mitigation measures would be required in these areas. Mitigation strategies are discussed later in this section. The results of the pedestrian safety assessment at Elevated (Podium) Level On Site for Scenario 4, are shown in Figure 13.27. Figure 13.27 Scenario 4 Proposed Scenario (Detailed and Outline Elements) - Pedestrian Safety Elevated (Podium) Level On Site
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Scenario 4 Proposed Scenario (Detailed and Outline Element) - Pedestrian Comfort (Summer Season) Elevated (Podium) Level On Site 13.9.35 The results of the comfort assessment for the summer season at elevated (podium) level for receptors On Site indicated that the podium level space within the outline element would have two locations with walking conditions during the summer (locations 194 and 196), and eight locations with strolling conditions (locations 189, 193, 195, 198, 202, 203, 204, 208). These conditions would be too windy for an amenity area. Mitigation measures would be required. Mitigation strategies are discussed later in this section. The results of the pedestrian summer comfort assessment at Elevated (Podium) Level On Site for Scenario 4, are shown in Figure 13.28. Figure 13.28 Scenario 4 Proposed Scenario (Detailed and Outline Element) - Pedestrian Comfort (Summer Season) Elevated Level (Podium) On Site.
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Scenario 4 Proposed Scenario (Detailed and Outline Elements) - Pedestrian Safety Elevated Level On Site 13.9.36 The results of the pedestrian safety assessment for Scenario 4 Proposed Scenario (Detailed and Outline Elements) Elevated Level On Site, indicated that the wind environment at Elevated Level at receptors are within the recommended criteria with wind speeds not exceeding the upper threshold of 15m/s for more than 2.2 hours, in line with the recommended guidelines. The results of the pedestrian safety assessment at Elevated Level On Site for Scenario 4 are shown in Figure 13.29. Figure 13.29 Scenario 4 Proposed Scenario (Detailed and Outline Elements) - Pedestrian Safety Elevated Levels On Site
Scenario 4 Proposed Scenario (Detailed and Outline Elements) - Pedestrian Comfort (Summer Season) Elevated Level On Site 13.9.37 The results of the comfort assessment for the summer season at Elevated Level for receptors On Site indicated that Wind conditions at balconies and terraces within the detailed element would have sitting conditions. These are suitable for the intended uses. The results of the pedestrian summer comfort assessment at Elevated Level On Site for Scenario 4 are shown in Figure 13.30.
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Figure 13.30 Scenario 4 Proposed Scenario (Detailed and Outline Elements) - Pedestrian Comfort Elevated Levels On Site
Scenario 4 Proposed Scenario (Detailed and Outline Elements) - Pedestrian Safety Elevated Level Off Site 13.9.38 The results of the pedestrian safety assessment for Scenario 4 Proposed Scenario (Detailed and Outline Elements) indicated that the wind environment at Elevated Level at receptors off site are within the recommended criteria with wind speeds not exceeding the upper threshold of 15m/s for more than 2.2 hours, in line with the recommended guidelines. The results of the pedestrian safety assessment at Elevated Level Off Site for Scenario 4 are shown in Figure 13.31.
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Figure 13.31 Scenario 4 Proposed Scenario (Detailed and Outline Element) - Pedestrian Safety Elevated Levels Off Site
Scenario 4 Proposed Scenario (Detailed and Outline Elements) - Pedestrian Comfort (Summer Season) Elevated Level Off Site 13.9.39 The results of the comfort assessment for the summer season at Elevated Level for receptors Off Site indicated that the wind conditions in this scenario remain broadly the same as the Existing Baseline. The exception is the elevated terrace at the Lewisham Police Station where the wind conditions in one receptor (253) moved up one category and are suitable for ‘standing’. However, this space remains suitable as a mixed-use amenity area, therefore no mitigation would be required. The results of the summer comfort assessment Elevated Level Off Site for Scenario 4 are shown in Figure 13.32.
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Figure 13.32 Scenario 4 Proposed Scenario (Detailed and Outline Elements) - Pedestrian Comfort (Summer Season) Elevated Level Off Site
First Effect Scenario 4 Proposed Scenario (Detailed and Outline Elements) Ground Level 13.9.40 In this scenario there would be several receptors to the north and south of the Site with strong winds in exceedance of the safety criteria. These effects would require mitigation measures. In the absence of mitigation, the effect of Scenario 4 Proposed Scenario (Detailed and Outline Elements) at Ground Level would be Major Negative. First Effect Scenario 4 Proposed Scenario (Detailed and Outline Element) Elevated (Podium) Level 13.9.41 In this scenario, seven receptors would be exceeding the safety criteria for sensitive pedestrians, i.e. the 15m/s strong winds threshold (receptors 194, 195, 198, 202, 204, 208, 222). In addition, one receptor was identified to exceed the able bodied 20m/s threshold (receptor 196). 13.9.42 The comfort assessment at podium level within the outline element also identified several receptors including two locations with walking conditions during the summer (locations 194 and 196), and eight locations with strolling conditions (locations 189, 193, 195, 198, 202, 203, 204, 208). These conditions would be too windy for an amenity area. Mitigation measures Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 13: Wind Microclimate
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would be required. In the absence of mitigation, the effect of Scenario 4 Proposed Scenario (Detailed and Outline Elements) at Elevated (Podium) Level would be Major Negative. Mitigation Scenario 4 13.9.43 In addition to the proposed landscape at ground and elevated levels, the mitigation elements considered and tested in the wind tunnel are summarised below. Further details and images of the mitigation measures are included in Appendix 13.1. Ground Level Mitigation • • • • • • • • •
• • • • •
Positioning of additional trees, hedges and screens on the northern side of Renell Street. Low level hedges and planters and positioning of a tree to the west of receptor 14 and to the west of receptor 9. Further landscaping at Ground Level associated with Phase 1a in the Northern Square and around Blocks N1 and N2. Nine trees changed from deciduous to evergreen, height remains same as landscaping scheme. Porous 3m deep porous canopy 50% open attached to the north façade of Block N3 Overhanging solid screen attached to the north façade of Block N3 with 3m ground clearance. Introduction of four elevated porous screens 50% open 4m above ground 3m tall, 2m wide, located along the central road space at Rennel Street. Positioning of five additional deciduous trees 8m tall located at the entrance between Blocks N3 and C5 on the northwest of the Site. Replacement of seven deciduous trees to evergreen at the entrance between Blocks S1 and S4 on the southwest of the Site, keeping the height the same as landscaping scheme. Introduction of seven additional evergreen trees at the entrance between Blocks S1 and S4 on the southwest of the Site, keeping the same height as in the landscaping scheme. Elevated Level Mitigation Introduction of porous 50% open 1.6m tall balustrade around elevated terrace at Block S4 on the southwest of the Site. Introduction of porous pergola 50% open 3m tall, 8m long, 5m wide at the elevated open space between Blocks C5 and C4 on the west of the Site. Introduction of four evergreen trees 6m tall at the elevated open space between Blocks C5 and C4 on the west of the Site. Positioning of vertical porous screen 50% open 1.6m tall at terrace edge at the elevated open space between Blocks C5 and C4 on the west of the Site. Addition of three deciduous trees with the same height as nearby proposed trees at the central area of the Podium Park.
Residual Effect 13.9.44 The introduction of the mitigation measures above made a significant improvement to the wind conditions at Ground Level such that out of the 17 receptors that exceeded the safety criteria in the absence of mitigation, 10 receptors satisfied the criteria, and 7 receptors located on the north side of the Site around Rennell Street remain above the threshold. At elevated podium level the introduction of the mitigation measures improved the wind Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 13: Wind Microclimate
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conditions for almost all the receptors with only one receptor (208) located at the elevated podium space between Plots C3 and S2 would remain above the recommended threshold. 13.9.45 The introduction of the mitigation measures for Scenario 4 results in a Residual Effect of Major Negative Significance at Ground Level and Major Negative Significance at Elevated Level. CFD Study 13.9.46 As expected, the windiest conditions are seen when including the Outline Elements which have assessed the Maximum Parameters that represent the tallest and densest massing tested. High-level high-speed winds downwash along the western facades of the masterplan, accelerating around the base of Plots C5 and C4 onto the podium park, and around the north and south corners of N3, causing safety exceedances in these areas. 13.9.47 However, it is important to note that Scenario 4 comprising the Detailed and Outline Elements combined represents an unrealistic worst-case scenario since the individual Plots within the outline element will be developed in detail and the building form and massing will change. It is expected that the developed design for each of the Plots will provide improved wind conditions. This is demonstrated comparatively within the CFD modelling work carried out to support the design along its evolution and to provide an early understanding of the wind implications on the Site. 13.9.48 The CFD study (Appendix 13.2) consisted of computational numerical simulations for a full range of wind directions, with relative wind speeds sampled and combined with longterm historical wind data. The CFD study considered three scenarios: 1) Detailed Plots in Existing: Phase 1a detailed plots N1 & N2 in the context of existing surrounding buildings. This corresponds to the ‘Detailed in Existing’ scenario evaluated in the wind tunnel tests. 2) Illustrative Masterplan: Phase 1a detailed plots N1 & N2 in the context of the illustrative masterplan and existing surrounding buildings. 3) Maximum Parameters: Phase 1a detailed plots N1 & N2 in the context of the Maximum Parameters massing (Outline) and existing surrounding buildings. This corresponds to the ‘Detail and Outline Element’ scenario evaluated in the wind tunnel tests. 13.9.49 Therefore, a comparison can be drawn between Scenario 3 and Scenario 2 in the CFD study to identify the expected improvements caused by the Illustrative Masterplan, which is more likely to represent the likely form of development that will come forward. 13.9.50 As such, Figure 13.33 shows a comparison between the Max Parameters and the Illustrative Masterplan at the winter season. It is evident that the reduced massing of the Illustrative Masterplan which incorporates more detail in the buildings form for each block, results in higher air permeability to the site, especially from the prevailing south-westerly and westerly prevailing winds, slowing wind speeds down. This effect is less apparent in the Max Parameters where a larger proportion of the prevailing south-westerly wind is deflected downwards towards ground level at the north of the site and into the podium levels.
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13.9.51 An additional comparison of the two cases is shown on Figure 13.34 where the area exceeding the safety criteria is substantially reduced, both at ground and podium levels. As discussed above, the Maximum Parameters that represent the tallest and densest massing tested create high-level high-speed winds to downwash along the western facades of the masterplan, accelerating around the base of Plots C5 and C4 onto the podium park, and around the north and south corners of N3, causing safety exceedances in these areas. Some of these exceedances disappear completely and some reduce substantially in size. It is worth adding that this exercise was undertaken in the absence of mitigation aiming to compare the effect of the massing only. 13.9.52 It is important to highlight that the above comparisons illustrate the point that with a carefully developed design, a detailed masterplan design would provide significant improvements to the wind conditions over an unrealistic maximum parameters scenario where buildings are modelled as simple extrusions with no particular design or shape intended. However, it is important to test the maximum parameters to ensure the most robust assessment has been carried out.
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Figure 13.33 Comparative CFD Analysis Detailed Elements and Outline Elements (Max Parameters) vs Illustrative Masterplan
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13.9.53 It is also envisaged that once the detailed design of the various Plots of the Outline Element progress towards detailed planning, there will be further opportunity for the mitigation options described above, to be further developed as part of the reserved matters stages. 13.9.54 The CFD analyses discussed above demonstrates that with a carefully developed design, an Illustrative Masterplan design would provide significant improvements to the wind conditions, allowing a solution to be found during the detailed reserved matters planning stages. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 13: Wind Microclimate
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13.10 Limitations and Assumptions 13.10.1 This ES chapter has been written by WSP using the results of the wind tunnel testing undertaken by RWDI included in Appendix 13.1. 13.10.2 The CFD analyses (Appendix 13.2) 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. However, the CFD study has not been used to determine the significant effects of the Proposed Development, these have been derived from the wind tunnel results.
13.11 Cumulative Effects 13.11.1 This section considers the likely cumulative effects that could arise from the Proposed Development when considered alongside other committed development schemes proximate to the Site. It identifies whether effects from several developments which individually may be insignificant could, when considered together, cause significant cumulative effects requiring mitigation. 13.11.2 A number of committed developments have been identified as being relevant to this assessment. These were identified through a review of LBL’s planning portal and have been agreed with LBL. The assessment is based on the best available information and draws on the assessments included in the ES and Application Reports that accompany the development applications, where available. The list of schemes that are relevant and included in the assessment are included in the Future Baseline section and listed in Table 13.6. Demolition and Construction Phase 13.11.3 The potential effects on wind microclimate at the Site during the demolition and construction stages have not been quantified as part of the assessment as these are expected to continuously vary as demolition and construction progresses. As such the effects during these stages would be temporary. Based on professional experience, it can be qualitatively stated that: •
Given the Site location and the massing of the Proposed Development, the potential effects on the wind microclimate at the Site during demolition and construction would be of lesser significance than those that would be experienced once the development has been completed.
•
Wind microclimate during this transitional stage will progressively vary as demolition and construction progresses, and it is not practical to quantitatively assess. However, it is expected that, given the Site location and the massing of the Proposed Development, the potential effects on the wind microclimate at the Site during demolition and construction would be of lesser significance than those that would be experienced once the development has been completed.
•
The completed development scenario represents the worst case, and this has been fully quantified as part of the Operational Phase assessment.
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Operational Phase Scenario 5 Cumulative Effects: Detailed and Outline Elements of the Proposed Development in combination with future (consented) schemes in the surrounding area Assessment Results Scenario 5: Detailed and Outline Elements + Cumulative Developments - Pedestrian Safety Ground Level 13.11.4 The results of the pedestrian safety assessment for Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) indicated that in this scenario there would be several receptors to the north and south of the Site with strong winds in exceedance of the safety criteria. These effects would require mitigation measures. The results of the pedestrian safety assessment at Ground Level for Scenario 5 are shown in Figure 13.34. Figure 13.34 Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) - Pedestrian Safety Assessment Ground Level
Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) - Pedestrian Comfort Windiest Season Ground Level
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13.11.5 The results of the windiest season comfort assessment for Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments), indicated that the introduction of the Outline Elements would make conditions overall windier, particularly to the north and south of the Site. Receptors 8, 9, 14, 40, 43, 46, 47, 108, 148, 168 classified as thoroughfare have been identified to have ‘walking’ conditions which would be one category too windy. Receptor 38 is identified to have wind conditions rated as ‘uncomfortable’ which would also be too windy for its usage. Additionally, wind conditions suitable for ‘strolling’ were identified at the northern entrance of N1 (receptor 32) which would be one category too windy for an entrance. Furthermore, wind conditions identified as suitable for ‘strolling’ and ‘walking’ around the Outline Elements would be too windy for entrance use. The receptors identified as exceeding the criteria would require mitigation measures. Mitigation strategies are discussed later in this section. The results of the pedestrian comfort assessment windiest season at Ground Level for Scenario 5 are shown in Figure 13.35. Figure 13.35 Scenario 4 Proposed Scenario (Detailed and Outline Elements) - Pedestrian Comfort Windiest Season Ground Level
Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) - Pedestrian Comfort Summer Season Ground Level
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13.11.6 The results of the summer season comfort assessment for Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) at Ground Level, indicated that there would be a number of areas identified as suitable for ‘strolling’ around the Outline Elements of the Proposed Development, which would be one to two categories windier than required at mixed use amenity areas. Therefore, for spaces where pedestrians would be expected to sit or stand, mitigation measures will be required. Mitigation strategies are discussed later in this section. The results of the pedestrian comfort assessment summer season at Ground Level for Scenario 5 are shown in Figure 13.36. Figure 13.36 Scenario 5 Proposed Scenario (Detailed Element + Cumulative Developments) Pedestrian Comfort Summer Season Ground Level
Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) - Pedestrian Safety Elevated (Podium) Level On Site
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13.11.7 The results of the pedestrian safety assessment for Scenario 5 Proposed Scenario (Detailed and Outline Element + Cumulative Developments) at Elevated (Podium) Level On Site indicated that the podium level space within the outline element would have seven receptors exceeding the safety criteria for all pedestrians, i.e. the 15m/s strong winds threshold (receptors 194, 195, 198, 202, 204, 208, 222). In addition, one receptor was identified to exceed the 20m/s threshold (receptor 196). Mitigation measures would be required in these areas. Mitigation strategies are discussed later in this section. The results of the pedestrian safety assessment at Elevated (Podium) Level On Site for Scenario 5 Elevated (Podium) Level On Site, are shown in Figure 13.37. Figure 13.37 Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) - Pedestrian Safety Elevated (Podium) Level On Site
Scenario 5 Proposed Scenario (Detailed and Outline Element + Cumulative Developments) - Pedestrian Comfort (Summer Season) Elevated Level (Podium) On Site
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13.11.8 The results of the comfort assessment for the summer season at elevated (podium) level for receptors On Site indicated that the podium level space within the outline element would have two locations with walking conditions during the summer (locations 194 and 196), and eight locations with strolling conditions (locations 189, 193, 195, 198, 202, 203, 204, 208). These conditions would be too windy for an amenity area. Mitigation measures would be required. Mitigation strategies are discussed later in this section. The results of the pedestrian summer comfort assessment at Elevated (Podium) Level On Site for Scenario 5 are shown in Figure 13.38. Figure 13.38 Scenario 5 Proposed Scenario (Detailed and Outline Element + Cumulative Developments) - Pedestrian Comfort (Summer Season) Elevated Level (Podium) On Site.
Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) - Pedestrian Safety Elevated Level On Site 13.11.9 The results of the pedestrian safety assessment for Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) Elevated Level On Site, indicated that the wind environment at Elevated Level at receptors are within the recommended criteria with wind speeds not exceeding the upper threshold of 15m/s for more than 2.2 hours, in line with the recommended guidelines. The results of the pedestrian safety assessment Elevated Level On Site for Scenario 5 are shown in Figure 13.39.
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Figure 13.39 Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) - Pedestrian Safety Elevated Levels On Site
Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) - Pedestrian Comfort (Summer Season) Elevated Level On Site 13.11.10 The results of the comfort assessment for the summer season at Elevated Level for receptors On Site indicated that Wind conditions at balconies and terraces within the detailed element would have sitting conditions. These are suitable for the intended uses. The results of the pedestrian summer comfort assessment at Elevated Level On Site for Scenario 5, are shown in Figure 13.40.
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Figure 13.40 Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) - Pedestrian Comfort Elevated Levels On Site
Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) - Pedestrian Safety Elevated Level Off Site 13.11.11 The results of the pedestrian safety assessment for Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) indicated that the wind environment at Elevated Level at receptors Off Site are within the recommended criteria with wind speeds not exceeding the upper threshold of 15m/s for more than 2.2 hours, in line with the recommended guidelines. The results of the pedestrian safety assessment at Elevated Level Off Site for Scenario 5 are shown in Figure 13.41.
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Figure 13.41 Scenario 5 Proposed Scenario (Detailed and Outline Element + Cumulative Developments) - Pedestrian Safety Elevated Levels Off Site
Scenario 5 Proposed Scenario (Detailed and Outline Elements Element + Cumulative Developments) - Pedestrian Comfort (Summer Season) Elevated Level Off Site 13.11.12 The results of the comfort assessment for the summer season at Elevated Level for receptors Off Site indicated that the wind conditions in this scenario remain broadly the same as the Existing Baseline. The exception is the elevated terrace at the Lewisham Police Station, where the wind conditions in one receptor (253) moved up one category and are suitable for ‘standing’. However, this space remains suitable as a mixed-use amenity area, therefore no mitigation would be required. The results of the summer comfort assessment at Elevated Level Off Site for Scenario 5 are shown in Figure 13.42.
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Figure 13.42 Scenario 5 Proposed Scenario (Detailed and Outline Elements Element + Cumulative Developments) - Pedestrian Comfort (Summer Season) Elevated Level Off Site
First Effect Scenario 5 Proposed Scenario (Detailed and Outline Elements + Cumulative Developments) Ground Level 13.11.1 In this scenario there would be several receptors to the north and south of the Site with strong winds in exceedance of the safety criteria. These effects would require mitigation measures. In the absence of mitigation, the effect of Scenario 5 Proposed Scenario (Detailed and Outline Elements) at Ground Level would be Major Negative. First Effect Scenario 5 Proposed Scenario (Detailed and Outline Element Elements + Cumulative Developments) Elevated (Podium) Level 13.11.2 In this scenario, seven receptors would be exceeding the safety criteria for sensitive pedestrians, i.e. the 15m/s strong winds threshold (receptors 194, 195, 198, 202, 204, 208, 222). In addition, one receptor was identified to exceed the able bodied 20m/s threshold (receptor 196). 13.11.3 The comfort assessment at podium level within the outline element also identified several receptors including two locations with walking conditions during the summer (locations 194 and 196), and eight locations with strolling conditions (locations 189, 193, 195, 198, 202, Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 13: Wind Microclimate
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203, 204, 208). These conditions would be too windy for an amenity area. Mitigation measures would be required. In the absence of mitigation, the effect of Scenario 4 Proposed Scenario (Detailed and Outline Elements) at Elevated (Podium) Level would be Major Negative. Mitigation Scenario 5 13.11.4 In addition to the proposed landscape at ground an elevated, the mitigation elements considered and tested are summarised below. Further details and images of the mitigation measures are included in Appendix 13.1. • • • • • • • • • •
• • • • •
Ground Level Mitigation Positioning of additional trees, hedges and screens on the northern side of Renell Street. Low level hedges and planters and positioning of a tree to the west of receptor 14 and to the west of receptor 9. Further landscaping at Ground Level associated with Phase 1a in the Northern Square and around Blocks N1 and N2. Nine trees changed from deciduous to evergreen, height remains same as landscaping scheme. Porous 3m deep porous canopy 50% open attached to the north façade of Block N3 Overhanging solid screen attached to the north façade of Block N3 with 3m ground clearance. Inclusion of three pillars 0.75m wide and long on the north façade of Block N3. Introduction of four elevated porous screens 50% open 4m above ground 3m tall, 2m wide, located along the central road space at Rennel Street. Positioning of five additional deciduous trees 8m tall located at the entrance between Blocks N3 and C5 on the northwest of the Site. Replacement of seven deciduous trees to evergreen at the entrance between Blocks S1 and S4 on the southwest of the Site, keeping the height the same as landscaping scheme. Introduction of seven additional evergreen trees at the entrance between Blocks S1 and S4 on the southwest of the Site, keeping the same height as in the landscaping scheme. Elevated Level Mitigation Introduction of porous 50% open 1.6m tall balustrade around elevated terrace at Block S4 on the southwest of the Site. Introduction of porous pergola 50% open 3m tall, 8m long, 5m wide at the elevated open space between Blocks C5 and C4 on the west of the Site. Introduction of four evergreen trees 6m tall at the elevated open space between Blocks C5 and C4 on the west of the Site. Positioning of vertical porous screen 50% open 1.6m tall at terrace edge at the elevated open space between Blocks C5 and C4 on the west of the Site. Addition of three deciduous trees with the same height as nearby proposed trees at the central area of the Podium Park.
Residual Effect 13.11.5 The introduction of the mitigation measures made a significant improvement to the wind conditions at Ground Level such that out of the 17 receptors that exceeded the safety criteria in the absence of mitigation, 10 receptors satisfied the criteria, and 7 receptors located on the north side of the Site around Rennell Street remain above the threshold. At elevated Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 13: Wind Microclimate
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podium level the introduction of the mitigation measures improved the wind conditions for almost all the receptors with only one receptor (208) located at the elevated podium space between Blocks C3 and S2 would remain above the recommended threshold. 13.11.6 The introduction of the mitigation measures for Scenario 4 results in a Residual Effect of Major Negative Significance at Ground Level and Major Negative Significance at Elevated Level. 13.11.7 As expected, the windiest conditions are seen when including the Outline Elements which use the Maximum Parameters that represent the tallest and densest massing tested. High-level high-speed winds downwash along the western facades of the masterplan, accelerating around the base of Plots C5 and C4 onto the podium park, and around the north and south corners of N3, causing safety exceedances in these areas. 13.11.8 However, it is important to note that Scenario 4 comprising the Detailed and Outline Elements combined represents an unrealistic scenario since the individual Plots within the outline element will be developed in detail and the building form and massing will change. It is expected that the developed design for each of the Plots will provide improved wind conditions. This is demonstrated comparatively within the CFD modelling work discussed in Scenario 4. 13.11.9 The CFD studies compares the wind effects between the Max Parameters and the Illustrative Masterplan. It is evident that the reduced massing of the Illustrative Masterplan which incorporates more detail in the buildings form for each block, results in higher air permeability to the site, especially from the prevailing south-westerly and westerly prevailing winds, slowing wind speeds down. This effect is less apparent in the Max Parameters where a larger proportion of the prevailing south-westerly wind is deflected downwards towards ground level at the north of the site and into the podium levels. 13.11.10 As discussed above, the Maximum Parameters that represent the tallest and densest massing tested create high-level high-speed winds to downwash along the western facades of the masterplan, accelerating around the base of Plots C5 and C4 onto the podium park, and around the north and south corners of N3, causing safety exceedances in these areas. Some of these exceedances disappear completely and some reduce substantially in size. It is worth adding that this exercise was undertaken in the absence of mitigation aiming to compare the effect of the massing only. 13.11.11 It is important to highlight that the above comparisons illustrate the point that with a carefully developed design, an illustrative masterplan design would provide significant improvements to the wind conditions over an unrealistic maximum parameters scenario where buildings are modelled as simple extrusions with no particular design or shape intended. 13.11.12 It is also envisaged that once the detailed design of the various Plots of the Outline Element progress towards detailed planning, there will be further opportunity for the mitigation options described above, to be further developed as part of the reserved matters stages.
13.12 Impact on Climate Change 13.12.1 "Wind projections for the UK are published by the Met Office as part of the UKCP18 Factsheet: Wind. This indicates that “there are no compelling trends in storminess as determined by the gust wind speeds, from the UK wind network over the last four decades." Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 13: Wind Microclimate
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It goes on to summarise the projections for UK winds over the coming century, indicating little to no change in the mean wind speeds, with any change being "modest compared to interannual variability". Considering these predictions, we would conclude that the current trends in the wind climate are not likely to significantly affect the assessment of wind microclimate for the Proposed Development.
13.13 Summary 13.13.1 This Chapter reports the likely significant effects of the Proposed Development on the Site and the surrounding area in terms of Wind Microclimate matters. Where appropriate, it also identifies proposed mitigation measures to prevent, minimise or control likely negative effects arising from the Proposed Development and the subsequent anticipated residual effects. 13.13.2 The method of assessment for the pedestrian level wind microclimate at the Operational Phase 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 in Appendix 13.1. In addition a CFD analyses (Appendix 13.2) 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. Assessment Results – Scenario 1 Existing Baseline Scenario 1 Existing Baseline 13.13.3 The results of the Existing Baseline safety assessment at Ground Level indicated that the wind environment of the Site and its surroundings is generally within the recommended criteria for safety. This is on the basis that wind speeds do not exceed the upper threshold of 15m/s for more than 2.2 hours, in line with the recommended guidelines. The exception to the above is receptor 37 located at the north of the Site where the safety criteria is exceeded. 13.13.4 The results of the comfort assessment for the windiest season at Ground Level indicated that the wind environment of the Site and its surroundings is generally within the recommended criteria for the designated uses. 13.13.5 The results of the Existing Baseline safety assessment at Elevated Level indicated that the wind conditions for all existing receptors surrounding the Site are within the pedestrian safety criteria and in line with the guidelines. 13.13.6 The results of the comfort assessment for the summer season at Elevated Level indicated that the wind conditions are within the required levels in most existing receptors. The exception is at a balcony at high level of The Lewisham Gateway Block D2 (receptor 249), where the wind conditions are suitable for strolling, therefore exceeding by one category the recommended criteria. Scenario 2 Future Baseline 13.13.7 The results of the Future Baseline safety assessment at Ground Level indicated that the wind environment of the Site and its surroundings is broadly similar to the Existing Baseline condition, i.e. mostly in alignment with the guidelines, although with some exceptions. The inclusion of nearby cumulative schemes would make wind conditions windier Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 13: Wind Microclimate
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to the north of the Site, with walking conditions identified at two crossing locations (receptors 37 and 38). 13.13.8 The results of the Future Baseline comfort assessment for the windiest season at Ground Level indicated that the wind environment of the Site and its surroundings is broadly similar to the Existing Baseline condition, i.e. in alignment with the guidelines, although with localised increased wind effects. The inclusion of nearby cumulative schemes would make wind conditions slightly windier to the north of the Site, with walking conditions identified at two crossing locations (receptors 37 and 38). These are thoroughfare locations, therefore remaining within the guidelines. 13.13.9 The results of the Future Baseline comfort assessment for the summer season at Ground Level indicated that the wind environment of the Site and its surroundings is broadly similar to the Existing Baseline condition, i.e. in alignment with the guidelines. All receptors remain within the guidelines and suitable for the current uses. 13.13.10 The results of the Future Baseline safety assessment at Elevated Level indicated that the wind conditions for all existing receptors surrounding the Site are within the pedestrian safety criteria and in line with the guidelines. 13.13.11 The results of the comfort assessment for the summer season at Elevated Level indicated that the wind conditions in the Future Baseline remain the same as the Existing Baseline, with wind conditions within the required levels in most existing receptors. The exception is at the balcony at high level of The Lewisham Gateway Block D2 (receptor 249), where the wind conditions are suitable for strolling, therefore exceeding by one category the recommended criteria. Scenario 3 Proposed Scenario (Detailed Element) First Effect Scenario 3 Ground Level 13.13.12 At Ground Level the results identified no receptors exceeding the safety criteria, and one location (receptor 37) which does not meet the criteria in the Existing Baseline showed an improvement such that this receptor moves within the recommended safety criteria in this scenario. However, in terms of pedestrian comfort the results indicate that the introduction of the Proposed Development (Detailed Element) would result in walking conditions at thoroughfare receptors 9 and 14, one category too windy for the current use and would require mitigation. Additionally, wind conditions suitable for ‘strolling’ was identified at the northern entrance of N1 (receptor 32) would be one category too windy and would require mitigation. In the absence of mitigation, the effect of Scenario 3 Proposed Scenario (Detailed Element) at Ground Level would be Moderate Negative. First Effect Scenario 3 Elevated Level 13.13.13 The wind assessment at Elevated Level On Site identified wind conditions suitable for ‘sitting’ or ‘standing’ which would be acceptable in private use amenity. Wind Conditions Off Site remained the same as the Existing Baseline, therefore no mitigation would be required. In the absence of mitigation, the effect of Scenario 3 Proposed Scenario (Detailed Element) at Elevated Level would be Negligible.
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Mitigation (Scenario 3) 13.13.14 A series of mitigation tests were undertaken to address the areas identified to be exceeding the criteria both at ground and Elevated Levels On Site and Off Site. The mitigation options assessed include the landscape scheme, additional trees and low-level planting. The mitigation assessments are discussed in detail in this chapter and are also included in Appendix 13.1. Residual Effect Scenario 3 13.13.15 The introduction of mitigation measures would result in a Residual Effect of Negligible Significance at Ground Level and Moderate Positive at Elevated Level. Scenario 4: Detailed and Outline Elements 13.13.16 This scenario comprises the Detailed and Outline Elements of the Proposed Development with the existing surroundings. Scenario 4: Detailed and Outline Elements - Pedestrian Safety Ground Level 13.6.9 First Effect Scenario 4 13.13.17 In this scenario there would be several receptors at Ground Level to the north and south of the Site with strong winds in exceedance of the safety criteria. These effects would require mitigation measures. In the absence of mitigation, the effect of Scenario 4 Proposed Scenario (Detailed and Outline Elements) at Ground Level would be Major Negative. 13.13.18 At podium level, seven receptors would be exceeding the safety criteria for sensitive pedestrians, i.e. the 15m/s strong winds threshold (receptors 194, 195, 198, 202, 204, 208, 222). In addition, one receptor was identified to exceed the able bodied 20m/s threshold (receptor 196). 13.13.19 The comfort assessment at podium level within the outline element also identified several receptors including two locations with walking conditions during the summer (locations 194 and 196), and eight locations with strolling conditions (locations 189, 193, 195, 198, 202, 203, 204, 208). These conditions would be too windy for an amenity area. Mitigation measures would be required. In the absence of mitigation, the effect of Scenario 4 Proposed Scenario (Detailed and Outline Elements) at Elevated (Podium) Level would be Major Negative. Mitigation (Scenario 4) 13.13.20 A series of mitigation tests were undertaken to address the areas identified to be exceeding the criteria both at ground and Elevated Levels On Site and Off Site. The mitigation options assessed include the landscape scheme, additional trees, low-level planting and porous wind deflecting elements. The mitigation assessments are discussed in detail in this chapter and are also included in Appendix 13.1. Residual Effect Scenario 4 13.13.21 The introduction of the mitigation measures made a significant improvement to the wind conditions at Ground Level such that out of the 17 receptors that exceeded the safety criteria in the absence of mitigation, 10 receptors satisfied the criteria, and 7 receptors located on the north side of the Site around Rennell Street remain above the threshold. At elevated Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 13: Wind Microclimate
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podium level the introduction of the mitigation measures improved the wind conditions for almost all the receptors with only one receptor (208) located at the elevated podium space between Blocks C3 and S2 would remain above the recommended threshold. 13.13.22 The introduction of the mitigation measures for Scenario 4 results in a Residual Effect of Major Negative Significance at Ground Level and Major Negative Significance at Elevated Level. 13.13.23 As expected, the windiest conditions are seen when including the Outline Elements which use the Maximum Parameters that represent the tallest and densest massing tested. High-level high-speed winds downwash along the western facades of the masterplan, accelerating around the base of Plots C5 and C4 onto the podium park, and around the north and south corners of Lewisham House, causing safety exceedances in these areas. 13.13.24 However, it is important to note that Scenario 4 comprising the Detailed and Outline Elements combined represents an unrealistic scenario since the individual Blocks within the outline element will be developed in detail and the building form and massing will change. It is expected that the developed design for each of the blocks will provide improved wind conditions. This is demonstrated comparatively within the CFD modelling work carried out to support the design along its evolution and to provide an early understanding of the wind implications on the Site. 13.13.25 It is also envisaged that once the detailed design of the various blocks progresses towards detail planning, there will be further opportunity for the mitigation options described above, to be further developed as part of the RMA stages. 13.13.26
Cumulative Effects (Scenario 5)
13.13.27 This section considers the likely cumulative effects that could arise from the Proposed Development when considered alongside other committed development schemes proximate to the Site. It identifies whether effects from several developments which individually may be insignificant could, when considered together, cause significant cumulative effects requiring mitigation. 13.13.28 The results in this scenario are almost identical to Scenario 4 with exactly the same residual effects. This is due to the fact that the only committed scheme (Lewisham Retail Park) which had not been built at the time of producing this ES Chapter, is in a location with no significant influence on the wind conditions at the Site. 13.13.29 However, it is important to note that, like Scenario 4, Scenario 5 comprising the Detailed and Outline Elements + Cumulative Developments represents an unrealistic scenario since the individual Blocks within the outline element will be developed in detail and the building form and massing will change. 13.13.30 As indicated for Scenario 4, it is expected that the developed design for each of the blocks will provide improved wind conditions. This is demonstrated comparatively within the CFD modelling work carried out to support the design along its evolution and to provide an early understanding of the wind implications on the Site. 13.13.31 It is also envisaged that once the detailed design of the various blocks progresses towards detail planning, there will be further opportunity for the mitigation options described Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 13: Wind Microclimate
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above, to be further developed as part of the RMA stages.
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Table 13.8: Summary of Effects DESCRIPTION RECEPTOR SIGNIFICANCE OF EFFECTS OF SIGNIFICANT MAJOR / POSITIV P / D / I ST / EFFECTS MODERAT E / T MT / E / MINOR / NEGATIV LT NEGLIGIBL E E Demolition & Construction n/a n/a n/a n/a n/a n/a n/a Operation Scenario 3 Detailed Element
SUMMARY OF MITIGATION / ENHANCEMENT MEASURES
SIGNIFICANCE OF RESIDUAL RELEVANT RELEVANT EFFECTS POLICY LEGISLATIO N MAJOR / POSITIV P / D / I ST / MODERATE E / T MT / / MINOR / NEGATIV LT NEGLIGIBLE E
n/a
n/a
n/a
n/a n/a n/a
Pedestrian Safety Pedestrian Safety
n/a
n/a
P
D
LT
n/a
Moderate
Positive
P
D
LT
n/a
n/a
P
D
LT
n/a
Negligible
n/a
P
D
LT
n/a
n/a
P
D
LT
n/a
Negligible
n/a
P
D
LT
n/a
Negative P
D
LT
Negligible
n/a
P
D
LT
n/a
Receptors Moderate Negative P Elevated Level On Site Pedestrian Receptors Negligible n/a P Comfort Elevated Level Off Site Scenario 4 Detailed and Outline Elements Pedestrian Receptors Major Negative P Safety Ground Level
D
LT
Negligible
n/a
P
D
LT
n/a
D
LT
Landscape, additional trees and low-level planting. Landscape, additional trees and low-level planting. n/a
Negligible
n/a
P
D
LT
n/a
D
LT
Landscape, additional trees and low-level planting, porous wind
Major
Negative P
D
LT
n/a
Pedestrian Safety Pedestrian Comfort
Receptors Negligible Ground Level Receptors Negligible Elevated (Balcony) Level On Site Receptors Negligible Elevated Level Off Site Receptors Moderate Ground Level
n/a
Pedestrian Comfort
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Pedestrian Safety
Receptors Negligible Elevated (Balcony)) Level On Site Receptors Major Elevated (Podium)) Level On Site Receptors Negligible Elevated Level Off Site
n/a
Pedestrian Comfort
Pedestrian Comfort
Pedestrian Safety
Pedestrian Safety
Pedestrian Comfort
Pedestrian Comfort
P
D
LT
Negative P
D
LT
n/a
P
D
LT
Receptors Major Ground Level
Negative P
D
LT
Receptors Negligible Elevated (Balcony) Level On Site Receptors Moderate Elevated (Podium) Level On Site Receptors Negligible Elevated Level Off Site
n/a
P
D
LT
Negative P
D
LT
n/a
D
LT
P
deflecting elements. n/a.
Negligible
n/a
P
D
LT
n/a
Landscape, additional trees and low-level planting, porous wind deflecting elements. Landscape, additional trees and low-level planting, porous wind deflecting elements. Landscape, additional trees and low-level planting, porous wind deflecting elements. n/a
Major
Negative P
D
LT
n/a
Negligible
n/a
P
D
LT
n/a
Major
Negative P
D
LT
n/a
Negligible
n/a
P
D
LT
n/a
Landscape, additional trees and low-level planting, porous wind deflecting elements. Landscape, additional trees and low-level planting, porous wind deflecting elements.
Moderate
Negative P
D
LT
n/a
Negligible
n/a
D
LT
n/a
D
LT
n/a
D
LT
n/a
P
Scenario 5 Detailed and Outline Elements + Cumulative Developments Pedestrian Receptors Major Negative P D LT Landscape, additional Major Negative P Safety Ground Level trees and low-level planting, porous wind deflecting elements. Pedestrian Receptors Negligible n/a P D LT n/a. Negligible n/a P Safety Elevated (Balcony)) Level On Site Lewisham Shopping Centre Plowman Craven Volume 1: Environmental Statement – Main Text 46730 Chapter 13: Wind Microclimate October 2024
Pedestrian Safety
Receptors Major Elevated (Podium)) Level On Site Receptors Negligible Elevated Level Off Site
Negative P
D
LT
n/a
P
D
LT
Pedestrian Comfort
Receptors Major Ground Level
Negative P
D
LT
Pedestrian Comfort
Receptors Negligible Elevated (Balcony) Level On Site Receptors Moderate Elevated (Podium) Level On Site Receptors Negligible Elevated Level Off Site
n/a
P
D
LT
Negative P
D
LT
n/a
D
LT
Pedestrian Safety
Pedestrian Comfort
Pedestrian Comfort
P
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Landscape, additional trees and low-level planting, porous wind deflecting elements. Landscape, additional trees and low-level planting, porous wind deflecting elements. Landscape, additional trees and low-level planting, porous wind deflecting elements. n/a
Major
Negative P
D
LT
n/a
Negligible
n/a
P
D
LT
n/a
Major
Negative P
D
LT
n/a
Negligible
n/a
P
D
LT
n/a
Landscape, additional trees and low-level planting, porous wind deflecting elements. Landscape, additional trees and low-level planting, porous wind deflecting elements.
Moderate
Negative P
D
LT
n/a
Negligible
n/a
D
LT
n/a
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P
14.0 References Ref. 1 Lawson, T., 2001 Building Aerodynamics, Imperial College Press [ISBN 1-86094-187-7] Ref. 2. Department of Communities and Local Government (July 2021) The National Planning Policy Framework. Ref. 3 Ministry of Housing, Communities and Local Government, National Planning Policy Guidance (NPPG). Ref 4 Mayor of London, 2021, The London Plan “The spatial development strategy for Greater London” Ref.5 Lewisham Local Plan: Proposed Submission Document, Regulation 19 Stage (January 2023). Ref. 6 Department of the Built Environment, 2021, City of London Local Plan City Plan 2036 Proposed Submission Draft Topic Paper 3 – TALL BUILDINGS AND PROTECTED VIEWS. Ref. 7 City of London Wind Microclimate Guidelines (CoL). Ref. 8 Historic England (2015) Historic England Advice Note 4, Tall Buildings. Ref. 9. Wind projections for the UK published by the Met Office as part of the UKCP18 Factsheet
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14.0 Ecology 14.1 Introduction 14.1.1 This Chapter reports the likely significant effects of the Proposed Development on the Site and the surrounding area in terms of ecological matters. Where appropriate, it also identifies proposed mitigation measures to avoid, minimise or compensate for any likely significant negative effects arising from the Proposed Development and the subsequent anticipated residual effects. 14.1.2 The effects of the Proposed Development are considered over both the demolition and construction and operational phases. 14.1.3 The main ecological effects covered in this Chapter include the following: • • •
The temporary loss of a peregrine falcon nesting site; The permanent loss of breeding habitat for black redstart; and The possible loss of and disturbance to active nests in the absence of mitigation.
14.1.4 This Chapter (and its associated figures and appendices) should be read together with the Introductory Chapters of this ES (Chapters 1 – 5), as well as Chapter 17: Effect Interactions. 14.1.5 This Chapter is accompanied by the following Appendices: • • • •
Preliminary Ecology Appraisal (Appendix 14.1); Bat Survey (Appendix 14.2); Peregrine Falcon Survey (Appendix 14.3); and Biodiversity Gain Plan (Appendix 14.4).
14.2 Competence 14.2.1 This assessment has been undertaken by Principal Ecologist Luke Verrall BSc (Hons). Luke is a Full member of the Chartered Institute of Ecology and Environmental Management (CIEEM) with over twelve-years’ experience within ecological consultancy. During this time, he has undertaken a wide variety of ecological surveys and assessments, including contributions to ecology chapters of environmental statements. He has also undertaken in-depth review and scrutiny of ES chapters when producing ecological design for an NSIP project.
14.3 Legislation, Planning Policy and Guidance Legislation 14.3.1 The following key pieces of nature conservation legislation are relevant to this assessment:
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The Conservation of Habitats and Species Regulations 2017 (as amended) (commonly referred to as the Habitats Regulations) 14.3.2 The Conservation of Habitats and Species Regulations 2017 (as amended by the Conservation of Habitats and Species (amendment) (EU Exit) Regulations 2019) implements the Bern Convention, the Birds Directive and the Council Directive on the Conservation of Natural Habitats and Wild Fauna and flora (92/43/EEC, the Habitats Directive) in England and Wales. It is important to note that the amending regulations generally seek to retain the requirements of the 2017 Regulations but with adjustments for the UK’s exit from the European Union. Regulation 4 confirms that the interpretation of these Regulations as they had effect, or any guidance as it applied, before exit day, shall continue to do so. These Directives specify the designation and protection of Special Areas of Conservation (SAC) and Special Protection Areas (SPA) which are together known in the UK as National Site Network sites (formerly Natura 2000 sites). They also provide protection for species, referred to as Protected Species (PS), formerly referred to as European Protected Species. Wildlife and Countryside Act 1981 (as amended) 14.3.3 The Wildlife and Countryside Act (WCA), 1981 (as amended), provides legal protection for Sites of Special Scientific Interest (SSSI) in England and Wales. It also provides varying levels of protection for all wild birds, including those listed on Schedule 1 (Sch1), which receive greater protection whilst breeding, along with plants listed in Schedules 5 to 8 of the Act. The Act also lists invasive species in Schedule 9. Natural Environment and Rural Communities Act 2006 14.3.4 The Natural Environment and Rural Communities (NERC) Act came into force on 1st October 2006. Section 40 of the Act requires all public bodies in exercising of those functions, to have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity. This is commonly referred to as the ‘biodiversity duty’. 14.3.5 Section 41 of the Act in England requires the Secretary of State to publish a list of habitats and species of ‘principal importance for the conservation of biodiversity.’ They are referred to in this Chapter as Habitats (HPI) and Species of Principal Importance (SPI). This list is intended to assist decision makers such as public bodies in implementing their duty under Section 40 of the Act. Under the Act, these are regarded as a material consideration in determining planning applications, which places a legal responsibility on public authorities in England to have due regard for habitats and species of conservation importance, whilst protecting all biodiversity.
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The Environment Act 2021 14.3.6 The Environment Act (the Act) gained Royal Assent on the 9 November 2021 and is now enshrined within UK law. The Act provides a mechanism for implementing Government’s ambitions for ‘improving the natural environment’, which were previously set out in publications including the 25 Year Environment Plan (25YEP). The Act provides recognition of the 25YEP as the first “environmental improvement plan” which, through the enactment of relevant regulations serves as the basis for the steps Government intends to take to improve the natural environment. The 25YEP was replaced by the Environmental Improvement Plan (also referred to as the EIP23) in January 2023. 14.3.7 The Act implements the ambitions for an improved natural environment, by setting out statutory or legal requirements which mandate action, under the oversight of the newly formed Office for Environmental Protection (OEP). The focus of the Act is the “…provision [of] targets, plans and policies for improving the natural environment…” and its requirements are structured around a number of broad themes. Of relevance to this report Part 6 of the Act sets out provisions for ‘Biodiversity Gain as condition of planning permission’. 14.3.8 The Environment Act 2021 also introduces statutory requirement for Biodiversity Net Gain to be applied to new development proposals (with a minimum 10% gain required) through the Town and Country Planning Act 1990, which is implemented by a suite of regulations:
• • • • • • •
The Environment Act 2021 (Commencement No. 8 and Transitional Provisions) Regulations 2024; The Biodiversity Gain (Town and Country Planning) (Modifications and Amendments) (England) Regulations 2024; The Biodiversity Gain (Town and Country Planning) (Consequential Amendments) Regulations 2024; The Biodiversity Gain Requirements (Irreplaceable Habitat) Regulations 2024; The Biodiversity Gain Requirements (Exemptions) Regulations 2024; The Biodiversity Gain Site Register Regulations 2024; and The Biodiversity Gain Site Register (Financial Penalties and Fees) Regulations 2024.
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Wild Mammals (Protection) Act 1996 14.3.9 The Wild Mammals (Protection) Act 1996 makes it an offence for any person to mutilate, kick, beat, nail or otherwise impale, stab, burn, stone, crush, drown, drag or asphyxiate any wild mammal with intent to inflict unnecessary suffering.
Planning Policy Context 14.3.10 The following national, regional and local planning policy and guidance is of relevance to the assessment of the effects of the Proposed Development in relation to ecology. National 14.3.11 The following national level policy and guidance documents are of relevance to the Proposed Development: National Planning Policy Framework (2023) 14.3.12 The National Planning Policy Framework (NPPF)1 replaced Planning Policy Statement (PPS9), was published in 2012 and most recently updated in December 2023. The NPPF sets out how the environment can be conserved and enhanced through the planning system. The NPPF emphasises the need for sustainable development. However, it also specifies the need for protection of designated sites as well as priority habitats and species. An emphasis is also made for the need for coherent ecological networks via their preservation, restoration and enhancement. In determining a planning application, planning authorities must demonstrate how a development will achieve biodiversity net gain and the conservation and enhancement of habitats and species. Development resulting in the loss or deterioration of irreplaceable habitats including aged or veteran trees and also ancient woodland should be refused, unless there are exceptional circumstances and a suitable compensation strategy. Planning Practice Guidance (NPPG) (2019) 14.3.13 The government publishes planning practice guidance (PPG) online to assist in the delivery of the planning policies for England set out within the NPPF. There are two sections of PPG of relevance to ecology in regard to the scheme, these are ‘Biodiversity Net Gain’2 and ‘Natural Environment’3.
1
The National Planning Policy Framework, 2023: https://www.gov.uk/guidance/national-planning-policy-framework
2
Biodiversity Net Gain PPG, 2024: Biodiversity net gain - GOV.UK (www.gov.uk)
3
Natural Environment, 2024: Natural environment - GOV.UK (www.gov.uk)
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Regional London Plan 2021 14.3.14 The London Plan (GLA, 2021) places greater emphasis on green infrastructure and proposes that developments should incorporate green infrastructure. Policy G5 encourages Local Boroughs to develop their own ‘Urban Greening Factor’ to identify the appropriate target for urban greening, based on the proportion of surface cover that contributes to ecosystem services. In the interim the target score is 0.4 for residential developments and 0.3 for commercial developments. Policy G6 states that ‘development proposals should manage impacts on biodiversity and aim to secure net biodiversity gain’. Sustainable Design and Construction Supplementary Planning Guidance (2014) 14.3.15 The aim of this supplementary planning guidance is to support developers, local planning authorities and neighbourhoods to achieve sustainable development. It does this by providing guidance on how to achieve the London plan objectives effectively. 14.3.16 Section 2.8 of the guidance is in relation to ‘Nature Conservation and Biodiversity’ and highlights from the outset the Mayor’s priorities of ‘no net loss in the quality and quantity of biodiversity’ and for ‘Developers [to] make a contribution to biodiversity on their development site.’ Local London Borough of Lewisham: Core Strategy (2011) 14.3.17 The Lewisham Core Strategy (Lewisham Council, 2011) was adopted in June 2011 and is the key planning document in the Lewisham Local Development Framework (LDF). The following policy is of most relevance to ecology in relation to the scheme: Core Strategy Policy 12 Open space and environmental assets 1. In recognising the strategic importance of the natural environment and to help mitigate against climate change the Council will: a. Conserve nature b. Green the public realm c. Provide opportunities for sport, recreation, leisure and well-being. 2. This will be achieved by:… f. preserving or enhancing the local biodiversity and geological conservation interests in accordance with national and regional policy, in the form of PPS9 and the London Plan by designating Sites of Importance for Nature Conservation. g. protecting trees, including street trees, and preventing the loss of trees of amenity value, and replacing trees where loss does occur… l. promoting living roofs and walls in accordance with London Plan policy and Core Strategy Policy 8.
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Lewisham Development Management Local Plan (2014) 14.3.18 The Lewisham Development Management Local Plan (Lewisham Council, 2014a) sets out the Council’s planning policies for managing development in Lewisham with the primary objective being to foster the delivery of sustainable development. The following policy is of most relevance: DM Policy 24 Biodiversity, living roofs and artificial playing pitches 1. The Council will require all new development to take full account of biodiversity and geodiversity in development design, ensuring the delivery of benefits and minimising of potential impacts on biodiversity and geodiversity. 2. Applicants for all major and, where appropriate, non-major development will be required to use up to date surveys and reports that are based on the latest legislation and carried out by a suitably qualified ecologist registered with the Chartered Institute of Ecology and Environmental Management (CIEEM). The surveys should be carried out during an optimal time and contain the appropriate degree of detail needed to identify and consider existing biodiversity interests and possible impacts on them, where the proposed site is part of, or located adjacent to, a site designated for its biodiversity value.
DM Policy 25 Landscaping and trees 2. Applicants for all major development and, where appropriate, non-major development (and always when here is a Tree Preservation Order in place) will be required to: Retain existing trees for the most part and in the event of tree removal, replacement planting will normally be required. New and replacement tree planting must use and appropriate species that reflects the existing biodiversity in the borough.
Lewisham Town Centre Local Plan (2014) 14.3.19 The Lewisham town centre local plan (Lewisham Council, 2014b) provides a vision and number of objectives for the town centre, supported by policies, guidance and a delivery plan. The most relevant policy to ecology is as follows: Policy LTC25 Adapting to climate change 1. All developments and works to the public realm will be able to adapt to the potential impacts of climate change. In doing so applications are required to use measures including, but not limited to, the following: a. Living roofs and walls, b. Water saving measures, c. Sustainable urban drainage systems, d. Vegetation and planting, e. Siting and design of buildings and services to minimise impacts, Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 14: Ecology
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f.
Materials.
Lewisham Local Plan (2023) 14.3.20 The Draft Lewisham Local Plan (London Borough of Lewisham, 2023) deals with matters of strategic importance for spatial development within the borough, including policies regarding protection, enhancement, creation, promotion and management of biodiversity. The following extracts are of most relevance to the ecology of the scheme: 10 GREEN INFRASTRUCTURE GR3 Biodiversity and access to nature C - Development proposals must seek to avoid harm to biodiversity including within SINC sites and Local Nature Reserves. In line with London Plan policy G3 (Biodiversity and access to nature), where it is demonstrated that harm is unavoidable, and where the benefits of the development proposal clearly outweigh the impacts on biodiversity, the following mitigation hierarchy must be applied to minimise impacts: a. Avoid damaging the significant ecological features of the site; b. Minimise the overall spatial impact and mitigate it by improving the quality or management of the rest of the site; and c. Deliver off-site compensation of better biodiversity value. E - Development proposals should seek to secure Biodiversity Net Gain. The BNG benchmark is a minimum 10 per cent increase in habitat value for wildlife compared with the pre-development baseline, calculated using an appropriate Biodiversity Metric. Biodiversity should be fully integrated into the design-led approach with consideration given to the site context and its wider landscape setting.
GR5 Urban greening and trees A - Development proposals must demonstrate how the design-led approach has been used to maximise opportunities for urban greening. This includes the integration of high quality and species diverse landscaping, street trees, wildlife habitat, green roofs and walls and Sustainable Drainage Systems. They must be designed with consideration given to the site context and the wider landscape setting as well as the layout, design, construction and long-term management of buildings and spaces. D - Development proposals should maximise the use of green roofs and walls. Major development proposals will be expected to demonstrate that the feasibility of integrating these measures has been fully investigated, and minor development proposals are strongly encouraged to incorporate them. Green roofs and walls will be supported where they are appropriately designed, installed and maintained. Development proposals should have regard to the latest industry good practice guidance to help ensure that green roofs and walls are designed to maximise environmental benefits and will function effectively over the lifetime of the development.
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E - Development proposals must seek to retain existing trees as well as the associated habitat with regard for the urban forest, with reference to Policy GR3 (Biodiversity and access to nature). They should also maximise opportunities for additional tree planting particularly in urbanised locations such as streets and town centres. Development proposals must demonstrate that they will: a. Provide for the sensitive integration of all trees whilst ensuring any new or replacement on-site provision is of a high ecological quality (including appropriate species, stem girth and life expectancy) and contributes positively to the microclimate; b. Protect veteran trees and ancient woodland; c. Retain trees of quality and associated habitat, wherever possible, with appropriate arrangements to secure their protection throughout demolition, construction, and external works, to the occupation stage of development; d. Avoid the loss of, and mitigate against adverse impacts on, trees of significant ecological, amenity and historical value; e. Ensure building foundations are sufficient to be climate change resilient in proximity to trees; and f. Ensure adequate replacement tree planting where the retention of trees is not reasonably practical, with replacement provision that meets the requirements of (a) above. Lewisham Biodiversity Action Plan (LBAP) 14.3.21 The Lewisham Biodiversity Action Plan (Lewisham Biodiversity Partnership, 2021) identifies the opportunities and objectives that Lewisham’s Biodiversity Partnership is committed to achieving. It contains action plans for conserving the following priority species and habitats within the Borough:
Priority Species 1. 2. 3. 4. 5. 6. 7. 8. 9.
All bat species; Black redstart Phoenicurus ochruros; Kingfisher Alcedo atthis; Common toad Bufo bufo; European hedgehog Erinaceus europaeus; House sparrow Passer domesticus; Song thrush Turdus philomelos; Stag beetle Lucanus cervus; and Swift Apus apus.
Priority Habitats 1. Living roofs; 2. Rivers; 3. Railway ‘linesides’; Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 14: Ecology
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4. Standing water and ponds; and 5. Woodlands and trees. Technical Standards and Guidance 14.3.22 This Chapter has been prepared with reference to best practice guidance published by the Chartered Institute for Ecology and Environmental Management (CIEEM) (CIEEM, 2018)4 and as detailed in British Standard 42020:2013 Biodiversity - Code of Practice for Biodiversity and Development (BSI, 2013)5.
14.4 Assessment Methodology and Significance Criteria 14.4.1 The following section outlines the methodologies applied to identify and assess the potential impacts and likely effects to result from the Proposed Development. Scope of the Assessment 14.4.2 An EIA Scoping Report was issued to LBL in January 2024 (Appendix 2.1). LBL’s formal Scoping Opinion was issued in June 2024 (Appendix 2.2). 14.4.3 The following potential effects were scoped into the assessment: • • •
Disturbance to bats foraging and commuting in the nearby Lewisham Railway Triangles Site of Borough Importance for Nature Conservation (SBINC); Peregrine falcon; and Breeding birds
Likely Significant Effects Demolition and Construction Phase • • •
Death/injury to peregrine falcon; Destruction of active bird nests; and Creation of habitats for foraging bats and birds.
Operational Phase •
Disturbance to bats utilising the nearby SBINC associated with increased lighting levels.
4
CIEEM (2018). Guidelines for Ecological Impact Assessment in the UK and Ireland. Terrestrial, Freshwater, Coastal and Marine. Chartered Institute of Ecology and Environmental Management, Winchester 5
British Standards Institution (2013). Biodiversity. Code of practice for planning and development: 42020. BSI, London.
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14.5 Extent of The Study Area 14.5.1 In accordance with CIEEM guidelines, the geographic scope of the assessment (the zone of influence (ZoI)) is defined by the area within which potential ecological impacts are considered likely to occur. This includes the physical extent of land-use associated with the proposals as well as indirect or exported effects of pollution and light or noise disturbance that may affect a wider area. The scope of assessment is determined for each impact based on its likely spatial extent and the distribution of ecological features likely to be affected. 14.5.2 The study area of sites, habitats and species was determined by application of best practice guidance. The maximum considered ZoI was up to 15km for International Important Wildlife Sites (IIWS), within a relevant impact risk zone for Sites of Special Scientific Interest (SSSI) where the project was of a type noted, 2km for other sites, and for sensitive ecological receptors within 200m of the Affected Road Network. Relevant guidance indicates the potential for offsite impacts on ecological features at these distances. The data searches within the desk study covered the Site boundary plus a radius of 2km, extended to 15km for IIWS to take account of this. 14.5.3 The ZoI for populations of bats and birds, and peregrine falcon encompasses a precautionary 2km radius from the Site due to the highly mobile nature of these species/species groups. For all other ecological features, the ZoI is up to 500m from the Site. Method of Baseline Collection 14.5.4 The baseline was determined through a combination of desk study, extended Phase 1 habitat survey and dedicated protected species/habitat surveys. The methodologies used to determine the ecological baseline are summarised within this chapter, with a full description available in the technical reports presented in (Appendix 14.1 – 14.4). The red line boundary was subsequently reduced in size, no changes in the impacts to the findings of the PEA or the impacts and effects of this ES chapter are anticipated. Desk Study 14.5.5 Information on protected species and habitats was received from Greenspace Information for Greater London (GiGL), the local biological records centre. Searches for recent data (less than ten-years’ old) were also made and records obtained from Magic (https://magic.defra.gov.uk/), the government’s online mapping service. Full details are included within the PEA in Appendix 14.1. Field Surveys 14.5.6 A summary description of the methodologies adopted for the relevant surveys is provided below. Full descriptions are included within Appendix 14.1 – 14.4.
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Extended Phase 1 Habitat Survey 14.5.7 An extended Phase 1 habitat survey of the Site was carried out on the 27 April 2023 in clear, dry weather conditions. It covered the entire Site including boundary features (PEA,2023). Habitats were described and mapped following standard Phase 1 habitat survey methodology (JNCC, 2010)6 and marked on a paper base map and subsequently digitised using ESRI ArcGIS software. The aim of this survey was to map all the habitats in the survey area and identify any habitats that are considered as potentially ecologically important and/or have some potential to support any ecologically important and/or legally protected floral or faunal species. The red line boundary was subsequently reduced in size, no changes in the impacts to the findings of the PEA or the impacts and effects of this ES chapter are anticipated. Full mapping of the extent of the site surveys are included within the PEA in Appendix 14.1. 14.5.8 Habitats were also assessed against descriptions of Habitat of Principal Importance as set out by the JNCC (BRIG, 2008)7 where appropriate. Biodiversity Net Gain 14.5.9 A Condition Assessment walkover survey was conducted across the site on the 5 April 2024 in suitable weather conditions. Habitats that were mapped in Phase 1 were subsequently converted to BNG. The purpose of the survey was to assess each parcel of habitat type in accordance with Government-published condition assessment criteria8 resulting in a level of condition being assigned. Following the survey, the results were input to the Statutory Biodiversity Metric Tool for analysis (see Appendix 14.4: Biodiversity Gain Plan).
JNCC (2010). Handbook for Phase 1 Habitat Survey – A Technique for Environmental Audit. England Field Unit, Nature Conservancy Council. Reprinted by Joint Nature Conservation Committee, Peterborough 6
7 BRIG 2007 Report on the Species and Habitat Review (Report by the Biodiversity Reporting and Information Group (BRIG) to the UK
Standing Committee). 8
Statutory biodiversity metric tools and guides - GOV.UK (www.gov.uk)
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Bats 14.5.10 An update to the original Preliminary Roost Assessment (PRA) conducted in 2021 of all 11 buildings on site (B1 to B11) was undertaken on the 27 April 2023 (see Appendix 14.2). The primary aim of the surveys was to establish the suitability of the buildings on Site to support bat roosts through an assessment of the presence of Potential Roost Features (PRF). 14.5.11 Buildings were assessed externally only and comprised a detailed search of all accessible architectural features for bat droppings, urine staining, scratch marks, staining and feeding remains. Windowpanes and other external surfaces were checked for droppings or other secondary evidence. Any features that could potentially provide access into internal areas (such as cavity walls) were noted. 14.5.12 A Ground Level Roost Assessment (GLRA) of all trees located on site was also undertaken. This assessment identified any suitable arboreal features that could provide access points for bats, including loose, flaking or folded bark, cracks and fissures in limbs, woodpecker holes, or any downward-facing crevice or holes in limbs or trunk. Any signs indicating the use of features by bats (as set out in 14.5.11) were noted. 14.5.13 Any tree with a level of potential to support a bat roost were assessed using the Cowan Scale9 which involved assigning values that consider the availability of suitable bat roosting features from ‘0’ (no value) through to ‘4’ (confirmed roost). 14.5.14 All surveyed buildings and trees were assessed using best practice guidelines 10. Values of negligible, low, moderate and high were assigned to each building and tree depending on its suitability to support roosting bats. 14.5.15 Any safely accessible PRF was subject to an endoscope inspection by a Natural England Level 2 Class Licence Holder for bat survey, on the 4 July 2023. The aim of the inspection was to further establish the suitability of Building 6 for roosting bats. 14.5.16 While the Site was assigned as having negligible suitability for foraging and commuting bats, due to the presence of the adjacent Oxleas Wood Triangle SINC, a single bat activity transect survey was undertaken on the 20 June 2023 in suitable weather conditions, in accordance with best practice guidance11 at the time to determine if any use of the site was made by bats present within the SINC (see Appendix 14.2). A single transect route was walked at a slow pace with ten five-minute listening points factored into the route where surveyors would stop and record bat activity (using Elekon Batlogger M bat detectors) before continuing along the transect. The route covered all habitats on site within the updated redline boundary. The survey aimed to determine how bats are using the Site for foraging and commuting, the species present, their status and relative conservation importance and likely impacts that could occur as a result of the proposals.
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9
Cowan, A. (2006). Trees and Bats. Guidance Notes 1. Arboricultural Association, Cheltenham.
10
Collins, J. (ed.) (2016) Bat Surveys for Professional Ecologists: Good Practice Guidelines. 3rd edition. The Bat Conservation Trust, London. 11
Collins, J. (ed.) (2016) Bat Surveys for Professional Ecologists: Good Practice Guidelines. 3rd edition. The Bat Conservation Trust, London.
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Peregrine falcon In view of the known presence of this species within the Site, a peregrine falcon survey was undertaken in 2023, involving two visits carried out in April and June 2023. The surveys took place in suitable weather conditions and following good practice guidance12. The purpose of the survey was to determine the continued presence/likely absence of breeding peregrine at the Site, their location, and to provide recommendations for mitigation measures as required. Full details are included within Appendix 14.3: Peregrine Falcon Survey Report. 14.5.17 Inspection for evidence of peregrine presence was undertaken of all possible areas of Lewisham Shopping Centre and associated buildings from ground level. The roof of the shopping centre was also accessed for surveying on the 21 April 2023. Access to the roof level of the tower block was not permitted for any survey. 14.5.18 Vantage Point (VP) surveys for peregrine were carried out on the 21 April and 23 June 2023, which involved an experienced ornithological surveyor being positioned for 1.5hrs at a suitable VP using high-powered binoculars to watch the buildings on site and recording the presence and activities of any peregrines present.
Limitations and Assumptions 14.5.19 Even where data are held, a lack of records for a defined geographical area does not necessarily mean that there is a lack of ecological interest; the area may be simply under-recorded. This is taken into account when interpreting records. 14.5.20 Whilst every effort has been made to provide a comprehensive description of the Site, no investigation can ensure the complete characterisation and prediction of the natural environment. 14.5.21 An internal inspection of relevant areas such as Buildings B6 and B2 was not possible due to access restrictions. It was also not possible to inspect the roof structures. Full details are included within Appendix 14.2. 14.5.22 The initial PRA survey conducted on 27th April 2023 was subject to access restrictions around building B6. As such a full PRA inspection could not be completed, therefore, a precautionary assessment of Moderate potential was made. This is not seen as a major limitation to the works due to access being granted to the building on 4th July 2023 for completion of a close inspection and endoscope survey. 14.5.23 During the endoscope survey for bats, an active black redstart nest containing hatchlings was recorded within an abandoned food stall in Building 6. The surveyor’s presence alerted the adult birds who began warning calls immediately. So as not to disturb the nest and potentially cause nest abandonment, the surveyors chose to survey the single food stall with the nest from a distance. This is not seen as a limitation to the survey however as no features were seen within this section that required close inspection. Results gathered from the bat transect surveys are representative of the bat activity at the times the surveys were undertaken. Only a single transect survey was undertaken, no further surveys were deemed necessary due to the lack of any supporting functional habitat for bats and the lack of presence of any bats during the survey. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 14: Ecology
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14.5.24 Data from ecological surveys should generally be considered to be valid for a period of 12-18 months, unless otherwise stated or there are any significant changes to the habitats within the site (CIEEM, 2019)13. Data used to support a mitigation licence application to Natural England must be from the most recent survey season; depending on the timing of the application, this may mean from the same or previous year. 14.5.25 All other limitations associated with the individual surveys are discussed in the technical reports in Appendix 14.1 – 14.2. All were adequately addressed, and the baseline is considered to be sufficiently robust to inform this impact assessment. Prediction Methodology 14.5.26 This section sets out the methodology for determining potentially significant effects that may arise as a result of the Proposed Development. It should be noted that the methodology for the demolition and construction phase is the same as that for the completed Proposed Development. 14.5.27 The effect of the Construction and Operational Phases of the Proposed Development on ecological features and attributes has been assessed in accordance with the Chartered Institute of Ecology and Environmental Management guidelines for Ecological Impact Assessment (EcIA) (CIEEM, 2018)14. The CIEEM criteria have then been translated to an effect that corelates with the scale of negligible, minor, moderate and major (and significant/not significant) to align with EIA terminology as presented within Table 14.2. Effects are considered to be adverse or beneficial with major and moderate effects considered to be ‘significant’ and minor and negligible effects considered to be ‘not significant’. This methodology is used in order to allow the results of the assessment of effects on biodiversity to be integrated into the wider EIA without compromising the CIEEM best practice approach. Methodology for Defining Effects 14.5.28 In accordance with the CIEEM EcIA guidelines, a Zone of Influence (ZoI) from the Proposed Development, was established. Following this, the ecological features that may be subject to effects arising from the Proposed Development were assigned a geographical scale of importance. Once the ZoI and geographical scale of importance of each ecological feature was determined, the potential impacts of the Proposed Development were predicted, taking into account the different stages and activities in the development process (i.e. demolition and construction, or operation). The scale of significance of the identified effects was then assessed. Assessment of Importance of Ecological Features 14.5.29 In line with CIEEM guidelines, features likely to be important in terms of biodiversity were identified and evaluated on a geographical scale of importance as set out below in Table 14.1. In descending level of importance, features assessed to be ‘important’ are categorised as: international and European; national (UK); regional (South east); metropolitan, county, vice county or other local authority-wide area (London); and local (Lewisham). Features of less than local level of importance are classified as being of site level importance where they have ecological importance within their immediate vicinity, or otherwise as being of negligible importance. Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 14: Ecology
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Table 14.1: Definition of Scale of Importance Scale of Importance
Examples of Definitions
International
An internationally designated site e.g., SPA, SAC, Ramsar Site, or site considered worthy of such designation; A viable area of a habitat type listed in Annex 1 of the Habitats Directive, or smaller area of such habitat which are essential to maintain the viability of a larger whole; or, A regularly occurring, substantial population of an internationally rare species.
National (UK)
A nationally designated site e.g., Site of Special Scientific Interest (SSSI), or site considered worthy of such designation; A viable area of habitat identified as a Habitat of Principle Importance (also known as a Section 41 habitat), or of smaller areas of such habitat, which are essential to maintain the viability of a larger whole; or, A regularly occurring, substantial population of a nationally rare species.
Regional
Areas of internationally or nationally important habitats, which are degraded but are considered readily restored; or, A regularly occurring, substantial population of a regionally scarce species.
Metropolitan, County
A site designated as a County Wildlife Site (CWS), Site or Metropolitan Importance for Nature conservation (SMINC) or Site of Borough Importance for Nature Conservation (SBINC); or, A regularly occurring, substantial population of a species scarce in the county.
Local, District, Parish
Viable areas of Local Biodiversity Action Plan (BAP) Priority Habitat, or small areas of such habitat which are essential to maintain the viability of a larger whole; or, A regularly occurring, population of a species scarce in the District.
Site
A regularly occurring population within the site itself or the immediate vicinity of the development.
Negligible
A habitat which offers little value for nature conservation e.g., hardstanding.
13
CIEEM (2019) Advice note on the life span of ecology reports and surveys. Chartered Institute of Ecology and Environmental Management, Winchester.
14
CIEEM (2018). Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial, Freshwater and Coastal, 2nd edition. Chartered Institute of Ecology and Environmental Management, Winchester
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Importance Based on Biodiversity Attributes 14.5.30 The ecological importance of areas of habitat and plant communities has been assessed against published selection criteria where available. Local Biodiversity Action Plans (BAPs), where they remain relevant, have been searched to identify whether action has been taken to protect all areas of a particular habitat and to identify current factors causing loss and decline of particular habitats. The presence of legally controlled weeds has also been taken into account. 14.5.31 When assigning a level of importance to a species, its distribution and status, including a consideration of trends based on available historic records, has been taken into account. Other factors influencing the importance of a species are legal protection, rarity and Species Action Plans (SAP). Guidance, where it is available, for the identification of populations of sufficient size for them to be considered of national or international importance has also been taken into account. Additionally, evaluation of importance has been based on inclusion on Annexes II, IV and V of the Habitats Directive, Annex I of the Birds Directive, under Section 41 of the NERC Act (2006) as SPI in England, as Red / Amber under the Birds of Conservation Concern 5 (the UK Red List for birds), under Annexes 1, 5 and 8 of the Wildlife and Countryside Act (1981 as amended) and as Local BAP species. 14.5.32 Factors taken into consideration in determination of importance of ecological features include (CIEEM, 2018): • • • • • • • • • • • • • • •
designations and nature conservation status; statutory and non-statutory designated sites for nature conservation; Habitats and Species of Principal Importance for nature conservation in England (NERC Act, s.41); Local BAP priority habitats and species; Red Data Book (RDB) species of conservation concern15; Birds of Conservation Concern 516 (Stanbury et al., 2021); nationally rare and nationally scarce species; legally protected species; animal or plant species, sub-species or varieties that are rare or uncommon, either internationally, nationally or more locally, including those that may be seasonally transient; ecosystems and their component parts, which provide the habitats required by important species, populations and/ or assemblages; endemic species or locally distinct sub-populations of a species; habitat diversity; habitat connectivity and/ or synergistic associations; habitats and species in decline; and large populations of species or concentrations of species considered uncommon or threatened in a wider context.
15
Search | JNCC
16
bocc-5-a5-4pp-single-pages.pdf (bto.org)
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Evaluation of Impacts 14.5.33 An assessment of likely ecological impacts has been undertaken in accordance with CIEEM guidelines (2018) only where clear evidence is available to substantiate and justify the findings. In the absence of such evidence, the precautionary principlel has been applied and the effect included as significant in the absence of evidence to the contrary. Impacts have been assessed initially without mitigation in accordance with the approach adopted by CIEEM (2018). Following identification of the scale and magnitude of impacts, mitigation measures have then been proposed that are commensurate with the impacts identified. The impact assessment has then been reapplied to determine the scale of any residual impacts to each ecological receptor, to determine potential residual effects. Only those receptors for which effects are considered significant are carried through to the mitigation stage. 14.5.34 A level of significance has been assigned to each predicted effect. The geographic scale of the effects has been estimated on the same geographic scale as set out in Table 14.1. Where an ecological feature falls into more than one category of scale (e.g., a site designated at both the international and national level), then the highest category is always selected for evaluation purposes. 14.5.35 Activities likely to generate impacts on ecological receptors have been identified by considering the following: • • • •
the design of the overall Proposed Development; desk study information; field survey information; and EIA experience and publications relating to similar projects/schemes.
14.5.36 Activities likely to generate effects were then broadly categorised into the following: • • •
demolition of existing structures and construction of the overall development; operation of the overall development; and potential non-standard operations (e.g., one off incidents and accidents).
14.5.37 The assessment takes account of the effects of impacts on ecologically important features according to the following process: • • • • •
identifying and characterising impacts and their consequence; taking account of measures to mitigate for these impacts; assessing the significance of any residual effects after mitigation; identifying appropriate compensation measures to offset significant residual effects; and, identifying opportunities for enhancement, including Biodiversity Net Gain.
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14.5.38 In accordance with BS42020: 2013 and CIEEM guidelines (2018), the following factors have been taken into account for each identified impact on each relevant ecological feature: • • • • • •
positive or negative; extent; magnitude (size / amount / intensity / volume); duration (short, medium or long-term, permanent or temporary); timing / frequency (occurring at a critical stage in lifecycle, regular or irregular); and, reversibility (reversible or irreversible).
14.5.39 In line with the mitigation hierarchy, suitable measures have been recommended to: • • • •
avoid negative ecological effects; mitigate to reduce negative ecological effects that cannot be avoided; provide compensation to offset effects; and, deliver ecological enhancements to achieve net gains in biodiversity.
14.5.40 Assessments have been based on available literature and professional judgement as to whether the integrity (of a site or ecosystem) or the conservation status (of a habitat or species) is likely to be affected; in other words, whether the effect would be ‘significant’ in ecological terms. 14.5.41 ‘Integrity’ in relation to land lacking a designation or objectives for nature conservation is a long-term concept and defined as follows: ‘The integrity of a site is the coherence of its ecological structure and function, across its whole area that enables it to sustain the habitat, complex of habitats and / or the levels of populations of the species that would be considered acceptably characteristic of the Site’. 14.5.42 For habitats, conservation status: ‘… is determined by the sum of the influences acting on the habitat and its typical species that may affect its long-term distribution, structure and functions as well as the long-term survival of its typical species within a given geographical area’. 14.5.43 For species, conservation status: ‘… is determined by the sum of the influences acting on the species concerned that may affect the long-term distribution and abundance of its populations within a given geographical area’.
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14.5.44 Each effect is then considered significant at the level at which the ecological receptor is important, combined with the scale at which the impact itself is likely to incur an effect. The ecological importance of a given receptor may not, therefore, be the same as the scale of effect significance. 14.5.45 Where ecological constraints to development are identified, mitigation measures that are proportionate to the predicted degree of risk to biodiversity and to the nature and scale of the Proposed Development are described. In addition, in accordance with the NPPF and the Environment Act 2021, opportunities for the provision of net gains in biodiversity are provided. 14.5.46 Where applicable, suitable monitoring or follow-up arrangements to determine whether mitigation has been successful and to specify appropriate remedial actions have been proposed. Lastly, residual effects are assessed using the aforementioned methods employed for the assessment of unmitigated impacts. Categorising Significant Effects 14.5.47 The CIEEM Guidelines state that an effect should be determined as being significant when it “either supports or undermines biodiversity conservation objectives for important ecological features or for biodiversity in general”. Significance is a concept related to the weight that should be afforded to effects when decisions are made, and to the consequences, in terms of legislation, policy and/or development control. So, a significant negative (adverse) effect on a feature of importance at one level would be likely to trigger related planning policies and, if permissible at all, generate the need for development control mechanisms, such as planning conditions or legal obligations, as described in those policies. 14.5.48 An effect on an important ecological feature may be significant at the same geographic scale at which the feature is determined to be important, or at a lesser geographical scale, depending on the characterisation of the impact. By way of example, limited impacts on a woodland of county importance might be assessed as being significant at a local level of importance. This methodology supports an evidencebased approach which supersedes previous matrix-based assessment methodologies.
14.6 Significance Criteria 14.6.1 The assessment of the potential impacts and likely effects as a result of the Proposed Development has taken into account both the Demolition and Construction Phases and Operational phases. The significance level attributed to each effect has been assessed based on the magnitude of change due to the Proposed Development and the sensitivity of the affected receptor/receiving environmental to change, as well as a number of other factors that are outlined in more detail in Chapter 2: Approach to Assessment. 14.6.2 Magnitude of change and the sensitivity of the affected receptor/receiving environmental are both assessed on a scale of high, medium, low and negligible (as shown in Chapter 2: Approach to Assessment).
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Effect Significance 14.6.3 The following terms have been used to define the significance of effects identified:
•
Major positive or negative effect – where the Proposed Development would cause a large improvement (or deterioration) to the existing environment; • Moderate positive or negative effect – where the Proposed Development would cause a noticeable improvement (or deterioration) to the existing environment; • Minor positive or negative effect – where the Proposed Development would cause a small improvement (or deterioration) to the existing environment; and • Negligible – no discernible improvement or deterioration to the existing environment as a result of the development will occur. Conversion to a matrix-based approach 14.6.4 As stated above, in order to provide a comparison across the other chapters in this ES, the geographical scale effects have been converted to a scale level of negligible, minor, moderate, and major. Effects are considered to be adverse or beneficial with major and moderate effects considered to be ‘significant’ and minor and negligible effects considered to be ‘not significant’. 14.6.5 For ease of reference, Table 14.2 below provides a means of relating the two approaches and is provided in order to allow the Ecology Chapter to be integrated into the wider EIA without compromising the CIEEM best practice approach. Table 14.2 Criteria for Determining Significance
Criteria
Scale
Nature
Positive effect on the status of ecological features of interest from county to regional and international level.
Major
Beneficial Significant
Positive effect on the status of ecological features of interest at local level.
Moderate
Positive effect on the status of ecological features of interest at Site level.
Minor
No noticeable effect on the status of ecological features of interest.
Negligible N/A
Negative effect on the status of ecological features of interest at Site level.
Minor
Adverse
Negative effect on the status of ecological features of interest at local level.
Moderate
Adverse
Negative effect on the status of ecological features of interest at county to international and regional level.
Major
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Significance
Beneficial Not Significant
Significant
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14.6.6 For each ecological feature identified as being important, relevant impacts are then characterised; effects defined and their significance assessed. Following this, if required, mitigation is identified and the resultant significance of any residual ecological impacts (whether adverse or beneficial) reported.
14.7 Baseline Conditions 14.7.1 This section outlines the existing baseline ecological conditions of the Site. The baseline includes the statutory and non-statutory wildlife sites and other ecological receptors relevant to the zone of influence. Additional information on the findings of the extended Phase 1 habitat survey and subsequent ecology surveys are included in Appendix 14. Designated Sites 14.7.2 The Site is not subject to any statutory nature conservation designations. Three Internationally Important Wildlife Sites are located within 15km of the Site (see Table 14.3). 14.7.3 The site does not fall within the ZoI for recreational impacts for Epping Forest SAC (6.2km)17 and it is considered unlikely that recreational impacts would occur to the other IIWS due to the distances from the Site. There are no other recognised impact pathways evident for pollution or other construction related impacts during the construction or operational phase, as a result no impacts are considered likely arising from the development and designated sites are scoped out of further consideration.
17
Natural England (2021) the Overarching Standard Advice for Development Applications within Epping Forest District. Natural England Peterborough
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Table 14.3 Internationally Important Wildlife Sites within 15km of the Proposed Development
Site Name
Lee Valley Ramsar site and SPA
Distance from Site and orientation
Ecological Importance
12.4km north
International
Qualifying features/Description
Potential constraint
Qualifying features of the SPA:
Due to the distance and limited connectivity between the Site and Lee Valley SPA and Ramsar site, the Proposed Development is not expected to result in significant negative effects on either the SPA or Ramsar site and on their respective qualifying features.
Wintering populations of Bittern (6% GB population), Shoveler (1.05% NW Europe) and Gadwall (1.5% NW Europe). Designated as a Ramsar: Supports nationally scarce plant species whorled water-milfoil Myriophyllum verticillatum and the rare or vulnerable invertebrate Micronecta minutissima (a waterboatman) and supports populations of shoveler and gadwall at levels of international importance.
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Epping Forest SAC
12.5km north west
International
Qualifying features of the SAC: Habitats listed in Annex 1 •
Atlantic acidophilous beech forests with Ilex and sometimes also Taxus in the shrublayer (Quercion roboripetraeae or IliciFagenion)
•
European dry heaths
•
North Atlantic wet heaths with Erica tetralix
Due to the type of development, distance and limited connectivity between the Site and Epping Forest SAC, the Proposed Development is not expected to result in negative effects on the SAC or its qualifying features.
Species listed in Annex 2 • Wimbledon Common SAC
14.6km
International
Stag beetle
Qualifying features of the SAC: Habitats listed in Annex 1: •
European dry heaths,
•
Northern Atlantic wet heaths with Erica tetralix.
Species listed in Annex 2 •
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Stag beetle
Due to the type of development distance and limited connectivity between the Site and Wimbledon Common SAC, the Proposed Development is not expected to result in negative effects on the SAC or its qualifying features.
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14.7.4 One nationally designated site, Brookmill Road Local Nature Reserve (LNR) and Site of Local Importance for Nature Conservation (SLINC) is located 800m north-west of the Site. This site comprises part of a disused railway embankment with native plantation woodland on the steep sides of the embankment. The Brookmill Road LNR is managed for educational use and is not publicly accessible. Therefore, due to the nature of the Proposed Development and distance from the Site, this statutory site does not warrant further consideration as no significant negative effects are likely as a result of the Proposed Development. 14.7.5 The Site lies within the IRZ (5km area) of one nationally designated site, the Oxleas Wood SSSI, located 4.8km east of the Site. IRZs are intended as a tool for local planning authorities to identify when specific types of development may require consultation with Natural England regarding their potential impact on statutory designated sites. Given the distance of the Site from the SSSI, it is unlikely that the development will have any significant impact on Oxleas Wood, and the development type does not meet the criteria of needing consultation with Natural England. Therefore, this site does not warrant further consideration as no significant negative effects are likely as a result of the Proposed Development. 14.7.6 The Site is not subject to any non-statutory nature conservation designations. In total, 25 non-statutory sites designated as SINCs are present within a 2km radius of the site. The closest of these sites is Lewisham Railway Triangles SINC which is directly adjacent to the west of the Site. The SINC is cited for its connecting function comprising key habitats that provide a wildlife corridor between areas within the Borough. 14.7.7 The remaining sites had no connecting ecological features, and were considered to be at sufficient distance to not be impacted by the development. These sites are not considered further within this assessment.
Table 14.4: Non-Statutory Designated Sites within 2km of Site
Site Name
Distance from Site and orientation
Ecological Importance
Qualifying features/Description
Potential constraint
Site of Metropolitan Importance for Nature Conservation (SMINC)
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Blackheath and Greenwich Park
640m northeast
This is assessed as important at a metropolitan level. Given the highly urban surroundings, this large open green space is of high ecological importance to the whole of London, providing a less common habitat within the urban landscape.
The largest area of open space in central south-east London. Greenwich Park contains many ancient parkland trees mostly sweet chestnuts, and other habitats including grassland, woodland and a lake. Blackheath has been intensively managed for sport and recreation, however several uncommon species remain including clustered and knotted clovers.
Not likely to be impacted by the Proposed Development due to distance from the Site. The nature of the works are unlikely to cause pollution impacts to this distance.
Site of Borough Grade II Importance for Nature Conservation (SBINC) Lewisham Railway Triangles
0m west
Importance is at a borough level, as a loss of which habitat would be significant to the Borough of Lewisham. Of high value for habitat connectivity and provision of a wildlife corridor.
Key habitats include rough grassland, tall herbs, scrub, scattered trees and woodland. The railway triangle hollows support woodland and rough grassland. Lewisham’s railsides comprise an extensive series of low disturbance wildlife habitats and green corridors.
The construction and operational phases of the development could result in the disruption of bats within the SBINC through an increase in lighting.
Lewisham to Blackheath Railsides
250m northeast
Importance is at a borough level, as a loss of which habitat would be significant to the Borough of Lewisham. This linear woodland habitat is of high value within the local ecosystem relating to local animal species.
Densely wooded railsides between Lewisham and Blackheath stations. The canopy is dominated by sycamore, with ash, silver birch, and oak also present. Of value to wildlife using wooded habitat such as breeding birds.
No constraints, the lack of connectivity to the development site lessens the potential for pollution to impact this SBINC.
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Hither Green Station
600m southwest
Importance is at a borough level, as a loss of which habitat would be significant to the Borough of Lewisham.
Railsides covered in sycamore woodland, with ash, pedunculate oak, and wild cherry also present. There is a dense scrub layer of hawthorn, elder, and bramble. The railway triangle is managed as a nature reserve and contains a pond, small stream, woodland, and grassland. Supports a good number of common bird species and provides some water habitat.
No constraints given the scale of the proposed works, it is not likely to extend a far enough distance to impact this site.
St Mary’s Churchyard, Lewisham
650m south
Importance is at a borough level, as a loss of which habitat would be significant to the Borough of Lewisham.
Old churchyard. Assemblages of fern species growing from tombstones and walls are the main ecological interest.
No constraints given the scale of the proposed works, it is not likely to extend a far enough distance to impact this site.
River Ravensbourne and Brookmill Park
750m northwest
Importance is at a borough level, as a loss of which habitat would be significant to the Borough of Lewisham.
Park supporting a variety of habitats including an ornamental garden, lake and nature reserve. A section of the River Ravensbourne has been re-landscaped and give a natural course, providing many niches for aquatic plants and animals.
No constraints. There is no waterway connecting the development area with this SBINC therefore it is unlikely that any pollution occurrence will impact this site.
St Johns Station
800m northwest
Importance is at a borough level, as a loss of which habitat would be significant to the Borough of Lewisham.
The railsides around St Johns Station has a mix of woodland and flower-rich grassland. Provides an area of low disturbance wildlife habitats and green corridors.
No constraints given the scale of the proposed works, it is not likely to extend a far enough distance to impact this site.
Site of Local Importance for Nature Conservation (SLINC)
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Hilly Fields
650m west
Importance is at a local level
Large park with many exotic tree species and smaller areas of woodland, scrub, and grassland.
No constraints given the scale of the proposed works, it is not likely to extend a far enough distance to impact this site.
Ladywell Fields
660m southwest
Importance is at a local level
Large park with several features of value to wildlife including the River Ravensbourne, railsides, small wooded areas and a nature reserve.
No constraints given the scale of the proposed works, it is not likely to extend a far enough distance to impact this site.
Brookmill Nature Reserve LNR
800m northwest
Importance is at a local level
A small nature reserve developed on a short section of disused railway embankment. The site is steep sided, and its banks are heavily wooded. Sycamore is dominant with ash, hornbeam, and hazel and a large plum tree.
No constraints given the scale of the proposed works, it is not likely to extend a far enough distance to impact this site.
Habitats and Flora 14.7.8 A brief description of habitats along with an approximate area in hectares at the Site is provided below. Further details can be obtained by reference to the Preliminary Ecological Appraisal (PEA) (see Technical Annex 14.1: Preliminary Ecological Appraisal Report).
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Habitats of Principal Importance 14.7.9 There were no habitats of principal importance (HPI) present on Site. One parcel of semi-improved grassland was located 1.8km north-east of Site. 14.7.10 There are approximately 230 parcels of deciduous woodland HPI located in all directions from the Site within a 2km radius. The closet of these is two parcels at Riverdale Sculpture Park approximately 25m south of Site. 14.7.11 Eight parcels of traditional orchard HPI are located within 2km of the Site, the closest of which being at Gilmore Road Park approximately 320m east of Site. 14.7.12 No areas of ancient woodland HPI were present within 2km of Site. Habitats on Site 14.7.13 The entirety of the site comprised areas of buildings and hardstanding, ornamental planting, and scattered trees. Buildings and Hardstanding 14.7.14 The Site comprised eleven buildings, ranging from four to 20-storeys in height (see Preliminary Roost Assessment in appendix 14.2 for building numbers). 14.7.15 These buildings consisted of retail shops making up Lewisham Shopping Centre, as well as a multistorey car park and a probation service building. Buildings were mostly brick and concrete construction with flat or mansard roofs, although some pitched roofs were present on retail buildings along Lewisham High Street. The buildings were considered to be of Negligible importance, however may provide higher importance as supporting habitat for peregrine and black redstart. Scattered Trees 14.7.16 There were 32 scattered trees present on Site, primarily grown as urban street trees for landscaping. Species present included: London plane, European lime, sycamore, Norway maple, silver maple and cherry. Due to their location in a highly urbanised area and their contribution to ecosystem services, the scattered trees present on Site were considered to be of importance at the site level. Ornamental Planting/Successional habitat 14.7.17 The Site contained a small area of ornamental planting (introduced shrub), mixed with successional species, within the south-western extent. Notable species present included: dog rose, common ivy, sycamore, cherry, London plane, field maple, perennial rye-grass, and cotoneaster species. This habitat was considered to be of negligible importance.
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Fauna Bats 14.7.18 The data search returned records for at least seven bat species within 2km of the Site. A single historic European Protected Species Mitigation Licence (EPSML) for a soprano pipistrelle roost was located approximately 200m north of Site in 2016. Table 14.5: Protected species mitigation licences granted within 2km of Site Licence number
Species
Start date
End date
Activity
Distance from Site
2015-15063EPS-MIT-2
Soprano pipistrelle
14/10/2016
08/01/2020
Destruction of a resting place
80m north
2018-34379EPS-MIT
Common pipistrelle, Soprano pipistrelle
21/06/2018
21/06/2023
Destruction of a resting place
500m north
EPSM20091505
Common pipistrelle, Soprano pipistrelle, Brown longeared
15/12/2009
14/12/2011
Destruction of a resting place
1.8km northwest
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14.7.19 A PRA of the Site in 2021 recorded all buildings and trees as having negligible potential to support roosting bats and a single activity transect survey of the Site recorded no bats. 14.7.20 During the updated 2023 PRA, building B1 was found to provide ‘Low’ bat roosting potential, whilst building B6 was identified to provide ‘Moderate’ bat roosting potential however during subsequent endoscope survey, this was downgraded to ‘Low’ suitability as well. The remaining nine buildings were all of negligible roosting potential. 14.7.21 The majority of trees on Site were found to be immature with a few semi-mature specimens present. None of these trees were found to provide any potential roost features suitable for bats. 14.7.22 While the habitat on site was considered to be of negligible potential to support commuting and foraging bats, due to the proximity of Lewisham Railway Triangles SBNCI to the Site, a single bat transect survey was undertaken in June 2023 to ascertain whether bats using the SBNCI were using the Site as supporting functional habitat. During the survey no bats were recorded at all and reflected the results of a previous survey undertaken in 202118. Given the highly urbanised context of the Site, which has the wide and busy Molesworth Street to the west and is surrounded by high levels of noise and lighting from streetlights, security lighting and surrounding shops, restaurants and bars, this was considered an accurate representation of the sites use for bats. 14.7.23 Small populations of bats are known to be present in the wider locale to the Site, given the presence of past EPSMLs to destroy bat resting places and records within 2km of Site. The Site is dominated by buildings and hardstanding, which have negligible value to supporting foraging and commuting bats, the scattered trees located along the western site boundary could provide a limited form of commuting habitat should bats be flying through the area, however surveys found no evidence of commuting bats. Therefore, the commuting and foraging habitat at the Site is considered likely to be of negligible importance. 14.7.24 Results of the endoscope survey of potential roosting features at Building B6 resulted in this building being downgraded from Moderate to Low suitability to support roosting bats. Only one other building was considered to provide the same roosting potential, which was Building B1, whilst all other buildings provided only negligible roosting potential due to their generally good state of repair. The buildings on Site offer some limited potential to support roosting bats, however the results of the activity transect survey combined with data search records indicate low levels of bat activity in the wider area. Therefore, the roosting habitat at the Site is considered likely to be of negligible importance.
18
The Ecology Consultancy (2021) Lewisham Shopping Centre – Bat Survey Report
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Birds 14.7.25 The data search returned numerous records from a variety of bird species within 2km of the Site, however the very limited habitats at the Site were considered unlikely to support the majority of species recorded in the data search. Aside from peregrine and black redstart (assessed below), the habitats on Site were considered to be of site level importance to breeding birds, not least as more suitable nesting habitats are present to the north, east and west of Site which would be more likely to be used by species of conservation concern. Peregrine falcon 14.7.26 At least 77 historic and current records for peregrine were provided from the data search dating between 1998-2014, and anecdotal evidence also suggested peregrine had previously been observed on building B2. This building was considered to provide good potential nesting opportunity for peregrine, as there were many ledges and flat areas on which eggs could be laid and incubated. Further dedicated surveys of building B2 found that peregrine was present on the building, and whilst only a male and female were observed on separate sides of the building during the survey, subsequent liaison with the client confirmed that a peregrine fledgling was rescued and there were four additional fledglings that had been sighted together on building B2, confirming a successful nesting attempt on Site. 14.7.27 Building B2 is a tall tower block in the north-west of the site and located in the centre of Lewisham. It has window ledges and other ledges around the building that peregrines have been seen to perch on, and an artificial nesting box has been installed on the building and monitored by ‘London Peregrines’. There is reported to have been a nesting pair present on the tower since at least 2009 and therefore the tower is of importance to the species locally. 14.7.28 As a result of the suitability of building B2 to support nesting peregrine, and the historic use of the site by a breeding pair, the Site was considered to be of borough level importance to breeding peregrine. Black redstart 14.7.29 An inspection of Building B6 on the 4 July 2023 during the PRA surveys discovered the presence of an active black redstart nest containing hatchlings within one of the food stalls. As black redstart nests are usually placed within holes or on internal ledges of buildings, buildings within the Site boundaries were considered to provide good nesting opportunities for the species.
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14.7.30 Current estimates are for up to 58 breeding pairs of black redstart being resident nationally in the UK19, historically Lewisham has recorded around 1% of the national population20. Breeding territory for black redstarts has been estimated at between 0.85 and 1.48ha per breeding pair. The presence of an active nest at the Site in 2023, confirms the use of the Site as a breeding resource. Based on the site size and in the absence of further survey data, on a precautionary basis it is considered that up to a further two pairs of breeding black redstart could be using the Site, representing around 5% of the UK breeding population. Based on the suitability of the Site to support breeding black redstart, the presence of and the protection afforded to the species, the population associated with the Site was considered to be of metropolitan scale importance to breeding black redstart. Invasive Species 14.7.31 A section of ornamental planting present on Site was found to contain a cotoneaster species amongst other introduced shrubs. Cotoneasters are notoriously difficult to identify to species level and there are five species of cotoneaster listed on Schedule 9 of the Wildlife and Countryside Act 1981 (as amended). The approach was taken to assume that the species of cotoneaster present on Site is one of the invasive Schedule 9 species. 14.7.32 Invasive species by their nature often have very limited value to biodiversity and for the most part they can actually have deleterious impacts upon native species of local provenance.
14.8 Summary 14.8.1 Table 14.6 provides a summary of current nature conservation importance of key ecological receptors. Table 4.6: Summary of Value of Key Receptors Key Ecological Receptor Lewisham Railway Triangle SINC Buildings and hardstanding Scattered trees Ornamental planting Commuting/foraging bats Roosting bats Breeding birds Peregrine falcon Black redstart
19
BTO (2024)
20
Lewisham BC (2021) A natural renaissance for Lewisham (2021-2026)
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Importance Borough Site Site Negligible Negligible Negligible Site Borough Metropolitan
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14.9 Future Baseline 14.9.1 This section outlines the future baseline conditions of the Site. 14.9.2 Consideration has been given to any likely changes between the time of survey and the future baseline for the construction and operation of the Proposed Development. In some cases, these changes may include the construction or operation of other planned or consented developments in the area. Where such developments are built and operational at the time of writing and data collection, these have been considered to form part of the baseline environment. Otherwise planned future developments are considered within the assessment of additional cumulative effects. The consideration of future baseline conditions has also taken into account the likely effects of climate change. 14.9.3 The future baseline of the site would likely consist of a continuation of current use, with areas of residential accommodation, commercial property use and storage.
14.10 Sensitive Receptors 14.10.1 The following are the sensitive receptors which will be considered in the following assessment: • • •
Lewisham Railway Triangle SINC; Peregrine falcon; and Black redstart
14.11 Identification and Description of Changes Likely to Generate Effects Demolition and Construction Phase Destruction of Schedule 1 bird nests 14.11.1 Negative effects may result from the refurbishment of Building B2, known to support a pair of breeding peregrine falcon and demolition of Building B6, known to support a pair of nesting black redstart. Disturbance 14.11.2 Negative effects may result from an increased level of disturbance caused by human activity, noise and vibration in the vicinity of ecologically sensitive features, such as nesting Schedule 1 list birds on Site. Species such as bats and birds within or adjacent to the Site may be disturbed by the demolition and construction phases. Pollution 14.11.3 Negative effects on retained trees and vegetation on or adjacent to the Site could result from an increased level of chemical, noise and sediment (dust) pollution during the demolition and construction phases.
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Lighting 14.11.4 The Site is within a central highly-urbanised part of Lewisham and is therefore already subject to high levels of lighting at night, however increased temporary lighting during the demolition and construction phases could result in impacts to sensitive species such as birds. The change of use from commercial to residential is likely to result in a reduction of lighting impacts during the operational phase due to the reduction in all night lighting currently in use within the Site. Habitat Loss 14.11.5 Negative effects may result from the loss of habitats including; buildings (e.g. destruction of active nests and loss of roosting habitat), scattered trees (e.g. removal of foraging areas for birds), introduced shrub (e.g. potential foraging habitat) during the demolition and construction phases. Habitat Creation 14.11.6 Positive effects may result from the creation of new habitats including scattered trees, shrubs, lined ponds with bankside planting and rain gardens, as well as artificial nesting and roosting features during the construction phase. These habitats may increase prey opportunity for peregrine falcon and foraging habitat for black redstart. 14.11.7 No impacts on statutory designated sites during construction are predicted. Operational Phase Disturbance 14.11.8 Negative effects may result from an increased level of disturbance caused by human activity in the vicinity of ecologically sensitive features. Species such as peregrine, black redstart and other breeding birds within the completed Proposed Development and adjacent to the Site may be disturbed by the operational phase. Lighting 14.11.9 Negative effects may result from the increased levels of lighting associated with the proposed residential buildings and shops and street lighting on the adjacent Lewisham Railway Triangles SINC, onsite and adjacent habitats, including retained trees and created habitats, and species sensitive to such impacts such as bats and birds. Predation 14.11.10 Adverse effects on species such as bats and birds may result from increased predation associated with a potential increase in domestic pets such as cats and dogs.
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Maintenance 14.11.11 Positive effects may result from the ongoing monitoring and appropriate maintenance of the habitat and landscaping areas proposed. 14.11.12 Negative effects may result from inappropriate habitat management.
14.12 Assessment of Likely Significant Effects Demolition and Construction Phase 14.12.1 This section identifies and assesses the scale and nature of the main effects arising from the Proposed Development during the construction phase. Embedded Mitigation Measures 14.12.2 All mitigation described below is embedded mitigation, the requirements of which will be submitted for approval as part of the application. 14.12.3 Losses of habitats on Site have been accounted for in the design of the scheme to provide suitable compensation and enhancement of overall biodiversity value. A BNG assessment has been carried out to ensure a net gain in biodiversity on Site that determined that the proposal would result in an increase of biodiversity value of over 10%. Anticipated Effects Sites of Importance for Nature Conservation (SINC) 14.12.4 Lewisham Railway Triangles is located immediately adjacent to the Site. The integrity of this SINC is dependent on maintaining the extent and presence of habitats and species for which it is designated. As such, this SINC is potentially vulnerable to increases in pollution and disturbance, particularly during the demolition and construction phases where an increase in noise, dust and lighting above the baseline levels could occur. 14.12.5 There would be no effect from overshadowing during demolition, with increases in overshadowing as construction increases in height towards completion, with ongoing shading once the scheme is complete. The increases in overshading to Lewisham Railway Triangles SINC is predicted to be small in area and only present during part of the day, the duration of which would vary due to the changing height of the sun through the year. The existing Lewisham House tower, which is to be retained, is likely to cast shadow on the SINC at certain times of the day and year already. Whilst there is some potential for minor changes to the botanical assemblages of this SINC, these are unlikely and not significant, particularly given that the area of the SINC that would be affected. 14.12.6 As such, in the absence of mitigation the proposals will result in a temporary significant effect on the integrity of the adjacent SINC at the construction stage that is significant at the site level. This equates to a minor negative effect (not significant).
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Peregrine Falcon 14.12.7 The conservation status of peregrine falcon at the Site is dependent on the presence of suitable nesting features and low levels of night-time lighting around the nest location. 14.12.8 Building B2 was surveyed and a male and female observed on separate sides during the surveys, however subsequent communication with the client confirmed a peregrine fledgling was rescued and there were an additional four fledglings observed on building B2, confirming a successful nesting attempt. 14.12.9 Peregrines are known to be inhabitants of urban inner-city sites as the tall height of some buildings emulates their more traditional nesting locations of cliff and rock faces. Demolition and construction would be likely to cause visual and auditory disturbance to prospective breeding birds which could prevent them from continuing to nest on Building B2. In the absence of any mitigation, it is likely that the proposals would result in a temporary negative impact to breeding peregrines which would be significant at local level. This would equate to a minor negative effect (not significant). 14.12.10 Peregrine falcon are protected under Schedule 1 of the Wildlife and Countryside Act 1981 (as amended) making it illegal for any person to intentionally or recklessly disturb any wild bird included in Schedule 1 while it is building a nest or is in, on or near a nest containing eggs or young; or disturb dependent young of such a bird. Demolition and construction works should be timed to be completed outside of the peregrine nesting period (March to August, inclusive). However, if clearance/works during this period are unavoidable then a suitably qualified/experienced ecologist would need to undertake a check of the Site and in particular Building B2 no more than 48hrs (preferably 24hrs) before the works are due to commence, to check for peregrine (or other nesting bird) activity. 14.12.11 The renovation and refurbishment of building B2, would result in the temporary loss of the existing nesting box on site. In the event that the new nesting box is not replaced in the space of a single season, there is a temporary negative impact on the conservation status of nesting peregrines that is significant at the site level. This equates to a minor negative effect (not significant).
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Black Redstart 14.12.12 The conservation status of black redstart at the Site is dependent on the presence of suitable nesting features and low levels of night-time lighting around the nest location. 14.12.13 Building B6 was confirmed to contain an active black redstart nest and buildings within the Site boundaries were considered to provide ample nesting opportunities for the species through provision of suitable holes or internal ledges. Therefore, the Site may support up to a further two breeding pairs of black redstart. 14.12.14 Black redstart has seen significant growth in the Greater London area since first being recorded in Wembley in 1926, however it remains one of Britain’s rarest breeding bird species with an estimated 58 pairs nesting in Britain, and Greater London being the most important UK breeding area for the species21. 14.12.15 Demolition of building B6 will result in the direct loss of a known breeding site and the wider demolition activity across the Site, will result in the loss of most of the viable roosting locations within the Site. Demolition and construction activity would be likely to cause visual and auditory disturbance to prospective breeding birds which could prevent them from wanting to nest on any other buildings located on or within proximity to the Site. 14.12.16 Demolition and construction activity will result in high levels of disturbance to breeding, nesting and foraging black redstart. This will likely result in the loss of breeding success during the construction programme. 14.12.17 In the absence of any mitigation, it is highly likely that the proposals would result in a permanent negative impact to breeding black redstart, which would be significant at the borough level. This would equate to a moderate negative effect (significant). 14.12.18 Black redstart are protected under Schedule 1 of the Wildlife and Countryside Act 1981 (as amended) making it illegal for any person to intentionally or recklessly disturb any wild bird included in Schedule 1 while it is building a nest or is in, on or near a nest containing eggs or young; or disturb dependent young of such a bird. 14.12.19 While the loss of breeding resource is likely within the site, any breeding pairs of black redstart are likely to be able to relocate to similar suitable sites within the local area, however the quality of such sites is unknown. 14.12.20 Due to the loss of the Site as a breeding resource for black redstart, the demolition and construction works will have a permanent negative impact on the conservation status of nesting black redstart that is significant at the borough level. This equates to a moderate negative effect (significant).
21
London Wildlife Trust (date unknown). Black Redstart: Advice for its conservation in London. Available from: black_redstart_advice_note.pdf (lbp.org.uk)
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Invasive Species 14.12.21 The majority of the existing Site is dominated by buildings and hardstanding, however a single small area of ornamental planting was present within the southern extent of the Site. Within this planted area, a species of cotoneaster was present amongst other introduced shrubs. Cotoneasters are notoriously difficult to identify to species level and there are five species of cotoneaster listed on Schedule 9 of the Wildlife and Countryside Act 1981 (as amended). Applying the precautionary principle, the approach was taken to assume that the species of cotoneaster present on Site was one of the invasive Schedule 9 species. 14.12.22 It is an offence to plant or otherwise cause to grow in the wild any plant which is included in Part II of Schedule 9. Therefore, in the absence of any mitigation, it is highly likely that works undertaken to facilitate the demolition and construction phases on site would result in the spread of invasive cotoneaster plants off site. Most obviously this could be through vegetation removal and disposal off site, however cotoneaster could be spread less obviously through berries that adhere to vehicle tyres, tools or the underside of boots. 14.12.23 Cotoneaster plants and the soils in which they have grown on Site should be treated as controlled waste therefore must be disposed of at a licensed landfill. A suitably licensed invasive plant species contractor should be engaged at an early stage to remove the plants, berries and affected soils prior to works beginning on site to prevent the risk of spread of the species to outside the Site boundaries. This not only will help to prevent contravention of the Wildlife and Countryside Act 1981 (as amended), but will also enhance the Site through removal of an invasive non-native species, which will help towards biodiversity net gain. Operational Phase 14.12.24 This section identifies and assesses the scale and nature of the main effects arising from the Proposed Development during the operational phase. Embedded Mitigation Measures 14.12.25 An artificial nest box for peregrine falcon will be installed on a suitable location on the newly refurbished building N3, at the end of the construction period as a replacement for the nesting site lost during the works. This box should continue to be monitored by a suitably qualified ecologist to confirm that it is in use. 14.12.26 The current design of the scheme includes green roofs and solar panels on 0.4ha of the roofing structure. These habitats provide foraging and nesting opportunities for black redstart.
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Anticipated Effects Designated Sites Sites of Importance for Nature Conservation (SINC) 14.12.27 There are 25 SINCs located within 2km of the Site, the closest being Lewisham Railway Triangles located adjacent to the Site, immediately adjacent to the Site. This is a valuable wildlife habitat in the centre of Lewisham and the nature of this SINC being railsides means is does not have any public access. There are not predicted to be any significant effects from potential increased footfall at the SINC as a result of the development, because the SINC is not publicly accessible. Any additional footfall from passing pedestrians along footpaths adjacent to the SINC are also unlikely to result in any significant effect to its integrity not least as the area is already heavily urbanised, with the four-lane Molesworth Road and two-track railway surrounding the SINC. The SINC citation states it to be ‘…an extensive series of low disturbance wildlife habitats and a vital network of green corridors’ and this will remain the case post-development. 14.12.28 As set out in the Demolition and Construction assessment, there will be current levels of shading from the existing buildings on Site, and with Lewisham Tower being retained in the proposals, there will be no change in the current levels of shading from the Tower post-development. There is likely to be additional shading of the SINC from the new buildings on site, however whilst there is potential for some minor changes to the botanical assemblages of the SINC as a result, these are likely to be insignificant, given that the area of the SINC that would be affected comprises deciduous woodland habitat, which is likely already shaded and should be resilient to any increased shading, and the level and duration of shading will change throughout a day and across the year. Therefore, effects arising from increased shading of the SINC are considered likely to be insignificant (not significant). 14.12.29 Molesworth Street, which runs within the western area of Site and is immediately adjacent to the SINC, is already subject to high levels of artificial lighting including street lighting and lighting from passing vehicles. It is likely that there is some light-spill from these existing light sources onto the SINC, which are assumed to remain postdevelopment. 14.12.30 There are not predicted to be any significant effects from potential increased footfall at the SINC as a result of the development, because the SINC is not publicly accessible. Any additional footfall from passing pedestrians along footpaths adjacent to the SINC are also unlikely to result in any significant effect to its integrity not least as the area is already heavily urbanised, with the four-lane Molesworth Road and two-track railway surrounding the SINC. The SINC citation states it to be ‘…an extensive series of low disturbance wildlife habitats and a vital network of green corridors’ and this will remain the case post-development.
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14.12.31 There could be significant effects from increased lighting on the SINC as a result of the development, if the design does not employ a wildlife friendly lighting strategy. Incorporation of measures such as cowls on streetlighting to prevent lightspill onto the SINC should be used, and where any external lighting is used on the western side of new buildings facing the SINC, this should be of a suitable lux and directional so that they light the public/building areas only and have limited (if any) lightspill onto the SINC. With these measures incorporated into the design, it is considered that the integrity of the SINC will be maintained during the operational phase such that effects arising from increased lighting of the SINC are considered likely to be insignificant (not significant). Peregrine falcon 14.12.32 A single pair of peregrine falcon are breeding on the Site. As the Site is a shopping centre in a highly urban area a high level of daily disturbance is already present. Urban peregrine falcons are already habituated to high levels of disturbance found in such a context. As such, it considered that there will be no irreversible significant arising from disturbance to nesting peregrine resulting in negligible effects resulting from the operational phase of the Proposed Development. Black redstart 14.12.33 A single pair of black redstart was recorded as breeding on the Site, and the Site has capacity to support up to a further two pairs. As the Site is a shopping centre in a highly urban area a high level of daily disturbance is already present, however some areas of the Site are currently disused resulting in areas that have lower levels of disturbance (including the location of the active nest). The change of use from commercial to residential, will likely result in a higher level of disturbance than current levels show; reducing roosting opportunity for black redstart, as well as disturbance at different times to the current baseline. 14.12.34 The loss of the existing breeding resource will be partially mitigated through provision of green roofs, which provide some degree of roosting habitat for black redstart. Black redstart are known to have specific breeding requirements and as a result it is likely that there will remain a deficit in suitable breeding habitat on Site for the species. 14.12.35 As such, it considered that without mitigation there will be a negative effect significant at the site level resulting from the operational phase of the Proposed Development, this equates to a minor negative effect (not significant).
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Mitigation General mitigation 14.12.36 All mitigation measure will be detailed in the Construction Environmental Management Plan (CEMP). 14.12.37 Mitigation measures include the appropriate storage of fuels and chemicals to minimise the risk of accidental spillage, and measures to reduce dust and noise. Sources of best construction practice and environmental management include CIRIA guidance22 and various Defra/Environment Agency guidelines23. 14.12.38 Demolition of buildings, and other associated clearance activity including the removal of introduced shrub and scattered trees with potential to support breeding birds, will be carried out September to February inclusive to avoid any potential offences relating to breeding birds during their main bird breeding season24, although it is recognised that some species (e.g. pigeons) may nest year-round and suitable checks must be made to ensure no active nests are present pre-building/vegetation removal at any time of year. Mitigation measures will ensure compliance with Schedule 1 of the WCA25. 14.12.39 No works are planned to be undertaken outside of normal working hours as set out in Chapter 5: Demolition and Construction, and therefore it is unlikely that task lighting will be required. Temporary lighting will be provided in the Site contractor compound for security and safety reasons but will be switched off when not required. The lux levels for security lighting will be kept low to reduce the spread of illumination. All external lighting will be directed towards the Site and away from retained habitats and commuting and foraging features, such as tree lines. Designated sites 14.12.40 Negative effects from air and waterbourne pollution will be avoided through the implementation of the CEMP, as well as works exclusion zones, and controls. In addition, surface water runoff will be strictly controlled and intercepted
22
Connolly, S. & Charles,P (2015) Environmental good practice on site guide. CIRIA, London
23
Defra/Environment Agency. Environment Management Guidance (2016) https://www.gov.uk/government/collections/pollutionprevention-guidance-ppg 24
Newton, J., Nicholson, B., Saunders, R., Willets, R. & Venables, R. (2011) Working with wildlife: guidance for the construction industry (2nd Ed.). CIRIA, London. 25
To include: appropriately timed vegetation clearance which will be predominantly carried out outside of the breeding bird season (March to September, inclusive), nesting bird checks prior to vegetation clearance if it is necessary during the breeding bird season and the use of works exclusion zones around active nests as required.
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Black redstart 14.12.41 Demolition and construction works should be timed to be completed outside of the black redstart nesting period (March to August, inclusive). 14.12.42 In order to mitigate for the loss of suitable breeding sites within the development, consideration should be given to the provision of suitable nesting opportunities within the design of buildings on site. This should include the provision of ledges high up on walls under the eaves. Nest boxes may be used, but they would need to be open fronted, and built directly into the structures, with a maximum density of up to 10 per hectare. 14.12.43 The provision of biodiverse green roofs will provide foraging habitat for black redstart and should be enhanced through the provision of a mosaic of habitats including pioneer vegetation communities that provides the most suitable foraging opportunity for the species. The use of singing posts would provide breeding males the positions required to broadcast from, further encouraging breeding behaviour within the Site. Residual Effects 14.12.44 Following the effective implementation of the embedded mitigation measures proposed above, there are no permanent significant residual effects arising from the Proposed Development during construction or operational phases. Black redstart 14.12.45 Following implementation of the mitigation measures proposed above, there are no permanent significant residual effects on black redstart arising from the Proposed Development during the construction or operational phases.
14.13 Cumulative Effects 14.13.1 This section considers the likely cumulative effects that could arise from the Proposed Development when considered alongside other committed development schemes proximate to the Site. It identifies whether effects from several developments which individually may be insignificant could, when considered together, cause significant cumulative effects requiring mitigation. 14.13.2 A number of committed developments have been identified as being relevant to this assessment. These were identified through a review of LBL’s planning portal and have been agreed with LBL. The schemes to be considered cumulative development as part of the EIA will be those located within a 1km radius of the Site that have the benefit of planning permission, or are reasonably foreseeable (i.e. resolution to grant) and are similar in terms of use, scale and nature 14.13.3 The assessment is based on the best available information and draws on the assessments included in the ES and Application Reports that accompany the development applications, where available.
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Lewisham Retail Park 14.13.4 The comprehensive redevelopment of the Lewisham Retail Park and Nos. 66 & 76 Loampit Vale including the demolition of all buildings on site to facilitate the provision of 4,343sqm of non-residential floorspace comprising (A1) Shops, (A2) Financial & Professional Services, (A3) Restaurants & Cafés, (B1) Business, (D1) Non-Residential Institutions and (D2) Assembly & Leisure uses and 536 residential units in buildings ranging from 4 to 24 storeys in height with private and communal open spaces, on-site energy centre, car and cycle parking, and associated landscaping and public realm works. 14.13.5 An EIA carried out on the proposed site in 2016 concluded that there wouldn’t be any residual construction or operational phase impacts resulting from the scheme on habitats, bats and nesting birds, and no cumulative impacts on any receptors are expected.
14.14 Summary 14.14.1 This chapter presents the findings of an assessment of the likely significant effects of the Proposed Development on terrestrial ecology of the Site and surrounding area. The following section provides a summary of the findings and conclusions of the assessment. Summary of baseline 14.14.2 There are three designated sites within the surrounding of the Site that were considered during the assessment. The nearest European site was Lee Valley Ramsay site located 12.4km east of the Site. The nearest nationally designated site was the Inner Oxleas Woods SSSI located approximately 4.8km east. 14.14.3 The Site was considered to have habitats suitable to support breeding birds and surveys recorded a breeding pair of Schedule 1 peregrine on Site and a breeding pair of black redstart on the Site. 14.14.4 In the light of the baseline conditions, the effects of the Proposed Development on the following ecology receptors was assessed: •
designated sites;
•
peregrine falcon; and
•
black redstart.
14.14.5 The key changes and activities associated with the Proposed Development that are likely to cause terrestrial ecological effects and that were included in the assessment are: •
habitat removal (loss) and disturbance;
•
disturbance to peregrine falcon; and
•
disturbance and loss of habitat for black redstart.
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Table 16.7 summarises the topic effects resulting from the Proposed Development.
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Table 16.7: Summary of Effects DESCRIPTION RECEPTOR SIGNIFICANCE OF EFFECTS OF SIGNIFICANT MAJOR / POSITIVE P D / I ST / EFFECTS MODERATE / / MT / / MINOR / NEGATIV T LT NEGLIGIBLE E Demolition and Construction
SUMMARY OF MITIGATION / ENHANCEMENT MEASURES
SIGNIFICANCE OF RESIDUAL RELEVANT RELEVANT EFFECTS POLICY LEGISLATIO N MAJOR / POSITIV P / D / I ST / MODERATE E / T MT / / MINOR / NEGATIV LT NEGLIGIBLE E
Pollution, noise Lewisham and vibration, Triangle dust SINC Disturbance and Peregrine loss of habitat falcon Disturbance and Black loss of habitat, redstart loss of breeding resource Operation
Negligible
Negative
T I
MT
Negligible
N/A
N/A N/A N/A
Moderate
Negative
T D
MT
Negligible
N/A
N/A N/A N/A
Moderate
Negative
P D
LT
Construction Environmental Management Plan Replacement of nesting provision Alternative nesting provision
Negligible
N/A
N/A N/A N/A
Lighting, recreational pressure, shading Disturbance, loss of foraging and nesting habitat
Lewisham Triangle SINC
Negligible
Negative
P D
LT
None
Negligible
N/A
N/A N/A N/A
Black redstart
Minor
Negative
P D
LT
Alternative roosting provision, installation of green roof
Negligible
N/A
N/A N/A N/A
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15.0 References CIEEM. (2018). Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial, Freshwater and Coastal, 2nd edition. Chartered Institute of Ecology and Environmental Management, Winchester. Greater London Authority (GLA). (2021). The London Plan: The Spatial Development Strategy for Greater London. https://www.london.gov.uk/sites/default/files/the_london_plan_2021.pdf Lewisham Biodiversity Partnership. (2021). A Natural Renaissance for Lewisham (2021-2026). Available from: Lewisham Council - Biodiversity in Lewisham Lewisham Council. (2011). Core Strategy: Development plan document. Available from: Lewisham Council - About our core strategy for the Local Development Framework Lewisham Council. (2014a). Development Management Local Plan. Available from: Lewisham Council - Development policy documents Lewisham Council. (2014b). Lewisham town centre local plan. Available from: Lewisham Council Lewisham town centre local plan documents London Borough of Lewisham. (2023). Lewisham Local Plan – Proposed submission document – Regulation 19 stage. Available from: https://lewisham.gov.uk/-/media/lewishan-local-plandocument_accessible_rev01.ashx?la=en Stanbury et al. (2021). Birds of Conservation Concern 5: the population status of birds in the UK, Channel Islands and Isle of Man. British Birds 114 pp. 723-747. British Birds Rarities Committee.
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15.0 Socio-economics 15.1 Introduction 15.1.1
This chapter of the ES was prepared by Quod and presents an assessment of the likely effects of the Proposed Development on socio-economics.
15.1.2
This chapter provides a description of the methods used in the assessment, a description of the relevant baseline conditions of the Site and surrounding area, an assessment of the likely effects of the Proposed Development during the Site preparation, demolition and construction works and once it is completed and operational.
15.1.3
Mitigation or enhancement measures have been identified, where appropriate, to avoid, reduce or offset any significant negative effects identified and/or enhance likely positive effects. The nature and significance of the likely residual effects are reported.
15.1.4
The socio-economic effects considered in this Chapter include the following: • • • • • • •
15.1.5
Generation of temporary employment during the demolition and construction phase; Loss of existing employment on-site through demolition of existing buildings; Potential disruption to surrounding businesses; Creation of permanent employment opportunities in the end uses; Delivery of new homes; Generation of demand for community infrastructure by the residential population living in new homes, specifically that for education, primary healthcare and open space and play space; and Local economic effects associated with spending by new residents and employees. This Chapter should be read together with the Introductory Chapters of this ES (Chapters 1 – 5), as well as Chapter 17: Effect Interactions.
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Competence 15.1.6
This assessment was undertaken by Joshua Skyers who has been part of Quod’s socioeconomic team for four years following completion of a degree in BSc Economics from University of Southampton.
15.1.7
The chapter has been reviewed by Barney Stringer, a Senior Director at Quod. Barney has 20 years of experience leading on Socio-Economic Impact Assessment of large and complex developments across the UK, including large scale residential-led and town centre regeneration. His education background includes a Joint Honours BSc, Politics MSc and an Economics Postgraduate Degree (PGCert).
15.2 Legislation, Planning Policy and Guidance 15.2.1
The following national, regional and local planning policy and guidance are relevant to the assessment of the effects of the Proposed Development in relation to socioeconomics and have been used to inform the professional judgements made in this Chapter.
Planning Policy Context National 15.2.2
The following national level policy and guidance documents are relevant to the Proposed Development: National Planning Policy Framework (2023) (Ref 15.1) • • • •
Presumption in favour of sustainable development; Chapter 5 ‘Delivering a sufficient supply of homes’; Chapter 6 ‘Building a strong, competitive economy’; and Chapter 8 ‘Promoting healthy and safe communities’
Regional London Plan 2021(Ref 15.2) • • • • • • • • • • • •
Policy GG1: Building strong and inclusive communities; Policy GG2: Making the best use of land; Policy GG4: Delivering the homes Londoners need; Policy GG5: Growing a good economy; Policy SD6: Town centres and high streets; Policy H1: Increasing housing supply; Policy S2: Health and social care facilities; Policy S3: Education and childcare facilities; and Policy S4: Play and informal recreation; Policy E2: Providing suitable business space; Policy E11; Skills and opportunities for all; and, Policy HC5: Supporting London’s culture and creative industries.
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Local London Borough of Lewisham: Core Strategy (2011) (Ref 15.3) • • • • • •
Spatial Policy 2: Regeneration and Growth Areas; Core Strategy Policy 1: Housing provision, mix and affordability; Core Strategy Policy 3: Mixed Use Employment Locations; Core Strategy Policy 6: Retail hierarchy and location of retail development; Core Strategy Policy 12: Open space and environmental assets; and Core Strategy Policy 19: Provision and maintenance of community and recreational facilities
Lewisham Town Centre Local Plan (2014) (Ref 15.4) •
Policy LTC8: Lewisham Central Policy Area
Lewisham Development Management Local Plan (2014) (Ref 15.5) • • • • • • • •
DM Policy 1: Presumption in favour of sustainable development; DM Policy 7: Affordable rented housing; DM Policy 8: Student housing; DM Policy 9: Mixed use employment locations; DM Policy 13: Location of main town centre uses; DM Policy 17: Restaurants and cafes; DM Policy 41: Innovative community facility provision; and DM Policy 43: Arts, culture and entertainment facilities
Draft Lewisham Local Plan (Regulation 19 stage) (2023) (Ref 15.6) • • • • • • • • • • • • • • • • • • • • •
Policy QD1: Delivering high quality design in Lewisham; Policy QD2: Inclusive and safe design; Policy QD3: Public realm and connecting places; Policy HO1: Meeting Lewisham’s housing needs; Policy HO3: Genuinely affordable housing; Policy HO7: Purpose built student accommodation; Policy HO8: Housing with shared facilities (Houses in Multiple Occupation); Policy EC1: A thriving and inclusive local economy; Policy EC2: Protecting employment land and delivering new workspace; Policy EC3: High quality employment areas and workspace; Policy EC7: Mixed-use Employment Locations (MEL); Policy EC11: Town centres at the heart of communities; Policy EC12: Town centre network and hierarchy; Policy EC13: Optimising the use of town centre land and floorspace; Policy EC14: Major and District Centres; Policy CI2: High quality community infrastructure; Policy CI3: Sports, recreation and play; Policy GR1: Green infrastructure and Lewisham’s Green Grid; Policy GR2: Open Space; Policy GR4: Lewisham Links; Policy LCA1: Central Area place principles; and
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•
Policy LCA2: Lewisham major centre and surrounds.
Guidance • • • •
Planning Practice Guidance (live document) (Ref 15.7); GLA Shaping Neighbourhoods: Play and Informal Recreation SPG (2012) (Ref 15.8); Greater London Authority (GLA) Social Infrastructure Supplementary Planning Guidance (SPG) (2015) (Ref 15.10); Homes and Communities Agency (HCA) Employment Density Guide – 3rd edition (2015) (Ref 15.11);
15.3 Consultation 15.3.1
As discussed in Chapter 2: Approach to Assessment, consideration has been given to the formal EIA Scoping Opinion provided by LBL and consultees and any additional consultation that may have occurred during the design period of the Proposed Development.
15.3.2
An EIA Scoping Report was issued to LBL in January 2024 (Appendix 2.1). LBL’s formal Scoping Opinion was issued in June 2024 (Appendix 2.2).
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Table 15.1: Consultation Feedback Consultee
Comment
Where is this addressed?
London Borough of Lewisham
It is suggested that the Applicant provides the evidence sources that have informed their decisions for selecting certain study areas and their sensitivity to potential construction and operation works. This should include a map and appropriate descriptors.
This is covered in the ‘Extent of The Study Area’ of this Chapter which outlines the study areas used and why these areas have been used, especially in relation to social infrastructure demand.
London Borough of Lewisham
The ES should clearly set out how all figures have been calculated (e.g. employment generation) and justified as appropriate, with reference to other relevant documents/aspect chapters where appropriate and ensure this represents the worstcase scenario.
This is covered Section 15.10 ‘Assessment of Effects, Mitigation and Residual Effects’ which outlines how both construction jobs and operational jobs will be generated. We have been able to calculate the likely worst-case employment scenarios by using likely worst-case employment densities as per the HCA Employment Density Guide (Ref 15.10) and applying professional judgment to the assessment by types of uses in their context.
The Scoping Report states that effects on the capacity of dentists, nurseries, leisure and other community facilities will be scoped out of the ES. This has been appropriately justified as the usage of such facilities varies amongst the population. However, as stated by the NHS HUDU consultation feedback, potential effects on secondary NHS capital (such as hospitals) should be considered with the ES, alongside primary healthcare infrastructure (such as GPs). It is advised that further consultation is sought with NHS HUDU to establish an agreed methodology.
The approach applied in the assessment of primary healthcare is an industry standard approach in line with that applied in the HUDU model.
London Borough of Lewisham
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Non-primary care (such as hospitals) is planned, funded and delivered at a strategic level, and not a Site level. Such infrastructure is not site-specific mitigation for a development of this scale and this is therefore not scoped into this assessment.
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15.4 Assessment Methodology and Significance Criteria 15.4.1
The following section outlines the methodologies applied to identify and assess the potential impacts and likely effects to result from the Proposed Development. Scope of the Assessment
15.4.2
The following potential effects were scoped into the assessment: • • • • • • •
Loss of existing employment on-site through demolition of existing buildings; Impact on existing businesses accommodated on-site; Generation of temporary employment during the demolition and construction phase; Creation of permanent employment opportunities in the end-uses; Delivery of new homes; Generation of demand for community infrastructure by the new residential population, specifically education, primary healthcare, and open space / play space; and Local economic effects associated with spending by new residents and employees.
Extent of The Study Area 15.4.3
The study area and assessment areas used within this chapter are as follows: • • • •
The Site (where data / information is available) – as defined by the red line boundary; Local – Lewisham Central and Blackheath (Lewisham) wards1; Borough – London Borough of Lewisham (LBL); and Region – London
1
The definition of these wards changed in 2022, we have used this most recent definition where available. Where not available i.e. BRES, we have used an LSOA best fit.
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15.4.4
Figure 15.1 shows the local extent of the Site, highlighting the Local Area, the Borough (LBL) and the Region.
Figure 15.1: Context Map
15.4.5
The study area for the social infrastructure baseline is based on reasonable travel distances relevant to specific types of facility as follows: • • •
Primary education and healthcare provision have been assessed within 1km from the Site boundary as this is a reasonable walking distance (approximately 10-15 minute walk) (Ref 15.9); To allow for pupil choice and in recognition that older students are more willing and able to travel further to school, secondary education (for academic years 7 to 11) has been assessed at a Borough-wide level (LBL); and Existing open space and playspace has been assessed within 800m of the Site boundary in line with GLA Guidance (Play and Informal Recreation SPG 2012) (Ref 15.10).
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15.4.6
The sensitivity of the existing socio-economic baseline conditions varies at different spatial levels. Table 15.2 lists the relevant socio-economic receptors and the spatial levels at which each is likely to be sensitive to effects of the Proposed Development.
Table 15.2: Spatial Sensitivity of Socio-Economic Conditions Receptor
Spatial Level
Existing employees
Site, Local Area, LBL
Existing local businesses
Site, Local Area, LBL
Construction industry and its employees
Regional
Labour Market (employment effects)
Local Area, LBL
Housing Market
LBL
Primary Education
Local (1km radius)
Secondary Education
LBL
Healthcare
Local (1km radius)
Open Space and Playspace
Site, Local (800m radius)
Additional Spending
Local Area, LBL
Method of Baseline Collection 15.4.7
Baseline socio-economic conditions that are of relevance to this assessment have been established through analysis of nationally recognised research, survey information, and datasets including: • • • • • • • •
Census data (2011) (Ref 15.12) and (2021) (Ref 15.13); Claimant count data (2024) (Ref 15.14); Business Register and Employment Survey (BRES) (2022) (Ref 15.15); Index of Multiple Deprivation (IMD) (2019) (Ref 15.16); GLA Residential Completions Dashboard (Ref 15.17); Schools, pupils and their characteristics (2024) (Ref 15.18) and information from Lewisham schools published admissions documents (Ref 15.19) Open space and playspace from Ordnance Survey and Sport England data, supplemented by local knowledge and desk-based research to identify existing open space and play space provision. ONS (2019) Population Estimates (Ref 15.20);
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Method of Assessment Demolition & Construction Phase Loss of existing employment on-site 15.4.8
Where known, direct business-level data has been used to inform existing employment levels on-site, made available either through the Applicant or surveys of the retailers. Where actual employment numbers are not known, employment densities have been applied to the existing floorspace areas to estimate existing employment capacity of the Site. These densities are based on survey data for similar space on-site, or where equivalent data was not available the Homes and Communities Agency (HCA) Employment Density Guide (3rd edition) (Ref 15.11). This approach has been adopted to better reflect that the actual number of jobs on-site now, which is influenced by the age, efficiency and quality of the current space, and may be different to typical job densities expected in modern newly-built floorspace.. Demolition and construction employment
15.4.9
Demolition and construction related employment from the Proposed Development has been calculated using the Construction Industry Training Board (CITB) Labour Forecasting Tool (Ref 15.21). This calculates the person years of construction employment required to deliver it based on the construction type and scale, from which Quod has estimated an average for the number of full-time equivalent (FTE) jobs over the duration of the construction phase. Operational Phase Housing Delivery and Population
15.4.10
Delivery of housing has been assessed against policy targets for the LBL set out in Chapter 4 of the London Plan (Ref 15.2), with the annual housing target currently being 1,667 homes per year.
15.4.11
Co-living homes and student accommodation are assessed against housing need based on a ratio of 1.8:1 (1.8 co-living homes equating to 1 standard home) and 2.5:1 (two and a half bedrooms being counted as a 1 standard home) respectively (Ref 15.2).
15.4.12
The estimated resident population has been calculated using the GLA’s Population Yield Calculator (Ref 15.22) based on housing size and tenure.
15.4.13
For co-living the population yield is 1.25 per home – this assumes that for every four coliving homes provided one is occupied by a couple and three accommodate one person. For student accommodation the population yield is one person per bed.
15.4.14
The estimated child yield of the Proposed Development has been calculated using GLA’s Population Yield Calculator (Ref 15.22) for primary (5 to 11 year olds) and secondary (12 to 16 year olds) age profiles. It is assumed that no child yield from any proposed Student Housing or co-living spaces, reflecting the size and tenure arrangements of those homes.
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Demand for Social Infrastructure An audit of existing community facilities has been set out in the ‘Baseline Conditions’ section of this ES chapter. Assessment of demand is based on the following:
15.4.15 • •
•
State-Funded Education Facilities: additional demand for school places (modelled as set out in Paragraph 15.4.14) is considered against existing capacity of schools within the relevant study areas. Primary Healthcare Facilities (General Practitioner (GP) surgeries): The number of people expected to live on-site is modelled in line with Paragraphs 15.4.12-13 above. This figure was then benchmarked against the baseline position of the capacity of local NHS GP facilities using the London average of 2,058 registered patients per FTE NHS GP. The net additional demand arising from the total population of the Proposed Development has been assessed using this benchmark and in the context of existing surplus or deficit within 1km. Open Space and Playspace: the population and number of children expected to live on-site was established as set out in Paragraphs 15.4.13-15 above. Demand for open space and playspace has been assessed against regional standards of open space and play space provision and is considered in the context of the proposed provision on-site and existing spaces within the area.
Employment Creation 15.4.16
The number of jobs that are likely to be accommodated by the proposed non-residential floorspace on-site has been estimated based using the following employment densities based on a combination of the HCA Employment Density Guide and professional experience: • • • •
Town Centre and Flexible Commercial Uses (Class E (a, b, c, d, e, f; g (i, ii)): between one FTE employee per 20 to 10 sqm NIA; Community and Cultural Uses (Class F.1; F.2): one FTE employee per 50 to 165 sqm GIA; Co-Living (Sui Generis): 1 job per 10 to 15 beds; and Student Accommodation (Sui Generis): 1 job per 50 student bed spaces.
Local expenditure by households and employees 15.4.17
An assessment of the level of spending likely to occur once the Proposed Development is operational, and the impact of the additional expenditure on the local economy, has also been carried out. This includes an assessment of: •
•
Household expenditure generated by the new households living within new homes who may buy goods and services locally: This was based on the average household expenditure of £210 per week for London (adjusted for non-local spending) (ONS Family Spending Survey 2023) (Ref 15.23); 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 2023 assuming average occupancy of co-living homes of 1.25 (assuming one home in every four occupied by two people);
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• •
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 inflation (Ref 15.24) . Local expenditure by net additional employees. An average spend per day of £14.19 per employee has been applied, based on survey information carried out by research agency Loudhouse for Visa Europe (2014) (Ref 15.25) and adjusted to account for inflation (Ref 15.26) .
Outline planning application methodologies 15.4.18
This is a Hybrid Application, with some elements of the Application in detail and some elements of the Application in outline.
15.4.19
The exact amount and mix of development for the outline element of the Application will be determined through Reserved Matter Applications (RMAs). At the outline stage maximum floorspace parameters have been set for the non-residential uses; a maximum home number and maximum floorspace parameter has been set for the residential uses; and a range of residential home types and tenures have been provided deliverable within that Parameter (refer to Chapter 4: The Proposed Development). For the outline element, for the purpose of this socio-economic assessment, the reasonable ‘worst case’ has been assessed. This depends on the relevant receptor, as set out below: • •
•
For housing delivery and residential expenditure, the reasonable ‘worst case’ is the indicative residential (1,524 homes) and student accommodation (630 rooms) development scenario. For population yield and its associated impacts (demand for education, healthcare and playspace), the reasonable ‘worst case’ has been based on the maximum residential development scenario (up to 1,600 homes) and the maximum student accommodation scenario (up to 661 rooms). For employment generation and employee expenditure, the reasonable ‘worst case’ has been based on the indicative non-residential floorspace scenario. Where a use class covers a range of types of uses, the one generating the smallest number of employees has been assessed.
Cumulative effects 15.4.20
Cumulative effects were assessed using information from extant planning permissions and planning applications that are yet to be determined for the cumulative schemes. The cumulative assessment considers the cumulative schemes as set out in the Lewisham Shopping Centre EIA Scoping Report and the Lewisham Market Application, which was submitted after the scoping was finalised.
15.4.21
Where relevant information was not available, either through the planning application documents or through policy documents, professional judgement was applied to identify the likely effects of the identified cumulative schemes.
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Determining Effect Significance 15.4.22
There is no published or formalised technical guidance or criteria available relating to the assessment of socio-economic effects. Industry standard best practice, professional judgement and experience
15.4.23
The most recent published data sources have been used in this assessment. However, as with any dataset, the information can only ever provide a snapshot in time and may not reflect the current baseline conditions as they exist today although changes that may have occurred in the interim are not likely to materially affect the conclusions of this assessment.
Sensitivity of Receptor 15.4.24
Receptor sensitivity in this assessment is based on a receptor’s prevailing capacity to respond to changes, which is influenced by its baseline and the speed with which changes could be absorbed. For example, an area with high unemployment, historic under-delivery of housing, or where access to social infrastructure is limited or will only be able to respond to changes in demand slowly will have higher sensitivity to socioeconomic effects. Receptor sensitivity is based on a scale of: •
• •
High: above average levels of socio-economic deprivation (for example, unemployment, economic inactivity, no qualifications, low skill levels), severe/historic under-delivery of housing, or social infrastructure at the relevant spatial level with no surplus capacity; Medium: average levels of socio-economic deprivation (for example, unemployment, economic inactivity, no qualifications, low skill levels), slight and/or sporadic underdelivery of housing, or social infrastructure operating close to or with limited capacity. Low: below average levels of socio-economic deprivation (for example, unemployment, economic inactivity, no qualifications, low skill levels), good housing delivery rates (e.g. in line or above policy targets), or social infrastructure with surplus capacity.
Magnitude of Impact 15.4.25
The assessment of the magnitude of the socio-economic impact has been quantified where possible and, where not possible, an objective qualitative assessment has been made. The magnitude of impact has been based on a scale of: • • • •
High: substantial change to one or more of the socio-economic receptors; Medium: noticeable change to one or more of the socio-economic receptors; Low: hardly perceptible change to one or more of the socio-economic receptors; and Negligible: no perceptible change to one or more of the socio-economic receptors.
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Effect Duration 15.4.26
Effects generated as a result of the demolition and construction works (i.e. those that last for this set period of time) are classed as ‘temporary’. The enabling, demolition and construction stage would occur over ten years and as such some effects may be temporary but long term. Effects that result from the completed and operational Proposed Development are classed as ‘permanent’ effects.
15.5 Significance Criteria Assessing Significance 15.5.1
Table 15.3 sets out the criteria for determining the significance of effects. The matrix below includes a degree of flexibility that can be used when considering the magnitude of an impact in the context of the sensitivity of the receptor. Site/context specific experience have been applied to make that judgment.
Table 15.3: Socio-Economic Matrix to Determine Significance of Effect Receptor Sensitivity
Magnitude of Impact High
Medium
Low
Negligible
High
Major
Major or Moderate
Moderate or Minor
Negligible
Medium
Major or Moderate
Moderate or Minor
Minor or Negligible
Negligible
Low
Moderate or Minor
Minor or Negligible
Negligible
Negligible
Negligible
Negligible
Negligible
Negligible
Negligible
15.5.2
Effects classified as moderate or major in scale are considered ‘significant’. Effects classified as minor or negligible in scale are considered ‘not significant’.
15.5.3
Following identification of the scale and nature of the likely effects, the requirement for mitigation to either eliminate or reduce any adverse effects, has been considered. Effects after mitigation or enhancement (assuming this form part of the Proposed Development) are presented as Residual Effects. Assessment of significance
15.5.4
The following terms have been used to define the significance of effects identified:
• Major positive or negative effect – where the Proposed Development would cause a large improvement (or deterioration) to the existing environment; Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 15: Socio-economics
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• Moderate positive or negative effect – where the Proposed Development would cause • •
a noticeable improvement (or deterioration) to the existing environment; Minor positive or negative effect – where the Proposed Development would cause a small improvement (or deterioration) to the existing environment; and Negligible – no discernible improvement or deterioration to the existing environment as a result of the development will occur.
15.6 Assumptions and Limitations 15.6.1
The Proposed Development and cumulative effects have assessed against a current baseline. This approach differs to that adopted in other chapters of the ES where a future baseline may be used. In a socio-economic context, there are many unknowns associated with trying to assess population and employment impacts against a future baseline. The current baseline (as far as this can be established using the most up to date datasets), therefore, represents a reasonable indicator against which to assess the impacts of development. As with any dataset, baseline data will change over time. The most recent published data sources were used in this assessment, but some data may be older than the true baseline (i.e. 2024).
15.6.2
The 2021 Census (Ref 15.13) was undertaken in March 2021, during the Covid-19 pandemic and therefore affected by the impacts of the pandemic. This is an unavoidable limitation that, in this context, is not likely to materially affect the assessment or conclusion.
15.6.3
In relation to the assessment of primary healthcare – for NHS GPs, residents usually register with a GP within the catchment area of where they live. Changes in the rules around GP registrations means that people can put a case forward to register with a GP outside of their catchment area. However, this is relatively rare, therefore assuming new residents will register close to their home is considered to be worst case in terms of the assessment.
15.7 Baseline Conditions The Site 15.7.1
The Site is in Lewisham Central ward, close to Blackheath Ward. The shopping centre is home to a range of occupiers, including larger retailers alongside smaller units.
15.7.2
Lewisham Shopping Centre is the core of the Lewisham Town Centre, which is the largest town centre within the Borough (Ref 15.6) and is a key focal point, serving a diverse catchment of residents.
15.7.3
The centre also benefits from very good public transport accessibility – it has a Public Transport Accessibility Level of 6b, which is the highest level - and is well connected to both Central London and Kent. As stated in the Draft Local Plan (Ref 15.6), the centre is currently undergoing significant transformation aiming to becoming a metropolitan centre.
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15.7.4
Within the Shopping Centre, there are 52 leased retail units, including shops and other smaller kiosks. There are five food and beverage units, and three units used for community & culture, which include the Bank of Things, the Migration Museum and the Toy Library. In addition to the shopping centre, the Site also includes retail units along the high street. It is estimated that there are c. 1,000 FTE employees currently located within the redline boundary, of which c.690 are located within employment floorspace to be demolished at the Site. Demographic Baseline
15.7.5
In 2021 the resident population of the Local Area was 24,600, with the majority of people located in Blackheath ward (16,400).
15.7.6
A high proportion of Local Area residents (80%) are of working age. This is greater than LBL (76%) and the London (75%). Children aged 16 and under accounted for 16% of the Local Area population, lower than proportions across LBL and London (both 19%). A summary of the demographic baseline is set out in Table 15.4.
Table 15.4: Demographic Baseline Summary Indicator
Lewisham Central
Blackheath (Lewisham)
Local Area
LBL
London
Population Total, 2011 (people)
-
-
-
276,000
8,170,000
Total, 2021 (people)
8,200
16,400
24,600
301,000
8,800,000
-
-
-
9%
8%
0-15 years (%)
14%
17%
16%
19%
19%
16-74 years (%)
84%
78%
80%
76%
75%
75 years or above (%)
2%
5%
4%
4%
5%
Growth (20112021) (%) Age structure: 2021 Census
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Labour Market and Employment Baseline 15.7.7
In 2021 the economic activity rate within the Local Area was 77%, which is greater than Lewisham (70%) and London (66%). The Local Area unemployment rate was 9.6%, higher than unemployment rates in Lewisham (8.2%) and London (7.3%).
15.7.8
Claimant count data provides the more recent information on the number of people claiming unemployment-related benefits, which includes Jobseekers’ Allowance and Universal Credit. The count is calculated for all working age residents aged between 16 and 64 years. This dataset is unable to capture all unemployed individuals as some local residents may not claim these benefits or may be ineligible.
15.7.9
In July 2024 the claimant count rate within the Local Area (6.4%) was lower than the rate In Lewisham (7%), but higher than the proportion in London (6%).
15.7.10
The Local Area has a higher proportion of people above the age of 16 with higher education qualifications (59%) when compared to Lewisham (50%) and London (47%). The proportion of people with no formal qualifications was lower in the Local Area (11%) when compared to LBL and London (at 15% and 16%, respectively).
15.7.11
Analysis of the occupation profile of the different geographic areas shows that areas with higher rates of qualification attainment also had a higher proportion of employed working age residents in managerial, technical or professional jobs2. Approximately 66% of the Local Area’s employed population had managerial, technical or professional jobs compared to proportions of 57% and 56% in LBL and London, respectively. The proportion of residents with sales, process or elementary jobs3 was lower in the Local Area (14%) when compared the Borough (20%) and regional (21%) levels.
2
Defined as the following occupations: Managers, directors, and senior officials; professional occupations; and associate professions, and technical occupations. 3
Defined as: Sales and Customer Service Occupations; Process Plant and Machine Operatives; Elementary Occupations
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Local Economy 15.7.12
In 2022 there were 11,300 jobs in the Local Area, 71,800 in LBL and 5,720,000 in London.
15.7.13
The largest employment sector (that is people who work in the area, including those who may live elsewhere) in the Local Area is ‘Retail’ which accounts for 18% of jobs. This was higher than proportions in LBL (11%) and London (8%).
15.7.14
‘Health’ is the second largest employment sector within the Local Area, accounting for 17% of all jobs in the area, which is higher than the proportion at the regional level (10%) but lower than the proportion at the LBL level (19%).
15.7.15
The employment profile of the Local Area in comparison to LBL and London is shown in more detail in the Labour Market and Economy summary table (Table 15.5).
15.7.16
The construction workforce is highly mobile, with workers frequently travelling regionally (and sometimes nationally and internationally) to fill vacancies. Therefore, the construction economy is best considered at a higher spatial level. According to the latest Construction Industry Training Board Labour Market Intelligence report for the London (Ref 15.27), there were c.411,000 construction jobs.
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Table 15.5: Labour Market and Employment Baseline Indicator
Lewisham Central
Blackheath (Lewisham)
Local Area
LBL
London
Economic activity (residents aged 16-74 years), 2011 Total number of working age residents
6,900
12,800
19,700
229,900
6,636,000
Economically active (%)
77%
71%
77%
70%
66%
Unemployed (%)
9.6%
7.6%
9.6%
8.2%
7.3%
Claimant count (residents aged 16-64) (July 2024)* Total Claimants
-
-
1,090
14,985
361,965
Claimant Rate
-
-
5.6%
7.0%
6.0%
Highest level of qualification (residents aged 16 years and above), 2021 No formal qualifications (%)
10%
12%
11%
15%
16%
GCSE/A-Levels (or equivalent) (%)
26%
28%
27%
33%
34%
Further of Higher Education (%)
61%
58%
59%
50%
47%
Other qualifications (%)
3%
2%
2%
3%
3%
Occupation (residents aged 16 – 74 years in employment), 2021
Managerial / Technical/ Professional** (%)
65%
67%
66%
57%
56%
Administrative /Trade/ Services***(%)
20%
19%
19%
23%
24%
Sales/ Process/ Elementary**** (%)
16%
14%
14%
20%
21%
Key Employment Sectors (jobs)*
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Total Jobs
-
-
17,000
71,700
5,720,000
Retail
-
-
2,050 (18%)
8,000 (11%)
439,500 (8%)
Health
-
-
1,925 (17%)
13,500 (19%)
589,000 (7%)
Accommodation & food services
-
-
1,315 (12%)
8,500 (12%)
490,000 (9%)
Note: Figures may not sum due to rounding. Sources: Census 2021, BRES 2022, ONS 2024 *When looking at BRES and Claimant Count data, we have used a best fit area of 2021 census wards using 2011 lower-super output areas. ** - defined as: Managers, Directors and Senior Officials; Professional Occupations; Associate Professional and Technical Occupations *** - defined as: Administrative and Secretarial Occupations; Skilled Trades Occupations; Caring, Leisure and Other Service Occupations **** - defined as: Sales and Customer Service Occupations; Process Plant and Machine Operatives; Elementary Occupations ^ - Degree (e.g. BA, BSc), Higher Degree (e.g. MA, PhD, PGCE), NVQ Level 4-5, HNC, HND, RSA Higher Diploma, BTEC Higher Level, Foundation degree
Deprivation 15.7.17
The Government’s Index of Multiple Deprivation (IMD) (2019) (Ref 15.16) measures deprivation in England by combining social, environmental, economic, and housing indicators to produce a single deprivation score for lower-layer super output areas (LSOAs). Areas are then ranked relative to other areas according to their score.
15.7.18
The seven domains used in the Index of Multiple Deprivation are: • • • • • • •
Income; Employment; Education, skills and training; Health deprivation and disability; Crime; Barriers to housing and services; and Living environment.
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15.7.19
Figure 15.2 shows that part the Site is within an area that is amongst the 20% most deprived in the country, with this deprivation being driven by living environment deprivation, barriers to housing and services and high levels of crime.
15.7.20
LBL has multiple neighbourhoods in the top 30% most deprived in England.
Figure 15.2: Index of Multiple Deprivation
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Housing Baseline 15.7.21
As of the 2021 Census, there were 11,190 households within the Local Area. The housing stock of the Local Area is comprised of 76% flats and 24% houses, with the proportion of flats in the Local Area exceeding proportions at the Borough (58%) and regional (54%) levels.
15.7.22
The largest tenure type in the Local Area is private rented, accounting for 37% of households, which is higher than proportions in the LBL (27%) and London (30%). The Local Area has a lower proportion of social rented households (26%) than LBL (29%), but a higher proportion when compared to London (23%).
15.7.23
Overcrowding is defined by the ONS as households that do not have enough bedrooms for the number of people living in that household and their characteristics and relationships (including age and sex). Households with a rating of -1 or lower are classified as being overcrowded. 2021 Census data suggests that 9% of all Local Area households are overcrowded, which is lower than rates in LBL and London (both at 11%). Out of all tenure types in the Local Area, overcrowding is significantly higher in privately rented households, with 14% of all households within this tenure being overcrowded. A summary of the housing baseline is presented in Table 15.6.
Table 15.6: Housing Summary Indicator Total Number of Households, 2021
Lewisham Blackheath Local Central (Lewisham) Area 3,800
LBL
7,390
11,190
London
122,000 3,420,000
Accommodation Type, Census 2021 Flats
86%
72%
76%
58%
54%
Houses
14%
28%
24%
42%
46%
Accommodation Tenure, Census 2021 Owner Occupied
25%
39%
34%
42%
45%
Shared Ownership
4%
2%
3%
2%
2%
Social Rented
22%
28%
26%
29%
23%
Private Rented
48%
31%
37%
27%
30%
Levels of Over-crowding (bedrooms, occupancy rating of -1 or lower), 2021 All Tenures
10%
8%
9%
11%
11%
Owner-Occupied
6%
3%
3%
4%
4%
Privately Rented
16%
13%
14%
19%
19%
Social Rented
10%
9%
10%
15%
15%
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15.7.24
The government recognises that the country is facing a national housing shortage and that an increase in the rate of house building is required to address this.
15.7.25
The London Plan (2021) sets out ten-year housing targets for each London borough. It has set the LBL a minimum target of 16,670 to be delivered over the plan period (1,667 per year).
15.7.26
The GLA Residential Completions Dashboard (Ref 15.17) sets out the net annual housing completions to monitor Borough performance against the targets set in the London Plan. Figure 15.3 sets out the LBL housing delivery performance for the last five years against the relevant London Plan target. This demonstrates that LBL met its housing target in 2018/19, but has failed to meet its housing delivery target since then.
Figure 15.3: LBL Housing Delivery against London Plan Targets
2,000 1,800
Net dwellings completed
1,600 1,400 1,200 1,000 800 600 400 200 0 2018/19
2019/20
Total Net Completions
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2020/21 Year
2021/22
2022/23
London Plan Target
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Primary Education 15.7.27
The latest Annual Schools Census published by the Department of Education provides detailed data on all schools in England and the number of pupils on roll in January 2024 (Ref 15.18).
15.7.28
All Local Authorities have a statutory duty to ensure that there are sufficient state-funded school places to cater for demand from local residents.
15.7.29
There are six schools providing primary education (including two all through schools) within 1km of the Site as shown in Figure 15.4.
15.7.30
According to the latest Schools Census data and Published Admission Numbers (PANs), the current combined surplus capacity of these six primary schools is 316 places, which is equivalent to 17%. Details of existing primary school capacity is set out in Table 15.7.
15.7.31
The closest primary school is St Saviour’s Catholic Primary School which is 100m east of the Site. This school has a surplus capacity of 6 places, equating to 3% of capacity.
Figure 15.4: Primary Schools within 1km of the Site
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15.7.32
St Matthew Academy has the highest surplus capacity for primary education, with more than half (55%) of the schools current capacity being unfilled. During 2017/18 and 2022/23, the number on roll each year was equal to half of agreed PAN or less. As a result of this, the PAN reduced from 60 to 30 in September 2023. This school is due to reach its new lower capacity of 210 in September 2029.
Table 15.7: Existing Primary School Capacity within 1km of the Site Map Ref.
Borough School Name
PAN Capacity Number on (2023/24) Roll (NOR)
Surplus
1
LBL
St Saviour's Catholic
30
210
204
6 (3%)
2
LBL
St Mary's Lewisham CofE
30
210
201
9 (4%)
3
RBG
Morden Mount
60
420
369
51 (12%)
4
LBL
Prendergast Vale
30
210
193
17 (8%)
5
LBL
Trinity CofE
60
420
400
20 (5%)
6
LBL
St Matthew Academy
30
390
177
213 (55%)
1,860
1,544
316 (17%)
Total
15.7.33
LBL’s Infrastructure Delivery Plan (IDP) (October 2023) (Ref 15.30) states that, as a general principle, the Council seeks to maintain a 3% surplus in school place to accommodate mid-year admissions and facilitate parental choice. Revised forecasting suggests that no further primary school places should be required through to 2025 and the Council will work to bring the surplus places closer to 3%.
15.7.34
LBL’s latest available School Place Planning Update (January 2024) (Ref 15.31) states that 2023 forecasting predicts a slight increase in numbers compared to previous years, driven by the higher than expected demand over the past two years. This is shown by the number of actual pupils in 2022 being 78 pupils higher than the forecasted figure. Since 2018, LBL has taken approximately 600 reception places out of the system, and will continue to reduce the number of primary school places, with reductions of 1-2FE on a yearly basis.
15.7.35
As a short term action, the School Place Planning Update states that caps on primary school admissions are in place for the academic year 2023/24 and in the medium term, the Council will continue discussions with primary schools once reception rolls are known. In the medium term, the Council will continue to work with schools and will consider the possibility of in-year Office of the Schools Adjudicator applications for PAN reductions dependent on application numbers.
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Secondary Education 15.7.36
According to the 2023/24 Annual Schools Census data, there are 14 secondary schools within the LBL, with a combined surplus of 1,381 places, equating to 8% surplus capacity – as set out in Figure 15.5 and Table 15.8.
15.7.37
The closest secondary schools to the Site are Prendergast Vale School 350m the west of the Site and St Matthew Academy 850m to the east, which have surplus capacities of 21 places (4% capacity) and 11 places (1% capacity), respectively.
15.7.38
Five schools have recently amended their PANs or have plans to in the next year, therefore the capacities set out in Table 15.8 do not reflect the capacity of the school in coming years. Details on these schools are set out below: •
•
• • •
Prendergast School – PAN increased from 116 to 120 in September 2020. The PAN then temporarily increased from 120 to 150 in September in September 2021 and returned to 120 in September 2022. This school will reach its new lower capacity of 600 by September 2026. Haberdashers’ Aske’s Hatcham School – The PAN changed from 208 to 220 in September 2020. The PAN then increased from 220 to 224 in September 2021. The PAN then dropped from 224 to 208 in September 2023. This school will reach its new increased capacity of 1,040 in September 2027. Deptford Green School – The PAN reduced from 234 to 180 in September 2020. This school will reach its new lower capacity of 900 places by September 2024. Forest Hill School – The PAN reduced from 240 to 180 in September 2022. This school will reach its new lower capacity of 900 by September 2026. Sedgehill School – The PAN reduced from 306 to 180 in September 2022. This school will reach its new lower capacity of 900 by September 2026.
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15.7.39
These PAN amendments will result 682 fewer places compared to the existing capacity of 12,662 places set out in Table 15.8. The new capacity of 11,980 will be reached in September 2027.
Figure 15.5: Secondary Schools in LBL
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Table 15.8: Existing Secondary School Capacity in LBL Map Ref.
School Name
PAN (2023/24)
Current Capacity
NOR
Surplus (%)
1
Prendergast Vale
120
600
579
21 (4%)
2
St Matthew Academy
180
900
889
11 (1%)
3
Prendergast*
120
600
617
9 (1%)
4
Trinity CofE
120
600
631
0 (0%)
5
Prendergast Ladywell
180
900
884
16 (2%)
6
Addey and Stanhope
120
600
591
9 (2%)
7
Haberdashers' Aske's Hatcham College*
208
1,040
1,098
0 (0%)
8
Deptford Green *
180
900
895
59 (6%)
9
Sydenham
240
1,200
1,177
23 (2%)
10
Forest Hill *
180
900
875
205 (19%)
11
Conisborough College
180
900
825
75 (8%)
12
Bonus Pastor Catholic College
180
900
918
0 (0%)
13
Sedgehill *
180
900
704
574 (45%)
14
Haberdashers' Aske's Knights Academy
208
1,040
1,026
14 (1%)
12,662
11,709 1,016 (8%)
Total
Note: negative surplus has been counted as zero capacity * These schools have recently amended their PANs – the figures presented represent capacity for 2023/24 entry and thus will differ from the capacity of the school when the amendments have worked their way through all school years.
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15.7.40
The IDP (2023) (Ref 15.30) notes that there are sufficient places in secondary schools through to 2025, but states that an additional secondary school may be needed after this year. It also notes that the Council did not progress with the planned expansion of Addey and Stanhope School, and has supported a reduction in PAN at both Prendergast Ladywell School and Deptford Green School, to manage the risk of a large oversupply.
15.7.41
If required, the Council considers that capacity could be increased by increasing the PANs for Prendergast Ladywell School, Deptford Green School, Forest Hill School and Sedgehill Academy (which have recently reduced their PANs). As a result of expected longer term population growth, the need to accommodate additional secondary school places beyond 2025 will be monitored and reflected in future iterations of the IDP.
15.7.42
According to the latest Lewisham School Place Planning update (January 2024) (Ref 15.31), an increase in applications for 2022/23 resulted in over-offering at undersubscribed schools and a similar pattern followed in 2023. Figures suggest that Lewisham secondary schools are gradually becoming more popular, with the Year 7 cohort in 2022/23 being 66 pupils higher than the forecasted number of pupils. The current primary year group numbers are consistent with cohorts around 3,300, suggesting that there should be a steady stream of pupils coming through to Year 7 in the near future. Discussions will continue with secondary schools regarding the overoffering of places to ensure that this does not happen in the future.
Primary Healthcare 15.7.43
There are five GP practices within 1km of the Site, the locations of which are shown in Figure 15.6 (Ref 15.32) .
15.7.44
Belmont Hill Surgery, Morden Hill Surgery, St Johns Medical Centre and Hillyfields Medical Centre, in addition to Honor Oak Health Centre which doesn’t fall within 1km of the Site, all operate under the Lewisham Care Partnership.
15.7.45
The partnership was formed in June 2017 and the GPs manage their combined list sizes together for greater efficiency and improved capacity to respond to patient needs. Table 15.9 includes all five GPs.
15.7.46
The number of FTE GPs set out within Table 15.9 includes fully qualified GPs and GPs in specialist training. GPs in specialist training are able to see and treat patients.
15.7.47
Local GP practices have an average of 1,952 patients per FTE GP as shown in Table 15.9, which is lower that the number of patients per FTE GP at the South East London ICB (2,076) and regional (2,058) levels. This suggests that there may be some limited capacity for population growth in this area to be met by existing primary health care provision. The closest GP surgery to the Site is the Triangle Group Practice, which has an average list size of 2,590 patients and is therefore unlikely to be able to support a significant growth in its list without additional resources.
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Figure 15.6: Primary Healthcare Facilities within 1km of the Site
Table 15.9: GP Capacity Map Ref
GP Practice Name
n/a
Honor Oak Health Centre (within LCP)
1
Belmont Hill Surgery (within LCP)
2
Morden Hill Surgery (within LCP)
3
St Johns Medical Centre (within LCP)
4
Hillyfields Medical Centre (within LCP)
5
Triangle Group Practice
Patient List Size
FTE GPs
Average Patient List Size per FTE GP
53,471
28.4
1,895
6,630
2.6
2,590
60,371
30.9
1.952
South East London ICB average
2,114,839
1,018.8
2,076
London average
11,044,082
5,365.5
2,058
Overall Total (within 1km)
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*including GPs in specialist training that are able to see patients 15.7.48
In line with the NHS’s plan to develop a more integrated care system, LBL is implementing a shift towards primary care networks (PCNs). PCNs involve GP practices coming together and delivering a wider range of services including pharmacists, physiotherapists, paramedics and social prescribing support works. The aim is to reduce pressure on GPs and respond to increasing demands associated with population growth.
15.7.49
To help facilitate this shift, LBL has stated its intention to develop four neighbourhood care hubs to provide a wide range of community-based health and care services, supported by other sites providing complementary primary care. The ‘Central Lewisham Neighbourhood Care Hub’ is proposed to be delivered on land at the University Hospital Lewisham site, c. 750m south of Lewisham Shopping Centre. The indicative timescale for delivery is 2026-2036.
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Open Space 15.7.50
An assessment of existing open space and playspace has been undertaken within an 800m catchment of the Site. There are eight open spaces within 800m of the Site, with closest being Cornmill Gardens which is situated just off Loampit Vale and accessed via a walkway under the railway. It offers local residents access to the River Ravensbourne and Waterlink Way, as well as providing a play area.
15.7.51
There is also a total of eight playspaces within a 800m catchment of the Site, with the closest playspaces to the Site being Cornmill Gardens Playspace and Paris Corte Playspace.
15.7.52
The largest open spaces within 800m of the Site are Hilly Fields Park and Blackheath Open Space. Hilly Fields Park is one of the oldest parks within the Borough and offers excellent views over Lewisham and the City of London, with the summit of Hilly Fields standing 175 feet above sea level. The park offers facilities which include a café, a picnic area, a football pitch, a cricket pitch, basketball and tennis courts and a dog exercise area. This park also hosts a farmers market every weekend where local residents can purchase fresh fruit and vegetables, as well as handmade burgers and sausages, organic bread and various relishes/sauces. Blackheath is spans both the Greenwich and Lewisham boroughs, with park being awarded the Green Flag award. Facilities at Blackheath include tennis courts, football pitches and a tea hut.
15.7.53
According to the latest Lewisham Parks and Open Space Strategy, the Site does not fall in an area of playspace deficiency but does fall within an area of deficiency for local, small and pocket parks.
15.7.54
Lewisham Town Centre (as part of the sub area) is defined as being in an area of deficiency in access to local parks but there ‘is no undeveloped land available to accommodate new open spaces’, while it is also stated that Lewisham Town Centre ‘benefits greatly from being within 10 minutes’ walking distance of Blackheath Metropolitan Park in the eastern sub area’.
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Figure 15.7: Open Space within 800m of the Site
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15.8 Future Baseline 15.8.1
In the absence of the Proposed Development, the baseline would be expected to evolve in accordance with background trends and in response to housing/employment development. Population figures will be influenced by factors such as new housing which will bring additional people to an area, affordability of housing stock, turnover of housing stock, and inward/outward migration patterns. This in turn will affect the capacity and ability of local social infrastructure to meet demand. As a major town centre Site, if the Site is not developed, there would be a significant opportunity cost in terms of housing delivery and regeneration. If this continued in the long term, the Town Centre could decline and may no longer be able to meet the needs of retailers or their customers.
15.8.2
Data from the Office for National Statistics (ONS) on population projections (which is not available at the ward level) indicates that the Borough can expect to grow by 9% between 2024 and 2043, which is slightly higher than the projected growth rate in London (6%) over the same time period.
15.9 Summary of Receptors and Sensitivity 15.9.1
Table 15.10 identifies existing and future socio-economic receptors and their respective sensitivity – drawing on information from the baseline section above.
Table 15.10: Summary of Receptor Sensitivity Receptor
Sensitivity (Value) and Description
Existing Employees and businesses on-site
High (Site) – the Site currently consists of the Lewisham Shopping Centre and further retail units along Lewisham High Street, including 72,970 sqm of Town Centre floorspace, of which 56,109 sqm is to be demolished. The area to be demolished accommodates approximately c.690 FTE employees.
Construction industry and its employees
Low (Regional) – the construction industry is assessed at a regional level due to the mobility of the construction workforce. There are approximately c.411,000 construction jobs based in the London region.
Existing businesses and labour market in the local area.
Low (Local, Borough) – Accessibility of employment is key to the prosperity of a population. Economic activity rates at the local level are relatively high while claimant count rates are below the borough and regional averages. In addition to this, the profile of occupations held by residents is skewed towards higher-skilled employment.
Housing market
High (Borough) - based on figures from the GLA on Annual Residential Development Completions, housing delivery in Lewisham has only met/exceeded the annual housing target once within the last 6 years (2018/19), with Lewisham only delivering 22% of its housing delivery target in 2022/23. Housing delivery in the future will need to meet higher targets than the adopted Local Plan levels to meet increasing housing needs. As such, it is important for the borough to continue to secure housing growth where appropriate.
Local social infrastructure: Primary schools
Low (1km) – There is currently a surplus capacity of 17% in primary schools within 1km of the Proposed Development, indicating that there is sufficient capacity to cater for increased demand in primary school places in the area.
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Receptor
Sensitivity (Value) and Description
Secondary schools
Medium (Borough) – There is currently a surplus capacity of 8% in secondary schools within LBL which indicates some surplus, and there are plans to expand existing schools.
Primary healthcare (GPs)
Medium (1km) – there is some limited capacity within local GPs. A new health hub is proposed within 750m of the Site.
Open space and play space
Medium (1km) – there is good access to strategic open space but Lewisham Town Centre is identified as being in an area of deficiency in access to local parks. In addition to this, the Site also falls within an area of deficiency for small and pocket parks.
Future Residents living in the new homes on-site
High (Site) – new residents require good access to social infrastructure, amenities and employment. There are, therefore, considered to be highly sensitive to local provision.
15.10 Assessment of Effects, Mitigation and Residual Effects Demolition & Construction Phase Existing Businesses and Employees On-Site and in the Local Area 15.10.1
As outlined in the Baseline section of this Chapter, the Site currently comprises: • •
Lewisham Shopping Centre - home to a total of 52 leased units; and Retail units along the high street.
15.10.2
The existing floorspace within the Site has been derived from various sources including a Landsec commissioned Ruxton Survey (2018) of town centre floorspace in Landsec ownership; review of planning and CIL records held on the Council’s website; GOAD plans for town centre floorspace; Valuation Office Agency floorspace areas; site surveys (inc. the latest in August 2024); and physical inspection.
15.10.3
Existing employment is calculated using:
• The Business Occupier Survey (Ref 15.33); • The Landsec Property Portfolio Economic Survey (Ref 15.34); and • Where exact employment is not known, the following densities have been applied to occupied units: o Retail uses have been estimated using employment densities derived from the two above surveys; and o For all other uses, HCA employment densities have been applied.
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15.10.4
This calculation yields approximately c. 1,000 FTE employees on-site, with c.690 located within floorspace to be demolished.
15.10.5
Jobs located in units to be demolished would be displaced by the Proposed Development. The Proposed Development will come forward in three main phases over 10 years, and therefore displacement would take place gradually over an extended period.
15.10.6
The phasing of the Proposed Development has been organised to ensure the continuity of operation of the Shopping Centre at the Site. Phase 3 – planned to commence in 2030 - is arranged so as to demolish and re-build the main extent of the shopping centre in sub-phases, with the aim of keeping the shopping centre functional in some capacity throughout the duration of construction. More detail on the proposed Phasing Strategy is set out in the Design and Access Statement and Chapter 5: Demolition and Construction.
15.10.7
If any businesses do not relocate within the Proposed Development, locally or they reduce their operations, some businesses may reduce the number of people they employ in the area. Given the characteristics of the local labour force and its connectivity to the wider London employment market, and the phasing of the development meaning any displacement is taking place over a long period of time, this change is not likely to be significantly different to the natural churn in the labour market.
15.10.8
Therefore, the effect of the potential loss of existing uses and employment on-site (medium magnitude of impact) is considered to be temporary, direct, moderate negative effect (significant) at the Site level and temporary, direct, minor negative effect at the local level (not significant).
Demolition and Construction Employment 15.10.9
The demolition and construction phase of the Proposed Development would generate employment within the construction industry. It is estimated that the Proposed Development would support an average of c.770 jobs (FTE) in any given month over the 10 year duration of the construction phase.
15.10.10
It is important to note that due to the nature of the construction programme, employment may fluctuate over the build programme, and could be higher at the peak. Construction employment is expected to be higher than average figures during the following periods: • •
Q4 2027 – Q2 2028 – Phase 1a and Phase 1b Overlap: This will be a busy period for construction and demolition, with Phase 1a nearing completion and the demolition of Phase 1b commencing. Q3 2030 0 Q1 2031 - Occupation of Phase 1a with new residents and construction and demolition across the entire site with 1b, 2a, 2b and 3a.
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15.10.11
Construction employment is highly mobile and, therefore, assessment of the construction phase is best considered at the regional level e.g. London wide level. In the regional context (low sensitivity), taking account of the c.411,000 construction jobs currently based in London, the impact of the c.770 jobs (FTE) jobs is considered a low magnitude of impact on the construction industry. Additional employment of this scale generated within the construction sector is positive but not significant. This would be a medium term temporary negligible effect at the regional level.
Mitigation, Monitoring and Residual Effects 15.10.12
Temporary, moderate (significant) and minor (not significant) negative effects have been identified with regards to the loss of employment at the Site and the Local levels respectively. The Proposed Development will accommodate employment once operational, including re-provision of similar uses – e.g. retail uses, leisure and community floorspace and no loss of active retail and employment space, resulting in a net increase in jobs.
15.10.13
Breaking down the phases into sub-phases will increase the opportunity for businesses and jobs to relocate within the site, for example completion and occupation of retail floorspace within phase 3a, before demolition of phase 3b. The availability of existing vacant space, plus newly vacant space expected to become available over time through natural churn of occupiers over the ten years of construction, as well as the phased availability of new floorspace as earlier phases complete – together will create opportunities for businesses to relocate and remain during construction, providing a significant degree of mitigation for disruption to businesses and employees. Landsec are in discussion with a number of the existing retailers to take retail floorspace as part of the Proposed Development, and will offer agents support for relocation to independent retailers within the centre.
15.10.14
The residual effect on businesses and employees after this mitigation is assessed as minor (not significant).
15.10.15
No negative effects have been identified with regards to Construction Employment, therefore, the residual effects would remain as stated above.
15.10.16
The benefit of construction employment could be enhanced at the local/district level by the implementation of recruitment/job brokerage schemes, apprenticeships and training schemes, and procurement protocols. These would be subject to negotiations between the Applicant and the Council and would be secured via the S106 agreement.
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Operational Phase – Completed Development Employment Creation 15.10.17
The Proposed Development includes a range of non-residential floorspace that will provide employment opportunities including the provision of flexible retail, commercial, community and cultural spaces. 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.
15.10.18
At 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.
15.10.19
Table 15.11 sets out the commercial floor areas proposed and an estimated number of jobs that could be accommodated by the Proposed Development (combining the Detailed Proposals and Outline Proposals).
Table 15.11: Employment opportunities by proposed use (Indicative Scenario) Use
GEA (sqm)
GIA (sqm)
NIA (sqm)
Density Range (sqm/unit per FTE employee)
FTE Jobs
Detailed Components Co-Living (Sui Generis)
445 homes
Flexible Commercial (Use Class E, 2,776 2,498 Sui Generis)* Detailed Components (Total) Outline Components Student Accommodation (Sui 630 beds Generis) 18,780 16,601 Town Centre (Class E (a, b, c, d, e, f; 18,780 16,601 g (i, ii)); and Sui Generis)** Community and Cultural Uses (Class 2,189 1,970 F.1; F.2; and Sui Generis) Outline Components (Total) Detailed and Outline Components (Total) Existing employment Net
2,252
1 job per 10 beds or 15 beds
30 - 45
15 - 20 NIA
115 - 150 145 - 195
14,110 14,110 1,675
1 job per 50 beds 15 - 20 NIA
710 - 940
10 - 20 NIA
710 – 1,410
50 – 165 GIA
10 - 40
13
1,445 – 2,405 1,590 – 2,600 690 900 – 1,910
*Class E includes a wide spectrum of uses. Based on professional judgement, and the nature and extent of the units in N1 & N2, it is assumed the employment density of these uses will be equivalent to retail and food and beverage uses. This is an illustrative assumption and will not form part of the planning permission. ** Based on professional judgement and the nature and extent of the town centre uses coming forward in the Outline Component, it is assumed the employment density of these uses will be equivalent to 50% retail uses, and 50% retail, food and beverage, or office uses.
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This is an illustrative assumption and will not form part of the planning permission. Please note: this does not include retained and refurbished uses. Figures may not sum due to rounding.
15.10.20
Due to the flexibility of the proposals, Table 15.11 shows that the detailed components of the Proposed Development could accommodate between 145 – 195 jobs (FTE) and the outline components could accommodate between 1,445 to 2,405 jobs (FTE).
15.10.21
When taking the estimated existing jobs located in floorspace to be demolished into consideration (c. 690 jobs (FTE)), the Proposed Development could result in a net increase of between 900 jobs and 1,910 jobs.
15.10.22
It is noted that the estimated displaced jobs (c. 690) is smaller than the proposed jobs (c. 1,590 – 2,610) even though the area to be demolished (56,109 GEA sqm) is greater than the area proposed in high employment density uses (e.g. town centre uses in indicative scheme, 37,820 GEA sqm). This difference is driven by the vacant existing floorspace, and known employment values in the occupied existing uses, which are much below the HCA Employment Density Guide, likely reflecting that older floorspace is not occupied to the same density levels as new floorspace.
15.10.23
Based on a likely worst case scenario the net increase of 900 jobs (high magnitude of impact) on the existing labour market (low sensitivity receptor), the Proposed Development would have a minor positive effect (not significant) at the local level and a negligible effect (not significant) at the borough level.
Housing Delivery 15.10.24
The London Plan 2021 (Ref 15.2) sets LBL a housing target of 16,670 new homes to be provided between 2019/20 and 2028/29; equivalent to 1,667 homes per year. The baseline demonstrates that LBL has managed to meet borough targets once in the last 5 years (2018/19), with total yearly completions as a percentage of yearly housing targets steadily declining since 2021/22. The housing need receptor is, therefore, identified as a high sensitivity receptor.
15.10.25
The Proposed Development includes delivery of 119 homes and 445 co-living homes as part of the Detailed Proposals and 1,524 homes and a 630-bed student accommodation as part of the Outline Proposals. This is the minimum housing scenario. These homes would contribute to the delivery of Borough housing targets for LBL.
15.10.26
At a ratio of 1.8:1, the 445 co-living homes are “equivalent” to 247 homes with respect to housing targets. At a ratio of 2.5:1, the 630 student accommodation beds are “equivalent” to 252 homes. When combined with the 1,643 homes, this equates to 12.8% of the tenyear London Plan target for LBL, a medium magnitude of impact.
15.10.27
Therefore, the effect on housing provision (high sensitivity receptor) would be direct, permanent, moderate positive effect at the LBL level (significant).
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Population 15.10.28
The estimated future population of the Proposed Development is set out in Table 15.12. This is based on the maximum residential development scenario (i.e 119 homes in detail, 1,600 homes in outline, 445 co-living rooms and 661 student accommodation beds). The estimated population and child yield has been calculated using the GLA Population Yield Calculator (2019).
15.10.29
For co-living homes and student accommodation beds, we have assumed that the population yield is 1.25 per home and 1 student per bed respectively.
15.10.30
A Form of Entry is an intake of 30 pupils at Reception (at Primary School) and Year 7 (at Secondary) that feeds through to 30 children in each year group of the school, adding to a total of 210 children across Years R-6 in Primary and 150 children in Years 7-11 at Secondary.
Table 15.12: Summary of Future Population of the Proposed Development (maximum housing scenario) Detailed Proposals
Outline Proposals
Total
Dwellings
119
1,600
1,719
Co-Living
445
0
445
0
661
661
769
3,586
4,355
0.4
1.4 1.7 (including students)
1.8 2.1 (including students)
Primary School Demand (places)
4
84
104
Primary School Forms of Entry (FE)
0.02
0.40
0.5
Secondary School Demand (places)
1
34
35
Secondary School Forms of Entry (FE)
0.01
0.22
0.23
Variable Homes Student Accommodation Population GP Demand (Full Time Equivalent GP required) (London benchmark 2,058 patients per GP)
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Education 15.10.31
The population of the Proposed Development would result in an increased demand for school places. Table 15.13 indicates potential demand for 124 school places – 89 primary and 35 secondary.
15.10.32
The Proposed Development would generate demand for 89 primary places, with 4 places arising from the detailed proposals and 85 arising from the outline proposals. This would equate to an overall primary demand of 0.42 FE (0.02 FE for detailed proposals and 0.40 FE for outline proposals) (medium magnitude of impact). There are not expected to be any children in the 445 co-living homes (Sui Generis).
15.10.33
As highlighted within the baseline section of this ES chapter, there is currently 17% surplus capacity within the five primary schools within 1km from the Site (low sensitivity receptor).
15.10.34
The likely effect of the Proposed Development on primary schools would be negligible at a Local Level (not significant).
15.10.35
The Proposed Development would generate demand for 35 secondary places, with 1 place arising from the detailed proposals and 34 arising from the outline proposals. This would equate to an overall secondary demand of 0.23 FE (0.01 FE for detailed proposals and 0.22 FE for outline proposals) (low magnitude of impact).
15.10.36
As highlighted within the baseline section of this ES chapter, there is currently 8% surplus capacity within all state secondary schools within LBL (medium sensitivity receptor).
15.10.37
The effect of the Proposed Development on secondary schools (medium sensitivity receptor) would negligible at the LBL level (not significant).
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Primary Healthcare (GPs) 15.10.38
The Proposed Development is expected to accommodate a maximum of 4,355 people, with 769 people living in the Detailed element and 3,586 people living in the Outline element.
15.10.39
Of the modelled resident population, 661 are students. Most student residents are likely to be between 18-23 years old. This age group has relatively low healthcare demands. Students can also register for GP services within their universities or may remain registered at their parental address. This demand is therefore likely to be significantly lower, and also distributed widely, including outside the borough. Student numbers in London are determined by university admissions, not by PBSA provision, and therefore demand is not entirely net additional.
15.10.40
Based on the London average patients per FTE GP of 2,058. The new resident population of the Proposed Development (excluding students) will generate demand for the equivalent of 1.8 FTE GPs (0.4 FTE GPs from the detailed proposals and 1.4 FTE GPs from the outline proposals). If students demand is factored in at standard rates, not allowing for the caveats set out above, this would rise to the equivalent of 2.1 FTE GPs (medium magnitude).
15.10.41
An effect of this magnitude on a medium sensitivity receptor would be assessed as direct, permanent minor negative effect at the local level (not significant).
Open Space 15.10.42
The Proposed Development will deliver new publicly accessible open space, including: • • • •
The Park – 5,255 sqm; Northern Square – 3,360 sqm; Eastern Terrace – 1,970 sqm; and New Model Market – 1,300 sqm.
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15.10.43
As outlined in the Baseline, the existing site does not currently provide any open space. Lewisham Town Centre (as part of the sub area) is defined as being in an area of deficiency in access to local parks but there ‘is no undeveloped land available to accommodate new open spaces’, while it is also stated that Lewisham Town Centre ‘benefits greatly from being within 10 minutes’ walking distance of Blackheath Metropolitan Park in the eastern sub area’. Open space is a medium sensitivity receptor.
15.10.44
Therefore, the provision of the new open and public realm space as part of the outline proposals (subject to RMA) reflects significant new provision in the context of the baseline which will benefit the new and existing local residents, site users and the wider local community (high magnitude of impact).
15.10.45
The open space provision is in line with both Policy 12 ‘Open space and environmental assets’ in the Lewisham Core Strategy which requires on-site provision of public open space as part of new development, and Policy GR2 of the Reg 19 LBL Local Plan which states that development proposals should maximise opportunities to include new public open space and improve connections to green space, while major developments will be required to incorporate new public space unless it is not feasible.
15.10.46
In conclusion, the effect of the Proposed Development on open space (medium sensitivity receptor) is assessed to be a direct, permanent, moderate positive at the Local Level (significant).
Playspace 15.10.47
Table 15.13 sets out the number of children expected to live within the Proposed Development and aligns with the typology of required for children of various ages.
Table 15.13: Playspace Demand (GLA Population Yield 2019) Age Detailed Component Outline Component (Max Residential) Profile Requirement Provided Difference Requirement Provided Difference 0–4 66 66 0 1,210 1,210 0 years 5 – 11 44 44 0 843 843 0 years 12 – 15 15 0 411 411 0 17 years Total 125 125 0 2,464 2,464 0
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15.10.48
The Detailed Proposals include delivery of 125 sqm of playspace meeting the demand generated by the proposed 119 homes.
15.10.49
Due to the nature of the Outline Proposals, there is no detailed design for playspace at this stage (and will be the subject of a RMA). However, it is estimated that the Outline Proposals will provide 2,464 sqm.
15.10.50
When combining the provision of playspace within the detailed and outline elements of the proposals, the Proposed Development will deliver 2,589 sqm. This is in line with the demand associated with the Maximum Residential Parameter (low magnitude).
15.10.51
As a result of this, the effect of the Proposed Development on playspace (medium sensitivity receptor) is assessed to be a direct, permanent minor positive at the Site and Local Level (not significant).
Additional Spending 15.10.52
The Development would generate economic benefits for the local economy (low sensitivity receptor) through spending by new employees, residents and student population as set out in Table 15.14.
Table 15.14: Estimated Household, Student and Employee Spending Category of Spending Household Spending (indicative scheme, 1,643 homes) Student Household Spending Co-living Spending Employee Spending Total Net Total
Spending (million) £17.9 £5.5 £2.5 £4.9 - £8.1 £30.8 - £34.0 £28.7 - £31.8
Figures may not sum due to rounding.
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15.10.53
Gross annual spending by new residents (including students) and employees accommodated by the Development would total approximately £30.8 - £34.0 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 £28.7 - £31.8 million (high magnitude of impact).
15.10.54
This effect would be (minor) positive but in the context of the scale of the local economy would not be significant.
Mitigation, Monitoring and Residual Effects 15.10.55
No significant negative effect has been identified. No further mitigation is proposed so residual effects remain as assessed.
15.10.56
A minor negative effect has been identified with respect to potential demand arising for primary healthcare. Primary healthcare provided by the NHS is funded by tax revenue as allocated to Primary Care Networks through Integrated Care Boards (ICB). ICB block funding for revenue spending is updated annually and services can therefore adjust to changes in population relatively quickly.
15.10.57
If sufficient evidence is provided that justifies mitigation in line with LBL priorities, and in accordance with Regulation 122 of the Community Infrastructure Levy Regulations (2010) (As amended), Section 106 or Community Infrastructure Levy spending could be directed towards health and education infrastructure.
15.10.58
Without mitigation either through ICB funding mechanisms or other funding sources there would be a residual minor negative effect (not significant) at a local level for primary healthcare.
15.11 Cumulative Effects 15.11.1
This section considers the likely cumulative effects that could arise from the Proposed Development when considered alongside other committed development schemes near the Site. It identifies whether effects from several developments which individually may be insignificant could, when considered together, cause significant cumulative effects requiring mitigation.
15.11.2
The assessment is based on the best available information and draws on the assessments included in the Environmental Statement (ES) and Application Reports that accompany the development applications, where available.
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Demolition and Construction Employment 15.11.3
The Development, together with the cumulative schemes, would be expected to generate employment opportunities during their respective demolition and construction stages. However, it is not possible to make a quantitative assessment of this level of employment. Variance in methodologies between projects for calculating construction jobs means that it is challenging to accurately sum them– especially considering different lengths of construction period, different peak employment points and uncertainty over construction starts.
15.11.4
Given the size and mobility of the regional construction labour market, it is not expected that the cumulative schemes would generate any negative effects with respect to socioeconomics. All effects are likely to be negligible or minor positive (not significant).
Mitigation, Monitoring and Residual Effects 15.11.5
Given the size and mobility of the regional construction labour market, it is not expected that the cumulative schemes would generate any negative effects with respect to socioeconomics. All effects are likely to be negligible or minor positive (not significant).
Completed Development 15.11.6
Planned developments within the surrounding area could have further cumulative socioeconomic effects with respect to population, housing provision, employment, spending, and demand for social infrastructure such as schools, healthcare and open space.
Employment 15.11.7
The cumulative effects on employment have been assessed by reviewing the planning applications relating to the relevant schemes as presented in Chapter 17: Cumulative Effects. Any amendment applications and RMAs to these cumulative schemes have also been considered where applicable. Standard assumptions in terms of job densities associated with different employment uses have been applied to the floorspace specified in the planning documents, using a minimum and maximum scenario. Where flexible use was indicated, an average number based on the listed potential use classes was applied to the minimum and maximum scenario.
15.11.8
Should all developments assessed come forward as planned alongside the Proposed Development, between 1,300 and 2,700 jobs would be generated (subject to confirmation on the final uses) (medium magnitude of effect). Considered alongside the Development, these schemes are be expected to have a minor positive effect on employment at the local level.
Population and Housing 15.11.9
In terms of effects on housing provision, the cumulative schemes are expected to bring forward an estimated additional 1,752 homes, in addition to 758 student accommodation bed spaces.
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15.11.10
The cumulative schemes along with the Development would therefore be a significant contribution to LBL’s 10-year housing target (equating to 12.3% of the target). Considered alongside the Proposed Development, this would equate to 25% of the 10year target and is considered to be a medium magnitude of effect. Therefore, the cumulative effect on housing provision is assessed to a permanent, moderate positive effect at the LBL level.
Demand for Community Facilities/Local Infrastructure 15.11.11
The new population accommodated by these homes would create an increase in demand for community facilities such as education and healthcare facilities. Population assumptions have been made for this assessment of cumulative effects using the Environmental Statements, other application documents or average household size from the Census for LBL. This provides an estimate that the cumulative schemes would accommodate approximately c. 5,300 residents in addition to the residents expected within the Proposed Development.
15.11.12
Each planning application will be required to provide appropriate mitigation in order to make their development acceptable in planning terms. and/or in the process of site allocation through the LBL Local Plan.
15.11.13
The cumulative schemes will also deliver various open spaces and playspaces which will benefit the existing local community and the future occupants of the Proposed Development, improving both the quality and amount of readily available spaces for users
15.11.14
Other developments are subject to the same planning obligations and requirements to mitigate impacts in line with LBL’s local policies. It is expected that any effects not mitigated through on-site physical provision will be mitigated though Section 106 contributions where these are necessary to make the development acceptable in planning terms and subject to viability and LPA priorities.
Mitigation, Monitoring and Residual Effects 15.11.15
Where on-site, physical provision of new social infrastructure facilities is not being made and there is an identified needed for additional capacity, the cumulative schemes will be expected to be subject to S106 to mitigate their impacts where these are necessary to make the development acceptable in planning terms and subject to viability and LPA priorities. It is expected that any effects not mitigated through on-site physical provision will be delivered though CIL/Section 106 contributions. Following mitigation where required, the residual cumulative effect in terms of demand for social infrastructure is therefore expected to be negligible or minor positive (not significant) (where a facility serves a wider need that just a specific development).
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DESCRIPTION RECEPTOR SIGNIFICANCE OF EFFECTS OF SIGNIFICANT MAJOR / POSITI P / D / I ST / EFFECTS MODERATE VE / T MT / / MINOR / NEGATI LT NEGLIGIBLE VE DEMOLITION & CONSTRUCTION LOSS OF EXISTING MODERATE NEGATIV T D MT EXISTING EMPLOYMENT
CONSTRUCTION EMPLOYMENT
BUSINESSES AND EMPLOYEES (HIGH) CONSTRUCTI ON INDUSTRY (LOW)
E
SUMMARY OF MITIGATION / ENHANCEMENT MEASURES
SIGNIFICANCE OF RESIDUAL RELEVANT RELEVANT LEGISLATIO EFFECTS POLICY N MAJOR / POSITIV P / D / I ST / MODERATE E / T MT / / MINOR / NEGATIV LT NEGLIGIBLE E
PHASING, RELOCATION WITHIN SITE, AGENT
Minor
NEGATIVE T
D
MT
N/A
N/A
SUPPORT FOR INDEPENDENT RETAILERS
NEGLIGIBLE
POSITIVE T
D
MT
NONE
NEGLIGIBLE
POSITIVE
T
D
MT
N/A
N/A
MINOR (LOCAL) NEGLIGIBLE (BOROUGH)
POSITIVE P
D
LT
NONE
MINOR (LOCAL) NEGLIGIBLE (BOROUGH)
POSITIVE
P
D
LT
N/A
N/A
MODERATE
POSITIVE P
D
LT
NONE
MODERATE
POSITIVE
P
D
LT
POLICY H1 N/A INCREASING HOUSING SUPPLY (LONDON PLAN 2021) POLICY HO1: MEETING LEWISHAM’S
OPERATION END-USE
EXISTING
EMPLOYMENT
LABOUR MARKET AND ECONOMY (LOW) HOUSING NEED (HIGH)
DELIVERY OF NEW HOMES
HOUSING NEEDS (DRAFT LEWISHAM LOCAL PLAN REG 19)
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DEMAND PLACED EXISTING PRIMARY EDUCATION PROVISION (LOW) DEMAND PLACED EXISTING ON SECONDARY SECONDARY EDUCATION EDUCATION FACILITIES PROVISION (MEDIUM) DEMAND PLACED EXISTING GP ON PRIMARY FACILITIES HEALTHCARE (MEDIUM) FACILITIES DEMAND FOR EXISTING AND PROVISION OPEN SPACE OF OPEN SPACE (MEDIUM)
NEGLIGIBLE
ON PRIMARY EDUCATION FACILITIES
DEMAND FOR
EXISTING
AND PROVISION OF PLAYSPACE
PLAYSPACE (MEDIUM)
ADDITIONAL
LOCAL
SPENDING BY RESIDENTS AND EMPLOYEES
ECONOMY (LOW)
NEGATIV P
D
LT
NONE
NEGLIGIBLE
NEGATIVE P
D
LT
N/A
D
LT
NONE
NEGLIGIBLE
NEGATIVE P
D
LT
N/A
D
LT
ICB FUNDING, CIL, S106
MINOR
NEGATIVE P
D
LT
N/A
D
LT
NONE
MODERATE
POSITIVE P
D
LT
POLICY GR1: N/A GREEN
E
NEGLIGIBLE
NEGATIV P E
MINOR
NEGATIV P E
MODERATE
POSITIVE P
MINOR
POSITIVE P
D
LT
NONE
MINOR
POSITIVE
P
D
LT
MINOR
POSITIVE P
ID
LT
NONE
MINOR
POSITIVE
P
ID
LT
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INFRASTRUCT URE AND LEWISHAM’S GREEN GRID AND POLICY GR2: OPEN SPACE (DRAFT LEWISHAM LOCAL PLAN REG 19) POLICY S4: N/A PLAY AND INFORMAL RECREATION (LONDON PLAN 2021) N/A
References Ref 15.1 Ministry of Housing, Communities and Local Government, 2023. Revised National Planning Policy Framework. Ref 15.2 Greater London Authority, March 2021. The London Plan – The Spatial Development Strategy for Greater London. Ref 15.3 London Borough of Lewisham (LBL), 2011. Lewisham Local Development Framework – Core Strategy Ref 15.4 London Borough of Lewisham (LBL), 2014. Lewisham town centre local plan – Development plan document. Ref 15.5 London Borough of Lewisham (LBL), 2014. Development Management Local Plan. Ref 15.6 London Borough of Lewisham (LBL), 2023. Lewisham Local Plan – Proposed submission document – Regulation 19 stage. Ref 15.7 Ministry of Housing, Communities and Local Government. (Live Document). Planning Practice Guidance [online]. Available at: http://planningguidance.communities.gov.uk/ (Accessed: 20 June 2024). Ref 15.8 Greater London Authority, 2012. Shaping Neighbourhoods: Play and Informal Recreation Supplementary Planning Guidance. Ref 15.9 Transport for London, 2017. Analysis of Walking Potential 2016. Ref 15.10 Greater London Authority, 2015. Social Infrastructure Supplementary Planning Guidance. Ref 15.11 Homes and Communities Agency, 2015. Employment Density Guide – 3rd Edition. Ref 15.12 Office for National Statistics, (2011). 2011 Census. Ref 15.13 Office for National Statistics, (2021). 2021 Census. Ref 15.14 Office for National Statistics, (2024). Claimant Count. Ref 15.15 Office for National Statistics, (2022). Business Register and Employment Survey. Ref 15.16 Department for Levelling Up, Housing and Communities, (2019). Indices of Multiple Deprivation. Ref 15.17 Greater London Authority (2023). Residential Completions Dashboard [online]. Available at:https://data.london.gov.uk/dataset/residentialcompletions%20dashboard?_gl=1%2aoohsed%2a_ga%2aNDQ2ODAxODUzLjE2Njg1OTkwNDY. %2a_ga_PY4SWZN1RJ%2aMTY3MzI3MTY3Ny4yLjEuMTY3MzI3MTY3OC41OS4wLjA (Accessed: 20 June 2024). Ref 15.18 Department for Education, (2024). Schools, Pupils and their Characteristics. Ref 15.19 LBL, 2023. Applying to start primary school in September 2023 and Bright futures – applying to start secondary school. Ref 15.20 Office for National Statistics, (2019). Population Estimates & Projections. Ref 15.21 Construction Industry Training Board (CITB) (2018) Labour Forecasting Tool (Accessed online by subscription: www.labourforecastingtool.com) Ref 15.22 GLA, (2019). GLA Population Yield Calculator v3.2 Ref 15.23 Office for National Statistics, (2024). Household Expenditure Survey 2021-2023. Ref 15.24 Department for Education, 2023. Student Income and Expenditure Survey 2021 to 2022 Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 15: Socio-economics
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Ref 15.25 Visa Europe, (2014). UK Working Day Spending Report Ref 15.26 Bank of England, (2021). Inflation calculator [online]. https://www.bankofengland.co.uk/monetary-policy/inflation/inflation-calculator
Available
at:
Ref 15.27 Construction Industry Training Board (CITB), (2022). Labour Market Intelligence Report – Greater London – 5 year outlook (2022 – 2026). Ref 15.28 Level 4 and above qualifications = degree (BA, BSc), higher degree (MA, PhD, PGCE), NVQ level 4 to 5, HNC, HND, RSA Higher Diploma, BTEC Higher level, professional qualifications (for example, teaching, nursing, accountancy). Ref 15.29 Defined as the following occupations: Sales and customer service occupations; process, plant and machine operatives; and elementary occupations. Ref 15.30 LBL (2023). Infrastructure Delivery Plan (IDP) - Evidence base document for Lewisham Local Plan. Ref 15.31 LBL (2021). School Place Planning Update – CYP Select Committee – 11th January 2024 Ref 15.32 NHS Digital. General Practice Workforce, December 2023. [online]. Available at: https://digital.nhs.uk/data-and-information/publications/statistical/general-and-personal-medicalservices/31-december-2023 Ref 15.33. Quod (2024). Business Occupier Survey. Ref 15.34. Landsec (2023). Property Portfolio Economic Survey.
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16.0 Climate Change 16.1 Introduction 16.1.1 This Chapter assesses the significance of the Proposed Development’s impact on, and vulnerability to, climate change. Where appropriate, it also identifies proposed mitigation measures to prevent, minimise or control likely negative effects arising from and to the Proposed Development and summarises the subsequent anticipated residual effects. 16.1.2 The effects of the Proposed Development are considered over its lifetime including demolition & construction phases, operational phase and decommissioning/end of life. 16.1.3 The main climate change issues covered in this Chapter include the following: •
• •
The assessment of the resilience of the Proposed Development to climate change through the climate change resilience (CCR) assessment; and The contribution of the Proposed Development to climate change through the greenhouse gas (GHG) emissions assessment. The interface with CCR and other topic chapters of this ES is captured in the InCombination Climate Impacts (ICCI) assessment within the individual Chapters 6 – 15 and Volume 2. This is the assessment of the potential impact when a projected future climate impact (e.g. increase in temperatures) interacts with an effect identified by another topic and is exacerbated. This also includes whether the implementation of the proposed measures in the ES are affected by climate change.
16.1.4 Each section of this chapter is split into the two aspects above, as they represent two separate assessments. 16.1.5 This Chapter (and its associated figures and appendices) should be read together with the Introductory Chapters of this ES (Chapters 1 – 5), as well as Chapter 17: Effect Interactions.
Competence 16.1.6 This assessment has been undertaken by Hannah Cooper, a senior consultant within WSP’s Sustainability and Climate Change team with over 10 years’ experience in sustainability consultancy services and reviewed by Gareth Oakley, an Associate Director in the same team.
16.2 Legislation, Planning Policy and Guidance 16.2.1 The following national, regional and local planning policy and guidance is of relevance to the assessment of the effects of the Proposed Development in relation to Climate Change.
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Planning Policy Context National 16.2.2 The following national level policy and guidance documents are of relevance to the Proposed Development: Climate Change Act (2008) (2050 Target Amendment)1 16.2.3 The Climate Change Act 2008 sets targets for reducing the UK’s impacts on climate change and the need to prepare for its impacts. 16.2.4 The Act established a legal requirement for an 80% reduction in the GHG emissions of the UK economy by 2050 (against a 1990 baseline) and sets interim targets to ensure progress towards this target. In June 2019 the UK Government updated this commitment to net zero emissions by 2050. The Climate Change Act also created the Committee on Climate Change, with responsibility for setting 5-year carbon budgets covering successive periods of Emissions reduction to 2050. 16.2.5 The Act also requires a Climate Change Risk Assessment to be used to assess the risks from the impact of climate change on the UK. The first UK Climate Change Risk Assessment (CCRA) was presented to Parliament in an Evidence Report in 2012; the latest CCRA is the third assessment in 2022. The overall aim of the Evidence Report is to assess the urgency of further action to tackle current and future risks, and realise opportunities, arising from climate change. Carbon Budget Order 20212 16.2.6 Carbon budgets place restrictions on the amount of GHG the UK can emit over a five-year period. The UK is the first country to set legally binding carbon budgets. Every tonne of GHG emitted between now and 2050 will be counted towards the budget. The 2021 Order establishes the carbon budget for the 2033-2037 budgetary period in the UK. The carbon budget for the specified period is 965 million tonnes of carbon dioxide equivalent, setting a cap on the maximum level of the net UK carbon account during this five-year period.
1
UK Government (2019). Climate Change Act 2008 (2050 Target Amendment) Order 2019. Available at: The Climate Change Act 2008 (2050 Target Amendment) Order 2019 (legislation.gov.uk) 2
UK Government. (2021). The Carbon Budget Order 2021. Available at: The Carbon Budget Order 2021 (legislation.gov.uk)
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National Planning Policy Framework (2023)3 16.2.7 The National Planning Policy Framework (NPPF) 2023 sets out the Government’s planning policies for England and how these are to be applied. The NPPF has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways. One of the objectives is an environmental objective, which includes the objective of “mitigating and adapting to climate change, including moving to a low carbon economy”. The NPPF states that new development should be planned for in ways that can help reduce greenhouse gas emissions. 16.2.8 Guidance relating to the reduction of greenhouse gases and ways to minimise vulnerability and improve resilience to climate change impacts is mainly set out in Section 14 “Meeting the Challenge of Climate Change, Flooding and Coastal Change”. It states that new development should be planned for in ways that avoid increased vulnerability to the range of impacts arising from climate change. National Planning Practice Guidance (NPPG) (2019)4 16.2.9 The National Planning Practice Guidance (NPPG) sets out how the government envisions the day-to-day workings of the planning system in England. The NPPG guidance on climate change advises planners on how to identify suitable mitigation and adaptation measures in the planning process to address the impacts of climate change. Climate Change Adaptation: Policy Information (2021)5 16.2.10 This policy paper states that “Preparing for a changing climate, or climate adaptation, will help the UK to reduce negative consequences of climate change and take advantage of new opportunities. Building the UK’s preparedness and resilience to climate change impacts is a cost-effective and essential way to protect our people, economy, and environment.” In addition, Section 2 provides an overview of how the UK is preparing for climate change. These include commitments to understanding the risks through the UK Climate Change risk assessment, preparing for climate change through the National Adaptation Programme (NAP), and adapting services and infrastructure under the Adaptation Reporting Power (ARP). In Section 4, the policy paper refers to the climate evidence, tools and research including the UK Climate Projections 2018 and the UK Climate Resilience Programme.
3
Department for Levelling Up, Housing and Communities (2023). National Planning Policy Framework (Online). Available at: https://www.gov.uk/government/publications/national-planning-policy-framework--2 4
Department for Levelling Up, Housing and Communities and Ministry of Housing, Communities and Local Government (2019). Planning Practice Guidance: Climate Change. Available at: https://www.gov.uk/guidance/climate-change 5
Department for Environment, Food and Rural Affairs (2022) Climate Change Adaptation: Policy Information. Available at: https://www.gov.uk/government/publications/climate-change-adaptation-policy-information/climate-change-adaptation-policy-information
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Building Regulations 16.2.11 The Building Regulations Part L6 govern the conservation of fuel and power in both new construction and refurbishment of the England and Wales building stock. Compliance with the Building Regulations is a regulatory requirement for all new developments. Carbon emissions of a development comparative to compliance with Part L is the key performance indicator for achieving many carbon targets. The new Building Regulations which came into effect from 15 June 2022, comprise five new Approved Documents, including uplifts to Part L (fuel and power) and Part F (ventilation), and will have a marked impact on new and existing buildings. 16.2.12 The Building Regulations Part O7 sets out the requirement that reasonable provision is made to limit unwanted solar gains in the summer and provide an adequate means to remove heat from the indoor environment. Regional London Plan 20218 16.2.13 Adopted in 2021, the London Plan is a Spatial Development Strategy and overall strategic plan for London for the next 20-25 years. The London Plan provides an integrated economic, environmental, transport and social framework for development across the Greater London Authority (GLA). Policies relevant to this assessment include: •
•
GG6 Increasing efficiency and resilience – outlines that buildings and infrastructure must be “designed to adapt to a changing climate, making efficient use of water, reducing impacts from natural hazards like flooding and heatwaves, while mitigating and avoiding contributing to the urban heat island effect.” SI1 Minimising greenhouse gas emissions – outlines that residential development should achieve a 10% and non-residential development a 15% minimum on-site reduction beyond Building Regulations. If a zero-carbon emissions target cannot be achieved on-site, then a contribution to a carbon offset fund or an alternative off-site proposal identified, and guaranteed delivery should be agreed.
6
HM Government. (2021). The Building Regulations 2010, Approved Document L1A: conservation of fuel and power in dwellings. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1082462/ADL1_revised.pdf 7
HM Government. (2021). The Building Regulations 2010, Approved Document O: Overheating. Available at: https://assets.publishing.service.gov.uk/media/6218c5aad3bf7f4f0b29b624/ADO.pdf 8
Greater London Authority. (2021). The London Plan. Available at: https://www.london.gov.uk/sites/default/files/the_london_plan_2021.pdf
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Local London Borough of Lewisham: Core Strategy (2011)9 16.2.14 Under ‘Core Strategy Policy 7 – Climate change and adapting to its effects’, the Council seeks to adopt a partnership approach to implement the principles of ‘avoidance, mitigation and adaptation’ to reduce Lewisham’s CO2 emissions. Furthermore, under ‘Core Strategy Policy 8 – Sustainable design and construction and energy efficiency’, the Council is committed to prioritising the reduction of the environmental impact of all new development, with a focus of minimising the overall carbon dioxide emissions of the development. 16.2.15 ‘Core Strategy Policy 10 – Managing and reducing the risk of flooding’ helps to reduce flood risk through the appropriate location, design and construction of development and the sustainable management of surface water run-off. The policy seeks to ensure that new development should be seen as an opportunity to reduce the causes and impacts of flooding by measures such as provision of flood storage, use of sustainable urban drainage systems, and re-creating the functional flood plain. Lewisham Town Centre Local Plan (2014)10 16.2.16 Under ‘Policy LTC24 – Carbon dioxide emission reduction’, the policy details the approach to be taken by the Council with regards to CO2 reductions in the town centre and considered the opportunity to deliver a co-ordinated and comprehensive approach to energy production and sharing. 16.2.17 ‘Policy LTC 25 – Adapting to climate change’ details how all developments and works to the public realm will be able to adapt to the potential impacts of climate change. In doing so, applications are required to use measures including living roofs and walls, water saving measures, siting and design of building to minimise climate impacts and vegetation and planting. Lewisham Development Management Local Plan (2014)11 16.2.18 Under ‘DM Policy 22 – Sustainable design and construction’, the Council will require all developments to maximise the incorporation of design measures to maximise energy efficiency, manage heat gain and deliver cooling.
9
Lewisham Council (2011). Core Strategy Development Plan Document (Online). Available at: https://lewisham.gov.uk/myservices/planning/policy/adopted-local-plan/core-strategy/about-our-core-strategy-for-the-local-developmentframework 10
Lewisham Council (2014). Lewisham Town Centre Local Plan (Online). Available at: https://lewisham.gov.uk/myservices/planning/policy/adopted-local-plan/lewisham/lewisham-town-centre-local-plan-documents 11
Lewisham Council (2014). Development Management Local Plan. Available at: https://lewisham.gov.uk/myservices/planning/policy/adopted-local-plan/development-policies
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Draft Lewisham Local Plan (2021)12 16.2.19 In November 2023, the emerging Lewisham Local Plan was submitted for independent examination. The Regulation 18 draft Local Plan has a focus on responding to the climate emergency including the following draft polices which, although the plan has not yet been adopted, have been considered for context purposes only: •
• •
QD1 Delivering high quality design: including development designed to assist in mitigating climate change and also make neighbourhoods and properties more resilience to its impacts through adaptation measures, public realm should be sustainability designed and constructed, including maximising opportunities for urban greening and mitigating the impacts of climate change. SD1 Responding to the climate emergency. SD7 Reducing flood risk.
Lewisham Climate Emergency Strategic Action Plan 2020-203013 16.2.20 In February 2019 the council of Lewisham declared a climate emergency and outlined ambitious plan to ‘Making Lewisham carbon neutral by 2030’. Guidance 16.2.21
The assessment will be undertaken in accordance with the following guidance: • • • •
The Institute of Environment Management and Assessment (IEMA) Environmental Impact Assessment Guide to Climate Change Resilience and Adaptation14 The Institute of Environment Management and Assessment (IEMA) Guide to: Assessing Greenhouse Gas Emissions and Evaluating their Significance15 ISO 14091:2021 Adaptation to climate change – Guidelines on vulnerability, impacts and risk assessment16 ISO 14064-2:2019 Greenhouse Gases – Part 2: Specification with guidance at the project level for quantification, monitoring, and reporting of greenhouse gas emission reductions or removal enhancements17
12
Lewisham Council (2021) Regulation 18 Draft Local Plan. Available at: https://consultation.lewisham.gov.uk/planning/lewisham-localplan-regulation-18-public-consultat/supporting_documents/LEWISHAM%20LOCAL%20PLAN_accessible.pdf 13
Lewisham Council (2020). Lewisham Climate Emergency Strategic Action Plan. Available at: https://lewisham.gov.uk//media/files/imported/lewisham-climate-emergency-strategic-action-plan-20202030.ashx#:~:text=Our%20ambition%20in%20delivering%20Lewisham's,that%20has%20tangible%20positive%20benefits. 14
IEMA (2020) EIA Guide to: Climate Change Resilience and Adaptation. Available at: https://www.iema.net/resources/readingroom/2020/06/26/iema-eia-guide-to-climate-change-resilience-and-adaptation-2020 15
IEMA. (2022). Institute of Environmental Management & Assessment (IEMA) Guide. Assessing Greenhouse Gas Emissions and Evaluating their Significance 2nd Edition. Available at: https://www.iema.net/preview-document/assessing-greenhouse-gas-emissionsand-evaluating-their-significance International Organization for Standardization. (2021). ISO 14091:2021 Adaptation to climate change — Guidelines on vulnerability, impacts and risk assessment. Available at: https://www.iso.org/standard/68508.html 16
International Organization for Standardization. (2019). ISO 14064-2:2019 Greenhouse gases — Part 2: Specification with guidance at the project level for quantification, monitoring, and reporting of greenhouse gas emission reductions or removal enhancements. Available at: https://www.iso.org/obp/ui/#iso:std:iso:14064:-2:ed-2:v1:en 17
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• • • •
The GHG Protocol18 PAS 2080:2023 Carbon Management in Buildings and Infrastructure19 RICS Methodology to Calculate Embodied Carbon of Materials20 RIBA 2030 Climate Challenge21
16.3 Consultation 16.3.1 As discussed in Chapter 2: Approach to Assessment, consideration has been given to the formal EIA Scoping Opinion provided by LBL and consultees and any additional consultation that may have occurred during the design period of the Proposed Development. Table 16.16.1: Consultation Feedback
Consultee
Comment
Where is this addressed?
Natural England
The ES should identify how the development affects the ability of the natural environment (including habitats, species, and natural processes) to adapt to climate change, including its ability to provide adaptation for people. This should include impacts on the vulnerability or resilience of a natural feature (i.e. what’s already there and affected) as well as impacts on how the environment can accommodate change for both nature and people, for example whether the development affects species ability to move and adapt. Nature-based solutions, such as providing green infrastructure on-site and in the surrounding area (e.g. to adapt to flooding, drought and heatwave events), habitat creation and peatland restoration, should be considered. The ES should set out the measures that will be adopted to address impacts.
The ES assesses the effects of climate change on the proposed natural features of the development within Section 16.9. Nature-based solutions have been integrated into the development, with the combined benefits of Sustainable Urban Drainage Systems, such as rain gardens, ponds and grassland. This is described in Section 16.9 and Chapter 14: Ecology.
Natural England
The ES should also identify how the development impacts the natural environment’s ability to store and sequester greenhouse gases, in relation to climate change mitigation and the natural
The development achieves an Urban Greening Factor (UGF) of 0.4 which is an improvement on the current baseline scenario for
18
World Resources Institute and World Business Council for Sustainable Development. (2015). The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard. Available at: https://ghgprotocol.org/corporate-standard 19
BSI. (2023). PAS 2080: Carbon Management in Buildings and Infrastructure. British Standards Institution. Available at: https://www.bsigroup.com/en-GB/insights-and-media/insights/brochures/pas-2080-carbon-management-in-infrastructure-and-builtenvironment/ 20
Royal Institution of Chartered Surveyors (RICS). (2023). Methodology to Calculate Embodied Carbon of Materials (2nd ed.). Available at: https://www.igbc.ie/wp-content/uploads/2015/02/RICS-Methodology_embodied_carbon_materials_final-1st-edition.pdf 21
Royal Institute of British Architects, 2019. RIBA 2030 Climate Challenge. Available at: https://www.architecture.com//media/files/Climate-action/RIBA-2030-Climate-Challenge.pdf.
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environment’s contribution to achieving net zero by 2050.
urban greening on site. The UGF calculation reflects the extent to which a development site has enhanced both natural capital and biodiversity within the landscape and planting proposed relative to baseline conditions.
16.4 Assessment Methodology and Significance Criteria 16.4.1 The following section outlines the methodologies applied to identify and assess the potential impacts and likely effects to result from, and to, the Proposed Development. Scope of the Assessment 16.4.2 An EIA Scoping Report was issued to LBL in January 2024 (Appendix 2.1). LBL’s formal Scoping Opinion was issued in June 2024 (Appendix 2.2). 16.4.3 The following potential effects were scoped into the assessment. Climate Change Resilience 16.4.4 The climate change variables and impact scoped into the climate change resilience assessment are documented in Table 16.2, with the associated potential significant effects which have been assessed. Table 16.2 Climate Change Impacts scoped into the assessment Climate variable and impact
Potential effects
Precipitation
Extreme precipitation events.
Flooding (pluvial or fluvial) may lead to damage, potentially meaning that buildings cannot be occupied and that roads are impassable and causing dangerous driving conditions. Flooding may also cause damage to surface leading to deterioration of materials and increased maintenance requirements. Extreme rainfall events may also be leading to destabilisation of soils and earthworks, potentially leading to disruption.
Drought
Buildings, roads, and vegetation are also sensitive to low rainfall or drought. Prolonged dry periods may lead to drying out and cracking of earthworks and soils, changes to growing seasons and greater amounts of dust and building damage. This will also cause water shortages for the end user and vegetation.
Extreme temperature events.
Drier and hotter summers will lead to more incidences of heat damage to buildings, increased energy needs, overheating in occupied spaces and associated health implications for end users. Roads are sensitive to extreme temperatures - high temperatures may cause damage to paved surfaces, including potential melting
Temperature
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and deformation. An increase in solar radiation can also cause more rapid deterioration of materials and associated infrastructure such as signage. Wind
Gales and extreme wind events Storms (lightning, hail)
High winds and storms can affect the stability of aboveground infrastructure and hasten material degradation due to wind-driven rain infiltration. Road users and cyclists may also be sensitive to high winds; associated infrastructure such as signage or signals could also be damaged by high winds or lightning strike.
Greenhouse Gases: 16.4.5 The Lifecycle Stages of a Lifecycle Assessment (LCA) have been scoped into the greenhouse gas emission assessment as summarised in Table 16.3. The significance of emissions have been considered while scoping in the greenhouse gas elements. Table 16.3 Greenhouse gas emissions LCA stages scoped into the assessment Element
Phase
Product stage (manufacture and transport of raw materials to suppliers) A1-3
Construction
Raw materials required for the Proposed Development will result in embodied emissions and have the potential to be significant in terms of GHG emissions.
Transport of materials to site A4
Construction
Construction stage emissions from fuel / energy consumption due to the delivery of material to site have the potential to be large.
Plant and equipment used during construction A5
Construction
Fuel / energy consumption of plant and equipment used during construction would generate GHG emissions which has the potential to be significant.
Disposal of waste A5
Construction
Emissions from the disposal of waste are unlikely to be large, due to a large proportion of construction waste being inert.
Replacement B4 and refurbishment B5
Operation
The replacement and refurbishment of the Proposed Development would release a potentially large emissions, which may be significant.
Operational Energy Use B6
Operation
In-use electricity emissions will be released on an annual basis due to the building use.
End-user emissions (regional traffic flows) – traffic B8/D
Operation
Changes to regional traffic flows are expected and this has the potential to result in a significant increase in GHG emissions.
Decommissioning process C1-C4
End of Life
Any emissions arising from decommissioning, stripping out, disassembly, deconstruction, and demolition operations as well as from transport, processing and disposal of materials at the end of life of the project. These emissions have the potential to be significant.
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Extent of The Study Area Climate Change Resilience 16.4.6 The assessment of climate change resilience relates to the impact of the future climate on the Proposed Development, as such the study area is defined as the red line boundary of the site. It includes the Proposed Development across its lifecycle, assumed to be 60 years, where climate change projections have been used to inform the potential future baseline conditions across the 60-year lifecycle. Therefore, for the purposes of this assessment, the climate change projections were extracted for up to the 2080s under the Representative Concentration Pathways (RCP) 8.5, in line with IEMA guidance recommendations. RCP8.5 is an emissions scenario which represents an economy relatively slow to transition to energy intensity reductions. 16.4.7 The spatial and temporal study area is used to define the baseline and future climate conditions at the site, which are used to inform the assessment. Greenhouse Gas Emissions 16.4.8 The GHG emissions assessment is not restricted by geographical area, instead the focus is on any increase or decrease in emissions because of the Proposed Development, across its lifecycle. The operational stage is based on a 60-year design life. Method of Baseline Collection Climate Change Resilience 16.4.9 The current and future baselines which have informed the CCR assessments have been derived from key data sources: • • • • •
State of the UK Climate Report 202222 Met Office records for regional UK Climate averages23 Met Office weather station data for Greenwich Climate Station24 UK Climate Projections 2018 (UKCP18) data and factsheets25 UK Climate Risk Indicators.26
22
Met Office (2022). State of the UK Climate. Available online at: https://www.metoffice.gov.uk/research/climate/maps-anddata/about/state-of-climate. 23
Met Office (2016). Southern England: Climate. Available at: https://www.metoffice.gov.uk/binaries/content/assets/metofficegovuk/pdf/weather/learn-about/uk-past-events/regionalclimates/southern-england_-climate---met-office.pdf 24
Met Office. Greenwich. Available at: https://www.metoffice.gov.uk/research/climate/maps-and-data/uk-climate-averages/u10hb54gm
25
UKCP User Interface. (n.d.) UKCP UI Products (Online) Available at: https://ukclimateprojections-ui.metoffice.gov.uk/products
26
Nigel Arnell et. al. (2021). The Climate Risk Indicators. Available at: https://uk-cri.org/
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16.4.10 The data is used to derive climate change trends within the study area, which informs of the potential impacts and effects associated with changes in climate parameters and extreme events. Greenhouse gas emissions 16.4.11 The current baseline, as per the IEMA guidance, encapsulates existing GHG emissions before the demolition/construction, operation and maintenance, and decommission of the Proposed Development, incorporating emissions from existing projects and infrastructure within the boundary of the Proposed Development. The business-as-usual scenario involves estimating baseline emissions, which represent the expected emissions from all relevant sources if the Proposed Development is not implemented. This baseline serves as a reference point for comparison with the projected emissions associated with the Proposed Development. 16.4.12 Data for the GHG assessment of the Proposed Development has been collated from the following data sources: • • • • • • •
The Energy Statement, submitted as part of the planning application; The Whole Life Carbon assessment, submitted as part of the planning application; The Transport Assessment, submitted as part of the planning application; Government GHG Conversion Factors for Company Reporting27; 2005 to 2021 UK local and regional CO2 emissions28; CIBSE TM46 Energy Benchmarks (2008)29; and Royal Institute of British Architects (RIBA) 2030 Climate Challenge30.
27
Department for Energy Security and Net Zero and Department for Business, Energy and Industrial Strategy (2024). Greenhouse gas reporting: conversion factors 2023 (Online). Available at: https://www.gov.uk/government/publications/greenhouse-gas-reportingconversion-factors-2023 Department for Energy Security and Net Zero (2023) 2005 to 2021 UK Local and regional greenhouse gas emissions – data tables (Online). Available at: https://www.gov.uk/government/statistics/uk-local-authority-and-regional-greenhouse-gas-emissions-nationalstatistics-2005-to-2021 28
29
CIBSE (2008). Energy Benchmarks (Online). Available at: https://www.cibse.org/knowledge-research/knowledge-portal/tm46-energybenchmarks 30
Royal Institute of British Architects (RIBA) (2021). RIBA 2030 Climate Challenge Version 2 (Online). Available at: https://www.architecture.com/-/media/files/Climate-action/RIBA-2030-Climate-Challenge.pdf
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Method of Assessment Climate Change Resilience 16.4.13 The climate variables that have been scoped into the assessment have been assessed to consider the climate change impacts and the significance of their effect on the Proposed Development. The significance of effects has been determined through consideration of the consequence and the likelihood of potential effects associated with climate variables on the Proposed Development receptors. The likelihood and consequence will be qualitatively assessed using the proposed significant criteria descriptions in Table 16.4 and Table 16.5. This will be informed by the existing and future baseline, and the UK CCRA331. These descriptions are in line with IEMA guidance. The likelihood definitions are dependent on the lifetime of the Proposed Development’s components and therefore would vary. 16.4.14 The assessment of likelihood and consequence (and therefore significance) has also considered the embedded mitigation. Embedded mitigation has been identified through consultation with the Project Team and the requirements of the policies listed in Section 16.2. Table 16.4 – Climate Change Resilience descriptions of likelihood categories Measure of
Description
likelihood Very high
The event occurs multiple times during the lifetime of the project e.g., approximately annually.
High
The event occurs several times during the lifetime of the project e.g., approximately once every five years.
Medium
The event occurs limited times during the lifetime of the project e.g., approximately once every 15 years.
Low
The event occurs occasionally during the lifetime of the project e.g., approximately once in 60 years.
Very low
The event may occur once during the lifetime of the project.
Table 16.5 – Climate Change Resilience descriptions of consequence categories Measure of
Description
consequence Very large
National level (or greater) disruption lasting more than 1 week.
31
UK Climate Risk (2023). National Summaries; CCRA3-IAref (Online). Available at: https://www.ukclimaterisk.org/publications/type/national-summaries/
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Large
National level disruption lasting more than 1 day but less than 1 week or regional level disruption lasting more than 1 week.
Moderate
Site wide level disruption lasting more than 1 day but less than 1 week.
Minor
Site wide level disruption lasting less than 1 day.
Negligible
Disruption to an isolated section lasting less than 1 day.
GHG Assessment 16.4.15 The assessment has followed best practice guidance, including the IEMA guidance which advocates a ‘good practice’ approach where GHG emissions are always considered and reported but at varying degrees of detail depending on the EIA and project in question. 16.4.16 In line with the guidance, this chapter sets out the methodological approach that has been taken to address the GHG emissions associated with the Proposed Development. Existing sources of GHG emissions prior to demolition/construction and operation of the Proposed Development (i.e. without development) are identified as the current baseline. Sources of GHG emissions following the construction and during operation of the Proposed Development have then been assessed, from which the significance, mitigation measures and residual effects are determined. 16.4.17 The GHG assessment approach considered emissions throughout the lifecycle of the Proposed Development including: •
•
•
Construction/demolition stage (A1 – A5) – embodied carbon emissions associated with manufacturing, transport, replacement, and disposal of the existing and proposed building elements; transport during construction; and construction processes; Operational stage (B1 – B8) – embodied carbon emissions associated with replacement/refurbishment of building parts, building emissions associated with buildings’ energy use, as well as transport emissions such as number of vehicles and distances travelled by building users; and, End of Life stage (C1 – C4) – embodied carbon emissions associated with decommissioning works and transport of materials to disposal sites or recovery.
16.4.18 For all lifecycle stages of the Proposed Development, the assessment has included the following: •
•
Collection of available data/information on the scale of GHG emitting activities (e.g. number of vehicle trips, kWh of electricity) for the baseline scenario and for the Proposed Development. In each case this will cover the Proposed Development’s lifespan (60 years); and Calculation of the GHG emissions by applying a suitable emissions factor (tCO2e per unit of emissions generating activity).
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16.5 Significance Criteria 16.5.1 The assessment of the potential impacts and likely effects as a result of the Proposed Development. The assessment of significance for both the CCR and GHG assessments varies from the standard EIA methodology outlined in more detail in Chapter 2: Approach to Assessment, as described below. Climate Change Resilience 16.5.2 The likelihood and consequence of the climate change impact are combined to assess the significance of effects on receptors, as shown in Table 16.6. The assessment is qualitative and based on professional judgement from knowledge of similar developments, engagement with the wider Project Team and a review of the relevant literature. Table 16.6 – Climate Change Resilience significance matrix Likelihood of climate change impact
Consequence of climate change impact Negligible
Minor
Moderate
Large
Very Large
Very High
Not significant
Significant
Significant
Significant
Significant
High
Not significant
Significant
Significant
Significant
Significant
Medium
Not significant
Not significant
Significant
Significant
Significant
Low
Not significant
Not significant
Not significant
Significant
Significant
Very Low
Not significant
Not significant
Not significant
Not significant
Not significant
16.5.3 The IEMA guidance outlines that an assessment of climate change in-combination with other environmental effects of the Proposed Development (in-combination climate impacts; ICCI) must be included. ICCI is the potential for climate change to exacerbate or ameliorate the potential effects identified within other environmental assessments for the Application Site. The ICCI assessment uses the methodology as part of the environmental topic and applies professional judgement. This assessment is contained in Chapter 17.
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Greenhouse gas emissions 16.5.4 The general approach adopted in the EIA, will be to attribute an effect significance level based on the sensitivity/value of the affected receptor(s) and the magnitude of change arising from the Proposed Development. As there is only one receptor, the climate, it has a consistent sensitivity no matter the location of the emissions source. There is no accepted technical guidance for determining a level of significance (i.e., high or medium) on the sensitivity of the climate. Therefore, the sensitivity of the receptor will not be used to assess significance. 16.5.5 There are currently no agreed thresholds for what level of GHG emissions is considered significant in the context of the EIA Regulations. With regards to assigning significance, the IEMA guidance provides guidance on how to assess GHG emissions in EIA: •
“When evaluating significance, all new GHG emissions contribute to a significant negative environmental effect; however, some projects will replace existing development that have higher GHG profiles. The significance of a project’s emissions should therefore be based on its net impact, which may be positive or negative…...
•
…. Whilst there is no single preferred method to evaluate significance, extensive research is being undertaken to explore significance, thresholds for GHG emission assessments, and science-based targets. “
16.5.6 In the absence of being able to assign a significance level, IEMA provides some further guidance on contextualising a project’s GHG emissions: •
“Under the principle that all GHG emissions might be considered significant, and the ongoing research of how to actually measure significance, it is down to the practitioner’s professional judgement on how best to contextualise a project’s GHG impact. Generating a project’s carbon contribution, will enable the impact of your project, to be contextualised against sectoral, local, or national carbon budgets. This will provide the practitioner and the Local Planning Authority with a sense of scale.”
16.5.7 Therefore, to contextualise the carbon emissions of the Proposed Development, these will be compared to the UK Carbon Budgets (Table 16.7) and RIBA 2030 Climate Change targets (Table 16.8). Although recent case law has made it clear that there is no obligation to do so, further contextualisation against the London carbon budgets will also be considered (Table 16.9). Table 16.7 – National carbon budgets set by the UK Government Carbon budget period Fourth: 2023-2027 Fifth: 2028-2032
UK carbon budget 1,950 MtCO2e 1,725 MtCO2e
Sixth: 2033-2037
965 MtCO2e
Table 16.8 – RIBA 2030 Climate Challenge target metrics for buildings RIBA sustainable outcome metrics Domestic Embodied Carbon (kgCO2e/m2) (Lifecycle stages A-C)
Current benchmarks
2020 Targets
2025 Targets
1000
< 600
< 450
2030 Targets
< 300
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Operational Energy (kWh/m2 /yr)
146
< 105
< 70
< 0-35
Operational Carbon (kgCO2e/m2/yr)
55
< 31
< 16
<5
1100
< 800
< 650
< 500
Operational Energy (kWh/m2 /yr)
225
< 170
< 110
< 0-55
Operational Carbon (kgCO2e/m2/year)
83
<49
<24
<7
Non- domestic Embodied Carbon (kgCO2e/m2) (Lifecycle stages A-C)
Table 16.9 – London Carbon Budgets32 Carbon Budget Period 2023-2027 2028-2032
London Carbon Budget 22.4 MtCO2e 18 MtCO2e
16.5.8 Any magnitude of emitted or avoided GHG emissions makes a cumulative contribution to climate change (adverse or beneficial respectively). 16.5.9 Significance of GHG impacts is assessed in line with IEMA Guidance; a development’s emissions should be based on its net impact over its lifetime, which may be beneficial, adverse or negligible. The evaluation of significance should not just focus on GHG emissions, or the magnitude of those emissions, but whether the Proposed Development contributes to reducing GHG emissions relative to a comparable baseline consistent with a trajectory towards net zero by 2050. 16.5.10 The following terms have been used to define the significance of the effects identified as set out in IEMA Guidance: • Major Negative (significant): the GHG impacts are not mitigated or are only compliant
with do-minimum standards set through regulation, and do not provide further reductions required by existing local and national policy nor make a meaningful contribution to the UK’s trajectory towards net zero. • Moderate Negative (significant): the GHG impacts are partially mitigated and may
partially meet the applicable existing and emerging policy requirements but would not fully contribute to decarbonisation in line with local and national policy goals, falling short of fully contributing to the UK’s trajectory towards net zero. • Minor Negative (not significant): the GHG impacts are fully consistent with applicable
existing and emerging policy requirements and good practice design standards; they are fully in line with measures necessary to achieve the UK’s trajectory towards net zero.
Greater London Authority (2018). ‘London Environment Strategy’. Available at: https://www.london.gov.uk/sites/default/files/implementation_plan.pdf 32
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• Negligible (not significant): the GHG impacts are reduced through measures that go
well beyond existing and emerging policy and design standards for projects of this type, such that radical decarbonisation or net zero is achieved well before 2050. • Positive (significant): the net GHG impacts are below zero, causing a reduction in
atmospheric GHG concentration, whether directly or indirectly, compared to the withoutproject baseline, substantially exceeding net zero requirements with a beneficial climate impact.
16.6 Baseline Conditions 16.6.1 This section outlines the existing baseline conditions of the Site. Climate Change Resilience 16.6.2 The latest State of the UK Climate Report22 summarises that the UK has warmed at a consistent rate with global mean temperatures, with observations that the UK extremes of temperatures are changing much faster than the average temperatures. The period 2013 – 2022 has been 25% wetter than 1961 – 1990, whilst January – August 2022 was the driest across England and Wales since 1976. The UK annual mean wind speed has decreased, consistent with trends globally. Widespread and substantial snow events have occurred, but their number and severity are generally declining. 16.6.3 The Site is located in the Met Office climate profile of Southern England23 which is subject to continental weather influences that bring cold spells in the winter and hot, humid weather in the summer. Much of Southern England, specifically around the Thames Estuary is sheltered from the Atlantic depressions, making it some of the driest parts of the region. However, Southern England is subject to summer thunderstorms and associated high intensity summer rainfall. 16.6.4 The northern half of the Site is located within Flood Zone 3, and a third of the Site is within Flood Zone 3b, the functional flood plain of the River Ravensbourne and the River Quaggy. A revised flood map based on site topography has demonstrated that this area of Flood Zone 3 is much lower, approximately 10%. The northern part of the site and surrounding streets are also subject to surface water flooding, similar in extent and severity to the fluvial flood risk. Refer to the Flood Risk Assessment (Appendix 9.1) for further details. 16.6.5 The average monthly climate data at Greenwich Park Weather station24 (approximately 1.6 km north of the Proposed Development and the most representative weather station in proximity) for the period of 1990-2020 are summarised in Table 16.10. The seasonal averages in temperature and precipitation reflect the summary climate profiles of the region described above. Table 16.10 - Greenwich Park Average Monthly Climate Month
January February March
Maximum temperature (°C)
Minimum temperature (°C)
Mean temperature (°C)
Days of air frost (days)
Sunshine (hours)
Rainfall (mm)
Days of rainfall ≥1 mm (days)
8.47 9.21 12.07
3.36 3.22 4.66
5.915 6.215 8.365
5.90 5.86 2.07
44.42 66.11 109.71
43.93 39.85 36.52
10.47 9.18 7.94
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April May June July August September October November December Seasonal averages: Winter Summer Annual
15.35 18.59 21.37 23.75 23.31 20.29 15.83 11.55 8.85
6.02 9.06 12.04 13.93 14.08 11.57 8.99 6.09 3.77
10.685 13.825 16.705 18.84 18.695 15.93 12.41 8.82 6.31
0.64 0.03 0.00 0.00 0.00 0.00 0.29 1.77 6.50
152.85 198.68 198.55 209.24 198.02 140.58 99.66 58.50 50.09
38.63 43.99 49.34 36.30 53.02 52.38 58.34 59.85 50.71
8.07 7.91 7.75 7.06 8.15 7.92 10.27 10.63 10.24
8.84 22.81 15.72
3.45 13.35 8.07
6.15 18.08 11.89
18.26 0.00 23.06
160.62 605.81 1526.41
134.49 138.66 562.86
29.89 22.96 105.59
Greenhouse Gas Emissions 16.6.6 The existing site comprises the Lewisham Shopping Centre: a range of retail units; a multistorey car park; 18-storey vacant former office building (Lewisham House); vacant leisure box and Riverdale Hall; and commercial properties on the High Street. The baseline conditions for the GHG assessment therefore relate to the current energy use of the Shopping Centre, as well as traffic flows generated by users of the Shopping Centre. 16.6.7 The baseline conditions for the Greenhouse Gas (GHG) assessment are determined by the current energy consumption and traffic patterns associated with the Lewisham Shopping Centre. Key consideration is the energy use of the existing building. The energy consumption of the existing retail units, car park, and other facilities within the shopping centre. According to the latest Energy Performance Certificates (EPCs), the shopping centre has an average energy rating of D. CIBSE TM46 provides energy benchmarks with an estimated annual energy consumption shown in Table 16.11. This is based on 31,000m2 of current commercial floor area and an 800-space car park. Table 16.11 Current baseline emissions – energy use (B6) Use
Benchmark
Retail (general)
165 kWh/m2
Total annual energy use (kWh) 5,115,000
Car park (mostly covered)
20 kWh/m2
160,000
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Additionally, the latest summary of GHG emissions for 2022 for Lewisham Council, London and the UK are presented in
16.6.8 Table 16.12. The emissions sources are a subset of the total emissions for each region, chosen for their relevance to the Proposed Development. These emissions have only been provided for context and are not the baseline emissions for this assessment.
Table 16.12 - Emissions Sources (2022) for Lewisham, London and the UK
Emission Sources
Lewisham (ktCO2e)
London Total (ktCO2e)
Industry Electricity
5.7
503.9
UK National Total (ktCO2e) 11,642.40
Industry Gas
1.2
471.9
14,197.00
Large Industrial Installations
0.1
43.2
26,157.20
Industry 'Other'
8.9
626.7
10,347.40
Commercial Electricity
40.0
3,720.90
19,072.80
Commercial Gas
54.4
2,384.20
12,543.00
Commercial 'Other'
4.2
361.8
2,280.00
Public Sector Electricity
10.4
580
3,611.10
Public Sector Gas
15.5
963.5
7,019.40
Public Sector 'Other'
3.4
158
1,064.30
Domestic Electricity
78.7
2,468.50
20,500.10
Domestic Gas
224.8
6,892.00
53,287.50
Domestic 'Other'
2.6
99.9
10,477.40
Road Transport (A roads)
82.4
3,622.10
44,172.80
Road Transport (Motorways)
0.0
526.6
23,978.40
Road Transport (Minor roads)
107.9
3,095.90
41,783.30
Diesel Railways
2.2
85.5
1,593.40
Transport 'Other'
1.7
187.2
3,128.50
Landfill
14.0
1,304.50
13,473.40
Waste 'Other'
7.9
379
5,260.40
Grand Total
668.2
28,563.30
3,75,929.30
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16.6.9 These baseline conditions provide a reference point against which the potential impacts of the redevelopment project on GHG emissions can be assessed.
16.7 Future Baseline 16.7.1 This section outlines the future baseline conditions of the Site. Climate Change Resilience 16.7.2 Changes in climate are projected to lead to warmer, wetter winters and hotter, drier summers. However, natural variations including extreme events such as storms and heat waves, will continue to punctuate these trends22. 16.7.3 UKCP18 and the Climate Risk Indicators tool has been used to derive the future climate change projections data presented in Table 16.13 for RCP8.5 for the Lewisham Local Authority Area.
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Table 16.13 – Future Climate Change Projections Climate Variable
Unit
Model Reference (1981-2010)
Climate Projections RCP8.5 50th (90th)
Current Baseline (1991-2020) 2030
2060
2080
(2021–2050)
(2051-2080)
(2071–2100)
Average summer temperature (JJA)
°C
17.8 °C
18.1 °C
+1.6 (+2.4)
+3.5 (+5.3)
+5.3 (+7.8)
Average winter temperature (DJF)
°C
5.7 °C
6.2 °C
+1.0 (+1.8)
+2.2 (+3.6)
+3.2 (+5.1)
Max summer temperature (JJA)
°C
22.5 °C
22.8 °C
+1.7 (+2.9)
+4.0 (+6.1)
+5.9 (+9.0)
Min winter temperature (DJF)
°C
3.1 °C
3.5 °C
+1.0 (+2.0)
+2.3 (+4.0)
+3.3 (+5.7)
Change in winter precipitation (DJF)
% 126 mm change
134 mm
+7.0 (+17.3)
+13.8 (+32.6)
+21.0 (+46.5)
Climate Variable
Unit
Current Baseline (1991-2020)
Change in summer precipitation (JJA)
Model Reference (1981-2010)
% 136 mm change
Lewisham Shopping Centre Volume 1: Environmental Statement – Main Text Chapter 16: Climate Change
138 mm
Climate Projections RCP8.5 50th (10th) 2030
2060
2080
(2021–2050)
(2051-2080)
(2071–2100)
-9.6 (-25.9)
-24.2 (-46.7)
-35.9 (-60.6)
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Temperature: 16.7.4 Table 16.13 shows the increasing trend in average summer and winter temperatures, as well as an increase in maximum summer temperatures. This coincides with an increase in incidences of extreme heat and heatwave events. 16.7.5 Winter temperatures are projected to increase, moving minimum temperatures into a range already experienced, and decreasing the number of low temperature events, although cold snaps could still occur. This trend is also likely to reduce the amount of precipitation that falls as snow. Precipitation: 16.7.6 Table 16.13 reflects the qualitative information for the region whereby the region experiences less winter precipitation compared to the rest of England, however under climate change projections, winter precipitation is anticipated to increase e.g. by 21% under RCP8.5 50% by the 2080s. Currently, the average rainfall (mm) in summer and winter is similar; however, under climate change projections, summer precipitation is anticipated to decrease e.g. by 36% under RCP8.5 50% by 2080s. Natural variations, including extreme precipitation events such as storms and resultant flooding, will continue to punctuate these trends across the year. 16.7.7 The Flood Risk Assessment demonstrates the portion of the Site which is affected by the 1 in 100 year event plus 20% climate change allowance. Wind: 16.7.8 The Global projections over the UK show an increase in near surface wind speeds over the UK for the second half of the 21st century for the winter season when more significant impacts of wind are experienced33. UKCP18 guidance depicts a wide spread of future changes in mean surface wind speed, however, there is large uncertainty in projected changes in circulation over the UK, and natural climate variability contributes much of this uncertainty34. Studies relating to future projections of storms suggest that climate-driven storm changes are less distinct in the northern than southern hemisphere35,36
33
Met Office. (2018). UKCP18 Factsheet: Wind. Available at: https://www.metoffice.gov.uk/binaries/content/assets/metofficegovuk/pdf/research/ukcp/ukcp18-fact-sheet-wind.pdf 34
Brown, S., Boorman, P., McDonald, R., and Murply, J. (2012). Interpretation for use of surface wind speed projections from the 11member Met Office Regional Climate Model ensemble. Post-launch technical document for the UKCP09. Met Office Hadley Centre, Exeter, Uk. Crown copyright. 35
Slingo, J., Belcher, S., Scaife, A., McCarthy, M., Saulter, A., McBeath, K., Jenkins, A., Huntingford, C., Marsh, T., Hannaford, J. and Parry, S. (2014) The recent storms and floods in the UK, Met Office, Exeter, 29pp. Available at: https://nora.nerc.ac.uk/id/eprint/505192/1/N505192CR.pdf 36
Bengtsson, Lennart & Hodges, Kevin & Roeckner, Erich. (2006). Storm Tracks and Climate Change. Journal of Climate. 19. 10.1175/JCLI3815.1. Available at: https://journals.ametsoc.org/view/journals/clim/19/15/jcli3815.1.xml
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GHG Assessment 16.7.9 No traffic growth has been applied to the base data when forming the assessment scenarios given that traffic growth in the area has been decreasing over the last 20 years. This is evident from the DfT traffic count data between 2002 and 2022 at locations around the Site. Further detail is found within the Transport Assessment (Volume 3B). 16.7.10 There is a national target for continued decarbonisation of grid supplied electricity as the UK electricity mix will have an increasingly greater share of low and zero carbon technologies. The operational emissions associated with the use of grid electricity within the Proposed Development will benefit from this. 16.7.11 The UK has committed to becoming net-zero carbon by 2050 with a continued focus on the reduction of GHG emissions aligned with the carbon budgets, in addition to this, the Government has set out the Future Homes standard which proposes no new gas boilers should be installed in new homes from 2025, meaning that new homes will be heated solely by electric systems (such as heat pumps) or other alternatives, which will be low in GHG emissions following grid decarbonisation.
16.8 Sensitive Receptors 16.8.1 The following are the sensitive receptors which will be considered in the following assessment: Climate Change Resilience 16.8.2 The following potential sensitive receptors have been identified as being relevant to the climate change resilience assessment associated with the scoped in effects of the operational phase: •
Residential buildings (dwellings, shared living homes and student homes);
•
Non-residential buildings and businesses;
•
Access roads and other ancillary infrastructure;
•
Open space and green infrastructure;
•
End users and visitors.
Greenhouse Gas Emissions •
The impacts of GHG emissions relate to their contribution to global warming and climate change. These impacts are global and cumulative in nature, with every tonne of GHG contributing to impacts on natural and human systems. The receptor is therefore the global atmosphere. •
GHG emissions result in the same global effects wherever and whenever they occur. Therefore, the sensitivity of different human and natural receptors is not considered in this assessment.
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16.9 Assessment of Effects, Mitigation and Residual Effects Climate Change Resilience Demolition & Construction Phase 16.9.1 Climate change effects during the construction phase was scoped out of further assessment given the mitigation measures identified above will be implemented and monitored as outlined in the CEMP. Operational Phase 16.9.2 This section identifies and assesses the scale and nature of the main effects arising from the Proposed Development during the operational phase and are presented in Table 16.14.
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Table 16.14 Likely significant effects assessment – Climate Change Resilience - Operation Climate change trend
Extreme precipitation events.
Receptor (asset)
Residential and nonresidential buildings.
Potential climate change impact
Flooding (pluvial or fluvial) may lead to damage of the buildings.
Control measures (mitigation)
Masterplan The built footprint has been reduced slightly to allow for the Flood Zone 3b to the north of the Site. The Finished Floor Levels (FFL) have been raised at least 300mm above the 1 in 100 year fluvial flood levels plus a 20% allowance for climate change, as discussed within the Flood Risk Assessment (Appendix 9.1). This is not possible everywhere across the masterplan due to tying into existing levels of surrounding streets, including for parts of Block N1 and Block N2 within the detailed application and sections of the outline application (Lewisham House to the north of the site). For buildings not set above the flood level, there will be additional flood resilience measures, such as demountable flood defences on doors to ground floor units. Furthermore, no residential development is proposed on the ground floor. Robust finishes will be designed to withstand water damage. All sensitive equipment such as power sockets will be set above the 1 in 100 year + 20% design level, and plant will be set above this level sometimes using a plinth.
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Residual effect (following mitigation) Likelihood
Consequence
Significance
Medium
Minor
Not significant
Climate change trend
Receptor (asset)
Potential climate change impact
Control measures (mitigation)
Residual effect (following mitigation) Likelihood
Consequence
Significance
EA Flood Warning Alerts will be connected to the building management system, and occupants will be encouraged to receive warnings. Maintenance and management will occur over the design life. Extreme rainfall events can destabilise soils and earthworks, potentially leading to damage to buildings.
Masterplan - detailed design of the foundations will take into account ground conditions and changing soil moisture with climate change.
Low
Moderate
Not significant
Access roads and other ancillary infrastructure
Flooding can cause damage to surfaces leading to deterioration of materials and increased maintenance requirements.
Masterplan – SUDS and permeable paving is proposed, where suitable, in parts of the Site to manage pluvial flood risk and damage to surfaces. During detailed design, infiltration testing will take place to identify opportunity for surface water flows to infiltrate to ground.
Medium
Minor
Not significant
Open space and green infrastructure
Flooding can cause damage or death to landscaping.
Masterplan - surface water runoff will be controlled at source with green roofs and the extensive soft landscaping and two-level podiums. Raingardens and filter drainage and two attenuation ponds are also proposed. The landscaping is designed to tolerate wet conditions.
Low
Negligible
Not significant
End users and visitors
Flooding can cause buildings to be unable to be occupied or cause damage to homes, roads to be impassable and cause dangerous driving conditions.
Masterplan - no residential development is proposed to be on the ground floor and safe emergency access and egress strategy is presented in the Flood Risk Assessment (Appendix 9.1).
Medium
Minor
Not significant
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Climate change trend
Drought
Receptor (asset)
Potential climate change impact
Control measures (mitigation)
Residual effect (following mitigation) Likelihood
Consequence
Significance
Residential and nonresidential buildings
Prolonged dry periods can lead to drying out and cracking of earthworks and soils, and greater amounts of dust and building damage.
Masterplan – the detailed design of the foundations will take into account ground conditions and changing soil moisture with climate change.
Low
Moderate
Not significant
Access roads and other ancillary infrastructure
Prolonged dry periods can lead to drying out and cracking of earthworks and soils, and greater amounts of dust and building damage.
Masterplan – the detailed design of the access roads will take into account ground conditions and changing soil moisture with climate change.
Medium
Minor
Not significant
Open space and green infrastructure
Changes to growing seasons and potential water shortages for vegetation can result in death of vegetation.
Masterplan - the species selection for the landscaping will be chosen for benefits of drought tolerance and hardiness to weather extremes and low irrigation requirements.
Medium
Negligible
Not significant
Medium
Minor
Not significant
There will be an efficient automated irrigation system and permanent water body retention pond in the masterplan. In instances of drought conditions, there is proposed rainwater harvesting for podium planting irrigation. The Landscape and Habitat Management Plan will be in place for ongoing success of the landscaping. End users and visitors
Prolonged dry periods can cause water shortages for the end user.
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Masterplan - the design of plots N1, N2 and the wider masterplan meet the 105 litre per person per day target, reducing demand on potable water during periods of dry conditions.
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Climate change trend
Extreme temperature events.
Receptor (asset)
Residential and nonresidential buildings.
Potential climate change impact
Drier and hotter summers can lead to heat and UV damage to buildings.
Control measures (mitigation)
Masterplan – the introduction of green spaces reduces the urban heat island effect.
Residual effect (following mitigation) Likelihood
Consequence
Significance
Low
Minor
Not significant
High
Negligible
Not significant
The detailed design of components will consider materials selection designed to promote longevity and materials in the façade design will be robust and resilient in line with Design Codes. Residential and nonresidential buildings.
Increased energy needs of the buildings for cooling.
Detailed – the energy hierarchy has been followed to firstly reduce the energy consumption of the building and minimise the cooling and heating requirements such as façade optimisation. On-site renewable energy technologies are also considered for inclusion. This is detailed within the Energy Strategy (WSP, 2024). Outline – Part L analysis of non-residential buildings will be undertaken which will inform MEP services strategy.
Access roads and other ancillary infrastructure
High temperatures can cause damage to paved surfaces, including potential melting and deformation. An increase in solar radiation can also cause more rapid deterioration of materials and associated infrastructure such as signage.
Masterplan – during the detail design, materials will be designed and specified for longevity in line with Design Codes. Maintenance activities will identify any maintenance or replacement of assets.
Low
Minor
Not significant
End users and visitors
High temperatures can lead to overheating in occupied spaces and associated health
Detailed
Medium
Minor
Not significant
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Climate change trend
Receptor (asset)
Potential climate change impact
implications for end users.
Control measures (mitigation)
Residual effect (following mitigation) Likelihood
Consequence
Significance
Low
Moderate
Not significant
For buildings N1/N2 the cooling hierarchy has been implemented and a cooling analysis. Buildings N1/N2 maximise natural ventilation with openable windows to allow for passive ventilation and the orientation and massing has considered its position and relative shading whilst maximising daylight opportunities. Façade options have been studied to minimise heat loss and solar gains, and to investigate the introduction of external shading measures and glazing ratio optimisation. As such, N1/N2 comply with CIBSE TM59 for the current weather file for both window open and window closed scenarios. Simulations were run for projected future weather data, which shows several spaces exceeding the criteria. Adaptive capacity options which will be investigated at detailed design include increase of window glass specification, external shading, increased mechanical ventilation rates, provide active form of cooling at a later date. There is space within plant rooms and utility cupboards to accommodate this. Masterplan The remaining buildings will undergo overheating analysis.
Gales and extreme wind events, storms (lightning, hail)
Residential and nonresidential buildings
High winds and storms can affect the stability of above-ground infrastructure and hasten material degradation due
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Masterplan – during the detailed design, waterproofing and barriers will be specified for vulnerable materials to reduce the impact of driving rain, alongside lightning protection.
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Climate change trend
Receptor (asset)
Potential climate change impact
Control measures (mitigation)
Residual effect (following mitigation) Likelihood
Consequence
Significance
to wind-driven rain infiltration.
Monitoring and maintenance procedures will identify deterioration of materials.
Access roads and other ancillary infrastructure
High winds, storms and lightning strikes can damage associated infrastructure such as signage or signals.
Masterplan - monitoring and maintenance procedures will identify damage of associated infrastructure.
Medium
Minor
Not significant
Open space and green infrastructure
High winds and storms can damage vegetation.
Masterplan – once established, the vegetation is considered more resilient, and vegetation is largely low level and protected within the development.
Low
Negligible
Not significant
End users and visitors
Road users and cyclists can be sensitive to high winds.
Masterplan – residents are encouraged to sign up to the EA flood alerts, where coupled with high winds, to encourage journeys to be postponed in the event of storms.
Low
Moderate
Not significant
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Greenhouse Gases 16.9.3 The Whole-Life Carbon (WLC) Assessment for the Proposed Development was conducted following industry standards and guidelines, including BS EN 15978:2011 and the RICS Professional Statement: Whole Life Carbon Assessment for the Built Environment (2nd Edition, 202320). The assessment covers a 60-year study period and includes all life-cycle modules, with the reporting split into two key sections: the Outline and Detailed Components of the scheme. Outline Assessment 16.9.4 For the Outline Component, the assessment includes all buildings and external areas within the masterplan application red line boundary. Due to limited details available at this stage, the calculations are based on embodied carbon target assumptions for each building typology, referencing usage, massing, and the outline energy strategy assumed across the wider site. 16.9.5 Data collection involved gathering information from the latest RIBA Stage 2 cost plan used within the Whole Life Carbon Assessment. Embodied carbon was calculated using One Click LCA software, covering modules A1-A5 (product stage and construction process stage), B1-B5 (use stage), and C1-C4 (end-of-life stage). Operational emissions B6 were included based on information contained within the Energy Strategy, accounting for grid decarbonisation across the lifecycle of the Proposed Development. In-use emissions B7 related to transport to/from the development by users and visitors, and service vehicles were based on information contained within the Transport Assessment. 16.9.6 The results of the WLC assessment for the Outline assessment are summarised here. Table 16.15 WLC Assessment – Outline assessment Phase
GHG Emissions (kgCO₂/m²) GHG Emissions (tCO₂) Percentage of Total Emissions
Construction (A1-A5)
633
148,330
58%
Operation (B1-B5)
310
72,640
29%
Operation (B6)
n/a
10,970
4%
Operation (B7)
n/a
17,560
7%
End of Life (C1-C4)
22
5,155
2%
Total
100%
Note: Totals may not sum due to rounding in reporting
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16.9.7 The construction phase (A1-A5) is the most significant contributor to GHG emissions, accounting for approximately 58% of the total emissions. This high percentage is primarily due to the extensive use of carbon-intensive materials such as concrete and steel, as well as the transportation of these materials to the construction site. 16.9.8 The operational phase (B1-B5), which includes maintenance, repair, and replacement activities, is another major hotspot, contributing around 29% of the total emissions. These emissions relate primarily to the materials needed for ongoing maintenance. 16.9.9 Other emissions during operation include energy use (B6) which has been calculated sharing around 4% of the total emissions and this is based on decarbonisation of the grid as defined by the Green Book.37 In-use emissions associated with transport of people and services to/from the development is around 7% of the share. 16.9.10 The end-of-life phase (modules C1-C4) are associated with the demolition and disposal of building materials and is very low (~2%) in terms of the lifecycle assessment. Adopting circular economy principles, such as recycling and reusing materials, can significantly reduce the impact of this phase. Detailed Assessment 16.9.11 For the Detailed Component, the assessment focuses on two specific plots, N1 and N2, within the development. Each plot was assessed independently, with individual modelling carried out per plot. Building-specific inputs were gathered from the cost plan information for N1 and N2. 16.9.12 Embodied carbon was calculated using One Click LCA software, with data reference product specifications used where other design information was not reported. Industry benchmarks were used for maintenance, repair, and replacement cycles where specific information was unavailable. Operational emissions were calculated based on energy modelling methods agreed for the planning stage Energy Statement, including both regulated and unregulated emissions. In line with the Outline Component, assumptions were made regarding the recycling and disposal of materials at the end of the building’s life. 16.9.13 here.
The results of the WLC assessment for the Detailed assessment are summarised
Table 16.16 WLC Assessment – Detailed assessment Phase
GHG Emissions (kgCO₂/m²) GHG Emissions (tCO₂) Percentage of Total Emissions Plot N1
Construction (A1-A5)
627
12,360
58%
Operation (B1-B5)
309
6,090
28%
37
DEZNZ (2023) Green Book Supplementary Guidance: valuation of energy use and greenhouse gas emissions for appraisal (Online). Available at: https://www.gov.uk/government/publications/valuation-of-energy-use-and-greenhouse-gas-emissions-for-appraisal
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Operation (B6)
n/a
1,140
5%
Operation (B7)
n/a
1,480
7%
End of Life (C1-C4)
19
370
2%
Total
100% Plot N2
Construction (A1-A5)
597
8,040
64%
Operation (B1-B5)
206
2,775
22%
Operation (B6)
n/a
580
5%
Operation (B7)
n/a
1,009
8%
End of Life (C1-C4)
5
70
1%
Total
100%
Note: Totals may not sum due to rounding in reporting
16.9.14 The detailed assessment of the Proposed Development reveals several key hotspots of emissions. For both Plot N1 and Plot N2, the construction phase (modules A1-A5) is the most significant contributor to the overall GHG emissions. This high percentage is primarily due to the extensive use of concrete and steel in the building’s substructure and superstructure, which are known for their high embodied carbon. 16.9.15 Another major hotspot is the operational phase (modules B1-B5), which includes maintenance, repair, and replacement activities. For Plot N1, this phase contributes 28% of the total emissions and for Plot N2, the operational phase contributes 22%. These emissions are driven by the materials needed for ongoing maintenance and repairs. The use of energyefficient systems and sustainable materials can help mitigate these emissions. EMBEDDED MEASURES 16.9.16 Embedded measures are design and management mitigation measures which have already been incorporated into the assessment of the Proposed Development. Where other mitigation is required to reduce or avoid a significant effect, this is referred to as secondary or additional mitigation. 16.9.17 The main mitigation measures from the WLC assessment are suggested based on the potential to reduce the GHG emissions from the Proposed Development which are detailed within the Whole Life Carbon assessment (Bioregional, 2024) and Energy Strategy (WSP, 2024). 16.9.18 These mitigation measures not only help in achieving the GLA's aspirational benchmarks but also support the broader goal of minimizing the GHG impact of the redevelopment, contributing to a more sustainable and resilient urban environment.
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Comparison with UK Carbon budgets 16.9.19 The total estimated GHG emissions arising from the Proposed Development are presented in Table 16.17. The Proposed Development GHG emissions have been put into context of the UK National Carbon Budgets for the entire construction, operation and decommissioning phases. The WLC operational phase emissions over the 60-year period and annual emissions have been used for significance analysis. Table 16.17: Proposed Development Impacts on Carbon Budgets – Whole project (outline and detailed) Stage / Timing
Total GHG Emissions (tCO2e)
Construction phase (A1 – A5)
168,730
Operation phase (B1-B7) (2028 – 2088)
114,255
Decommissioning (C1-C4) (Post 2088)
5,595
Total whole life carbon (60 years)
293,130
Comparison of the Proposed development GHG Emissions against UK National Carbon Budget Budget (tCO2e)
Total GHG Emissions (tCO2e)
Total tCO2e during fourth Carbon Budget period (2023-2027)
1,950,000,000
168,730
Total tCO2e during fifth Carbon Budget period (2028-2032)
1,725,000,000
Total tCO2e during sixth Carbon Budget period (2033-2037)
965,000,000
Total tCO2e beyond 2037 (no Carbon Budget set yet) till 2088 (end of operational phase and decommissioning)
N/A
(<0.1%) 9,520 (<0.1%) 9,520 (<0.1%)
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16.10 Limitation and Assumptions Climate Change Resilience 16.10.1 UKCP18 is the result of a programme of work by the Met Office’s Hadley Centre Climate Programme and contributing organisations. UKCP18 provides the most up-to-date assessment of how the climate of the UK may change over the 21st Century. However, climate change, by its very nature, is associated with a range of assumptions and limitations. For example, there is uncertainty in climate models regarding how global climatic trends will be reflected at the regional and local scale. The future baseline represents projections under a single ‘high emissions’ future scenario (RCP8.5) and cannot be treated as a prediction. Data for the 10%, 50% and 90% probability levels for the high emissions scenario (RCP8.5) have been used in the assessment to highlight uncertainty and ensure a conservative assessment of risk. The 10%, 50% and 90% probability levels correspond to the low, central and high changes in the probabilistic projections. Leading climate change data from the UKCP18 programme has been used to explore trends and magnitude of change at the regional scale. Greenhouse Gases •
The outline component assessment has limited detailed design information, leading to the reliance on assumptions and industry benchmarks. Assumptions are made based on the building’s massing, intended usage, and preliminary architectural designs.
•
Estimated operational emissions are based on calculations carried out for the Detailed components of the Proposed Development.
•
These calculations align with Part L of the Building Regulations as part of the planning stage energy submission.
•
Unregulated energy consumption is estimated using the same modeling process.
•
Estimates include circular economy metrics relating to the expected end of life for key construction, demolition, and excavation arisings.
•
The main assessment is based on specifications established as reasonable design assumptions, ensuring a robust and comparable position to develop as the designs progress.
•
The One Click LCA software is used for embodied carbon calculations, ensuring alignment with recognized standards like ISO 14040/44.
•
Environmental product declarations (EPDs) and third-party verified data are used where available to enhance calculation accuracy.
•
Generic carbon factor databases are utilized in the absence of specific data, providing a basis for initial calculations.
•
The assessment captures all life cycle stages from raw material extraction (A1) to material disposal (C1-C4), but it assumes zero impact for module A0 (nonphysical process before construction).
•
Comparison with GLA and RIBA 2030 benchmarks assumes that these benchmarks remain constant, whereas they may be updated or revised in future.
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16.11 Cumulative Effects Climate Change Resilience 16.11.1 The CCR assessment is an assessment of the resilience of the Proposed Development to projected climate change. The resilience of the Proposed Development assets is unaffected by other developments. Greenhouse Gases 16.11.2 The approach to cumulative effects assessment for GHGs differs from that for many EIA topics. All global cumulative GHG sources are relevant to the effect on climate change, and this is taken into account in defining the receptor as being of ‘high sensitivity’. The contextualisation of GHG emissions, by its nature, incorporates the cumulative contributions of other GHG sources which make up that context. Therefore, it has not been necessary to carry out a separate cumulative effects assessment of GHG emissions. This approach is in accordance with IEMA Guidance.15
16.12 Summary Climate Change Resilience 16.12.1 The CCR assessment has concluded that there are likely to be no significant effects remaining following the assessment of climate change impacts during operation/use of the Proposed Development. This is because all relevant and implementable measures have been embedded into the proposals and are likely to be effective and deliverable. Greenhouse Gases 16.12.2 The GHG assessment has concluded that there are likely to be no significant effects remaining following the assessment of climate change impacts during operation/use of the Proposed Development. This is because all relevant and implementable measures have been embedded into the proposals and are likely to be effective and deliverable.
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Table 16.18 Summary of Effects
DESCRIPTION RECEPTOR SIGNIFICANCE OF EFFECTS OF SIGNIFICANT MAJOR / POSITI P / D / I ST / EFFECTS MODERATE VE / T MT / / MINOR / NEGATI LT NEGLIGIBLE VE Demolition & Construction GHG Global Negligible Negativ P D MT environment e
SUMMARY OF MITIGATION / ENHANCEMENT MEASURES
As detailed in Whole Life Negligible Carbon assessment (Bioregional, 2024) and Energy Strategy (WSP, 2024).
Negative P
D
MT
CCR
The Project
SIGNIFICANCE OF RESIDUAL RELEVANT RELEVANT EFFECTS POLICY LEGISLATIO N MAJOR / POSITIV P / D / I ST / MODERATE E / T MT / / MINOR / NEGATIV LT NEGLIGIBLE E
Negligible
Negativ T e
D
MT
CEMP
Negligible
Negative T
D
MT
GHG
Global Negligible environment
Negativ P e
D
LT
As detailed in Whole Life Negligible Carbon assessment (Bioregional, 2024) and Energy Strategy (WSP, 2024).
Negative P
D
LT
CCR
The Project
Overall Minor Negativ P e
D
LT
As detailed in Table 16.14
Negative P
D
LT
London Plan Climate SI1 Change Act 2008; Carbon Budget Order 2021 London Plan Climate GG6 Change Act 2008
Operation
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Overall Minor
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London Plan Climate SI1 Change Act 2008; Carbon Budget Order 2021 London Plan Climate GG6 Change Act 2008
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17.0 Effect Interactions 17.1 Assessment of Intra-Project Cumulative Effects 17.1.1 As there is no established EIA methodology for assessing and quantifying the combined effects of individual effects on sensitive receptors, the following approach therefore uses the defined residual effects outlined with the Technical Chapters of the ES to determine the potential for interactions between effects, and consequently the potential for significant intraproject cumulative effects. 17.1.2 This section provides an assessment of potential effect interactions between the relevant environmental topics on identified sensitive receptors during construction and operation of the Proposed Development. The results of the assessment presented in this section are following implementation of the recommended mitigation measures, as described with Chapters 6 – 16 and Volume 2. 17.1.3 The effect interactions presented in Tables 17.10 and 17.11 below are based on professional judgements made by technical specialists who have completed the technical assessments, taking into account the baseline conditions at the Site and in the surrounding area together with the findings from the various technical studies. To ensure a proportionate approach, both negligible and neutral effects have been disregarded. 17.1.4 In terms of effect interactions, the following sensitive receptors have been identified due to their sensitivity as assessed in this ES: •
Existing residential uses in the surrounding area;
•
Future on-site residential uses;
•
Existing and future commercial users of the Site and surrounding area;
•
Existing below and above ground heritage assets;
•
Social Infrastructure.
Effect Interactions During Demolition and Construction 17.1.5 Table 17.10 comprises a summary matrix for the demolition and construction works, showing the potential effect interactions following implementation of the recommended mitigation measures, based on the assessments presented within Chapter 6 – 16 and Volume 2.
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Table 17.10: Matrix of Residual Effect Interactions – Demolition and Construction Phase Receptor
Residual Effect
Residential Dwellings – Existing surrounding the Site
Noise and Vibration
Scale and Nature of Residual Effects
Yes.
Noise from construction works
Minor Negative (Not Significant)
Vibration from construction works
Minor Negative (Not Significant)
Visual Local residents, users of the town centre facilities and commuters
Existing and Future Commercial Uses
Minor to Moderate Adverse (Significant)
Noise and Vibration Minor Negative (Not Significant)
Vibration from construction works
Minor Negative (Not Significant)
Visual
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These effects are considered to have the potential to interact to produce an intra-project cumulative effect. Considering the collective weight of the effects’ significance and nature, a Minor Negative (Not significant) to Moderate Adverse (Significant) effect is anticipated. Yes.
Noise from construction works
Local residents, users of the town centre facilities and commuters
Potential for Intra-Project Cumulative Effects / Effect Interactions
Minor to Moderate Adverse (Significant)
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These effects are considered to have the potential to interact to produce an intra-project cumulative effect. Considering the collective weight of the effects’ significance and nature, a Minor Negative (Not significant) to Moderate Adverse (Significant) effect is anticipated.
Residential Dwellings – Future on Site
Noise and Vibration
Yes.
Noise from construction works
Minor Negative (Not Significant)
Vibration from construction works
Minor Negative (Not Significant)
Visual Local residents, users of the town centre facilities and commuters
Aquifers
Drainage Pollution caused by demolition and construction works
Below ground heritage assets
Minor to moderate negative (significant)
No.
No Effects to interact with.
No Effects to interact with. No.
Minor negative (not significant)
No Effects to interact with.
Locally listed buildings
Minor adverse (not significant)
No.
Buildings of townscape merit
Moderate adverse (significant)
No Effects to interact with.
Heritage
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No.
Socio-economics Loss of employment
Heritage
Negligible to minor negative (not significant)
Archaeology Site preparation and piles
Employment
Minor to Moderate Adverse (Significant)
These effects are considered to have the potential to interact to produce an intra-project cumulative effect. Considering the collective weight of the effects’ significance and nature, a Minor Negative (Not significant) to Moderate Adverse (Significant) effect is anticipated.
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Townscape
Townscape Town centre
Minor adverse (not significant)
No. No Effects to interact with.
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Effect Interactions During Operation 17.1.6 Table 17.11 comprises a summary matrix for the operation phase, showing the potential effect interactions following implementation of the recommended mitigation measures, based on the assessments presented within Chapter 6 – 16 and Volume 2
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Table 17.11: Matrix of Residual Effect Interactions – Operational Phase Receptor
Residual Effect
Residential Dwellings – Existing surrounding the Site
Noise and Vibration
Scale and Nature of Residual Effects
Yes.
Noise from building services
Minor negative (not significant)
Noise from operational activity
Minor negative (not significant)
Transport Severance
Minor positive (not significant)
Daylight. Sunlight Daylight, sunlight, overshadowing and solar glare
Negligible to Major Negative (significant)
Wind Pedestrian comfort and safety
Major negative (significant)
Socio-economics Employment
Minor positive (not significant)
Housing
Moderate positive (significant)
Demand on healthcare
Minor negative (not significant)
Open space provision
Moderate positive (significant)
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Potential for Intra-Project Cumulative Effects / Effect Interactions
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These effects are considered to have the potential to interact to produce an intra-project cumulative effect. Considering the collective weight of the effects’ significance and nature, a Major Beneficial to Major Negative (Significant) effect is anticipated.
Visual Local residents, users of the town centre facilities and commuters
Existing and Future Commercial Uses
Minor to Major beneficial (significant)
Noise and Vibration
Yes.
Noise from building services
Minor negative (not significant)
Noise from operational activity
Minor negative (not significant)
Transport Severance
Minor positive (not significant)
Daylight. Sunlight Daylight, sunlight, overshadowing and solar glare
Negligible to Major Negative (significant)
Wind Pedestrian comfort and safety
Major negative (significant)
Socio-economics Employment
Minor positive (not significant)
Housing
Moderate positive (significant)
Demand on healthcare
Minor negative (not significant)
Open space provision
Moderate positive (significant)
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These effects are considered to have the potential to interact to produce an intra-project cumulative effect. Considering the collective weight of the effects’ significance and nature, a Moderate Positive to Major Negative (Significant) effect is anticipated.
Increased spend
Residential Dwellings – Future on Site
Minor positive (not significant)
Noise and Vibration
Yes.
Noise from building services
Minor negative (not significant)
Noise from operational activity
Minor negative (not significant)
Transport Severance
Minor positive (not significant)
Daylight. Sunlight Daylight, sunlight, overshadowing and solar glare
Negligible to Major Negative (significant)
Wind Pedestrian comfort and safety
Major negative (significant)
Socio-economics Employment
Minor positive (not significant)
Housing
Moderate positive (significant)
Demand on healthcare
Minor negative (not significant)
Open space provision
Moderate positive (significant)
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These effects are considered to have the potential to interact to produce an intra-project cumulative effect. Considering the collective weight of the effects’ significance and nature, a Moderate Positive to Major Negative (Significant) effect is anticipated.
Flood Risk
Heritage
Townscape
Heritage Listed buildings
Minor beneficial (not significant)
No.
Locally listed buildings
Minor beneficial (not significant)
No Effects to interact with.
Buildings of townscape merit
Minor to moderate beneficial (significant)
Townscape Town centre
Moderate beneficial (significant)
No.
Residential zone
Minor beneficial (not significant)
No Effects to interact with.
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Minor to Moderate Positive (significant)
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18.0 Summary of Effects, Mitigation and Monitoring 18.1 Introduction 18.1.1 The EIA process involves an iterative approach in that it informs each stage of the design, and where practicable, incorporates measures to mitigate likely significant environmental effects in order that the Proposed Development proactively seeks to avoid, reduce, or offset negative effects. As such, inherent mitigation measures are embedded within the design features of the Proposed Development, and attention is drawn to these within the relevant technical chapters of this ES. 18.1.2 Where the assessment has resulted in likely significant negative effects, additional mitigation measures have been identified to: • •
Control and manage the demolition and construction activities; and Control relevant operational aspects of the Proposed Development.
18.1.3 Table 18.1 offers a summary of the effects and mitigation measures identified within each of the technical chapters of this ES (Chapters 6 – 16). 18.1.4 It is expected that the mitigation measures identified within the relevant technical chapters (Chapters 6 – 16) and summarised in the Table 18.1 below would form part of detailed design specifications as appropriate for submission, and approved in response to appropriately expressed planning conditions. 18.1.5 The effects for the BHTVIA are contained within ES Volume 2 and are not reported herein (due to the number of receptors to report effects against).
18.2 Demolition and Construction Phase 18.2.1 The mitigation measures proposed during construction have been selected for their practicality and effectiveness. Chapter 5: Demolition and Construction, of this ES is supported by an outline CEMP which sets out how the construction works will be carried out and the Applicant’s intentions for managing the construction process. 18.2.2 The outline CEMP describes how the Proposed Development could be delivered taking into account the local constraints, buildings and environment. It acts as a guide, as the actual construction methodology will be developed following selection and appointment of the principal contractor. Specific mitigation measures as identified for the construction works within the technical Chapters are summarised below. 18.2.3 Once a contractor has been appointed, it is proposed that a formal CEMP will be prepared and submitted for approval by LBL and other consultees as appropriate before construction commences. Implementation of the management plans will allow management and control of the proposed construction works associated with groundworks, including management of materials, wastewater and the storage of fuels and construction plant.
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18.2.4 The CEMP will provide details of the procedures and methods to be followed to minimise potential negative effects of construction on the local environment, relating to local air quality, noise and vibration levels, lighting, visual amenity and ground conditions. Once they are approved, contractors working on the Site would be required to comply with the requirements of the management plans through the provision of detailed method statements.
18.3 Operational Phase 18.3.1 Many of the mitigation measures which have been identified through the EIA process rely on effective implementation once the Proposed Development is completed. The precise management structures for controlling these activities, to ensure that effects are minimised and the design objectives are achieved, will be subject to approval by LBL. 18.3.2 Specific mitigation measures identified for the Operational Stage within the technical ES chapters are summarised in Table 18.1. The measures have been assessed within each chapter and considered in the determination of the classification of the residual effects.
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Table 18.1: Summary of Effects and Mitigation Measures MITIGATION MEASURES
METHOD OF IMPLEMENTATON
LIKELY RESIDUAL EFFECT
Noise from construction works
CEMP
Planning condition and compliance with legislation (Control of Pollution Act, 1974)
Minor Negative
Vibration from construction works
CEMP
Planning condition
Minor Negative
Noise from construction traffic
CEMP
Planning condition
Negligible
Operational road traffic noise
None necessary
Building services noise
Plant sound power level maxima.
CHAPTER
PHASE
LIKELY EFFECT
6. Noise & Vibration
Demolition and Construction
Operational Phase
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Negligible Negative
Planning condition
Minor Negative
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7. Air Quality
Demolition and Construction
Internal noise levels within Embedded mitigation of Proposed Development MVHR and acoustic performance specifications for glazing.
Planning condition
Minor Negative
Demolition and Construction
Planning condition
Negligible Negative
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CEMP. DMP
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8. Transport
Operational Phase
Future users of the Proposed Development
None necessary
Negligible Negative
Demolition and Construction
Driver Delay, Severance
CEMP
Planning condition
Negligible
Operational Phase
Severance
Travel Plan. DSMP
Planning condition
Minor Positive
Driver delay
Travel Plan. DSMP
Planning condition
Negligible
Pedestrian and cyclist delay
Travel Plan. DSMP
Planning condition
Negligible
Travel Plan. DSMP
Planning condition
Negligible
Effects on Pedestrian Amenity
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Travel Plan. DSMP
Planning condition
Negligible
Travel Plan. DSMP
Planning condition
Negligible
Submission and approval of demolition method statement and risk assessment to control risk of groundwater pollution Submission and approval of piling method statement and risk assessment to be undertaken to mitigate against creating pathways that could contaminate the groundwater CEMP
Planning condition
Negligible to Minor Negative
Planning condition
Negligible to Minor Negative
Planning condition
Negligible to Minor Negative
Effects on Fear and Intimidation
Effects on Accident and Safety 9. Water resources, Drainage and Flood Risk
Demolition and Construction
Pollution caused by demolition works and removal of sub-surface obstructions.
Pollution caused by piled foundations
Potential contamination by spillage and release of contaminants from construction site
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Operation
Potential contamination by spillage and release of contaminants from construction site
CEMP
Risk of fluvial and surface water flooding to the northern part of the site from the wider local sewer catchment.
The tendering process will ensure that construction site managers and workers are aware of the risks of flooding, sign up to the EA flood warning service and have an emergency plan to adequately protect workers, equipment and ongoing works. Embedded mitigation.
Planning condition
Neutral
Flood Risk
Embedded mitigation.
Planning condition
Minor to Moderate Positive
Surface Water
Embedded mitigation.
Planning condition
Minor Positive
Geology and Groundwater
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Planning condition
Negligible to Minor Negative
Negligible to Minor Negative
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10. Ground Conditions and Contamination
Demolition and Construction
Water and Drainage Infrastructure
Embedded mitigation.
Planning condition
Minor Negative
Effect of contamination on Demolition and Construction Workers
Further Ground Investigation and Assessment Remediation Options Appraisal, Remediation Strategy and Verification Reporting
Planning condition
Negligible Negative
Planning condition
Negligible Negative
CEMP UXO engineer watching briefs, intrusive Magnetometer surveys and UXO response plans Effect of contamination on Adjacent Site Users and Future Site Users (within earlier completed phases of the development)
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Further Ground Investigation and Assessment Remediation Options Appraisal, Remediation Strategy and Verification Reporting Construction Environmental
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Effect of contamination on Controlled Waters receptors
Management Plan (CEMP) UXO engineer watching briefs, intrusive magnetometer surveys and UXO response plans Further Ground Investigation and Assessment Remediation Options Appraisal, Remediation Strategy and Verification Reporting
Planning condition
Negligible Negative
Planning Condition
Negligible Negative
CEMP Piling Risk Assessment
11. Archaeology
Demolition and Construction
Site preparation
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Archaeological evaluation of the Site will be required. The most appropriate investigation
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Minor – Moderate Negative
Daylight
strategy is likely to entail archaeological trenches to confirm the presence, nature and significance of any archaeological remains in the areas of proposed impact. The results would allow an informed decision to be made regarding an appropriate mitigation strategy for any significant archaeological assets. This might comprise targeted archaeological excavation in advance of construction, and/or a watching brief during ground works. None required
Sunlight
None required
Negligible – Major Negative
Overshadowing
None required
Negligible Positive
Solar Glare
None required
Negligible to Minor Negative
Piles
Pile caps and connecting ground beams
Utilities trenches/tree planting
12. Daylight, Sunlight and Overshadowing
Demolition and Construction
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Negligible Negative
Negligible Negative
Negligible – Major Negative
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Daylight
None required
Negligible – Major Negative
Sunlight
None required
Negligible – Major Negative
Overshadowing
None required
Negligible
Solar Glare
None required
Negligible to Minor Negative
Light Pollution
None required
Negligible
Demolition and Construction
Pedestrian Comfort
None Required
As per operational stage.
Operation (Detailed Element)
Receptors Ground Level (safety)
n/a
Moderate Positive
Receptors Elevated (Balcony) Level On Site
n/a
Negligible
Operation
13. Wind Microclimate
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Operation (Detailed and Outline Element)
Receptors Elevated Level Off Site
n/a
Receptors Ground Level
Landscape, additional trees and low-level planting.
Planning Condition
Negligible
Receptors Elevated Level On Site
Landscape, additional trees and low-level planting.
Planning Condition
Negligible
Receptors Elevated Level Off Site
n/a
Receptors Ground Level
Landscape, additional trees and low-level planting, porous wind deflecting elements.
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Negligible
Negligible
Planning Condition
Major Negative
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Receptors Elevated (Balcony)) Level On Site
n/a.
Receptors Elevated (Podium)) Level On Site
Landscape, additional trees and low-level planting, porous wind deflecting elements.
Planning Condition
Major Negative
Receptors Elevated Level Off Site
Landscape, additional trees and low-level planting, porous wind deflecting elements.
Planning Condition
Negligible
Receptors Ground Level
Landscape, additional trees and low-level planting, porous wind deflecting elements.
Planning Condition
Major Negative
Receptors Elevated (Balcony) Level On Site
n/a
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Negligible
Negligible
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14. Ecology
Demolition and Construction
Operation
Receptors Elevated (Podium) Level On Site
Landscape, additional trees and low-level planting, porous wind deflecting elements.
Planning Condition
Moderate Negative
Receptors Elevated Level Off Site
Landscape, additional trees and low-level planting, porous wind deflecting elements.
Planning Condition
Negligible
Pollution, noise and vibration, dust
CEMP
Planning Condition
Negligible
Disturbance and loss of habitat
Replacement of nesting provision
Planning Condition
Negligible
Disturbance and loss of habitat, loss of breeding resource
Alternative nesting provision
Planning Condition
Negligible
Lighting, recreational pressure, shading
None
Planning condition
Negligible
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15. Socioeconomics
Demolition and Construction
Operation
Disturbance, loss of foraging and nesting habitat
Alternative roosting provision, installation of green roof
Loss of existing employment on-site
Relocation within Site
Minor Negative
Demolition and Construction Employment
None Required
Negligible Positive
Employment Generation
None Required
Minor Positive
Housing Delivery
None Required
Moderate Positive
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Planning condition
Negligible
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Healthcare
None Required
Primary Education
None Required
Negligible
Secondary Education
Financial contributions via CIL
Negligible
Open Space
None Required
Moderate Positive
Playspace
None Required
Minor Positive
Additional Spending
None Required
Minor Positive
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CIL payment
Minor Negative
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16. Climate Change
Demolition and Construction
Operation
GHG
Measures outlined in the Energy Strategy
Section 106 obligations
Negligible Negative
CCR
CEMP
Planning Condition
Negligible Negative
GHG
Measures outlined in the Energy Strategy
Planning Condition
Negligible Negative
CCR
Various measures outlined in Chapter 16
Planning Condition
Minor Negative
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18.4 Monitoring Noise and Vibration 18.4.1 As detailed in Chapter 6: Noise and Vibration, due to the risk of noise and vibration effects during construction, particularly from piling and excavations, noise and vibration monitoring is recommended for the duration of the construction phase. This measure and associated trigger levels would be agreed with Lewisham via an Application for Section 61 Prior Consent under the Control of Pollution Act 1974 and incorporated into the CMP. 18.4.2 The monitoring should involve real-time continuous monitoring at locations that should be agreed with Lewisham. Where possible, pre-construction baseline monitoring should start at least one month before work commences on-site. Air Quality 18.4.3 As detailed in Chapter 7: Air Quality, due to the risk of dust effects during construction, particularly in relation to the track-out by HDVs, on-site air quality monitoring is recommended for the duration of the construction phase. This measure would be incorporated into the CMP. 18.4.4 The monitoring should involve real-time PM10 continuous monitoring at locations that should be agreed with Lewisham. Where possible, pre-construction baseline monitoring should start at least three months before work commences on-site. Transport Demolition and Construction 18.4.5 As previously set out, a CMP and CLP would be prepared. Monitoring would form a core part of the CMP and the CLP as these are, to some extent, likely to be dynamic documents which evolve with the needs of the demolition / construction works. Some aspects, such as quantifying deliveries / collections, would be enabled by systems in place such as delivery booking; whilst others, such as staff monitoring, are likely to require formal survey, for example of staff travel patterns. This understanding would enable the setting of targets, measures and policies to ensure that adverse effects of the process are minimised, and that beneficial effects are reinforced. 18.4.6 Responsibility for the management of the CMP (and its subordinate components) is likely to be captured within the role of Construction Manager (or similar). Agreement to the content of the CMP, and by extension the CLP, would be required prior to and during the demolition and construction works and would include Lewisham, TfL, the Applicant and the Main Contractors. Operational 18.4.7 The primary mechanism for the monitoring of transport-related effects of the complete and operational Development is the Travel Plan.
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18.4.8 The Travel Plan would be charged with seeking continuous improvement to the travel behaviours of the residents of the Site, and for ensuring that non-residential occupiers of the Site operate their own subordinate TPs which are in line with the Site objectives, targets and measures. Ecology 18.4.9 No specific ecological monitoring is proposed as part of the Development once it is complete and operational. However, once details of the CEMP have been confirmed, these may set out monitoring requirements as needed Archaeology 18.4.10 All archaeological fieldwork will be carried out in accordance with a scope of works which will be agreed, through a planning condition, in advance of commencement by GLAAS. The appointed fieldwork contractors will liaise with GLAAS to ensure that their works are suitably monitored. Wind 18.4.11 No specific monitoring of the environmental effects is proposed; however, further detailed testing would be undertaken at the detailed design stage. Daylight, Sunlight and Overshadowing 18.4.12 No specific monitoring of the environmental effects is proposed; however, further detailed testing would be undertaken at the detailed design stage.
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19.0 Summary of Residual Effects 19.1 Introduction 19.1.1 The likely significant residual environmental effects arising as a result of the Proposed Development have been assessed. These are the likely effects following the implementation of the proposed mitigation measures, as outlined within the preceding technical chapters (Chapters 6 - 16) and Volume 2. 19.1.2 Whilst each technical chapter provides a detailed assessment of the likely residual effects, this Chapter presents a summary of the residual effects of the Proposed Development. 19.1.3 Operational residual effects are generally permanent in nature, whereas effects that arise during the demolition and construction phase are often less significant due to their temporary nature. A summary of the residual effects and the likely significant environmental effect are outlined below. 19.1.4 Residual effects for the BHTVIA are contained within ES Volume 2 and are not reported herein (due to the number of receptors to report effects against).
19.2 Overview 19.2.1 The design of the Proposed Development incorporates a range of embedded enhancement and mitigation measures aimed at reducing any significant effects to existing and future receptors. Measures proposed in Chapter 18: Summary of Effects, Mitigation and Monitoring should be implemented at detailed design stage in order to further improve effects and ensure that the sustainability and environmental performance of the Proposed Development is optimised. The residual effects reported within the ES are summarised in Table 19.1 below. 19.2.2 Planning conditions, obligations and / or other measures may be implemented to ensure the delivery of the mitigation and enhancement measures as set out within this ES and other documents submitted in support of the Planning Application.
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Table 19.1: Summary of Residual Effects SIGNIFICANCE OF RESIDUAL EFFECTS
CHAPTER
PHASE
6. Noise & Vibration
Demolition and Construction
Operational Phase
DESCRIPTION OF RESIDUAL EFFECT Noise from construction works
MAJOR / MODERATE / MINOR / NEGLIGIBLE Minor
POSITIVE / NEGATIVE
PERMANENT DIRECT / / INDIRECT TEMPORARY
Negative
T
D
SHORT / MEDIUM / LONG TERM ST/MT
Vibration from construction works
Minor
Negative
T
D
ST/MT
Noise from construction traffic
Negligible
Negligible
T
D
ST/MT
Operational road traffic noise
Negligible
Negligible
P
D
LT
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Building services noise
Minor
Negative
P
D
LT
Internal noise levels within Proposed Development
Minor
Negative
P
D
LT
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7. Air Quality
8. Transport
Demolition and Construction
Demolition and Construction
Negligible
Negative
T
D
MT
Operational Phase
Future users of the Proposed Development
Negligible
Negative
P
D
LT
Demolition and Construction
Driver Delay, Severance Negligible
N/A
T
D
MT
Operational Phase
Severance Minor
Positive
P
D
LT
Negligible
N/A
P
D
LT
Driver delay
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Pedestrian and cyclist delay
9. Water resources, Drainage and Flood Risk
Demolition and Construction
Negligible
N/A
P
D
LT
Effects on Pedestrian Amenity
Negligible
N/A
P
D
LT
Effects on Fear and Intimidation
Negligible
N/A
P
D
LT
Effects on Accident and Safety
Negligible
N/A
P
D
LT
Pollution caused by demolition works and removal of sub-surface obstructions.
Negligible to minor
Negative
T
D
MT
Pollution caused by piled foundations
Negligible to minor
Negative
T
D
MT
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Operation
Potential contamination by spillage and release of contaminants from construction site Potential contamination by spillage and release of contaminants from construction site
Negligible to minor
Negative
T
D
ST
Negligible to minor
Negative
T
D
ST
Risk of fluvial and surface water flooding to the northern part of the site from the wider local sewer catchment.
Negligible to minor
Negative
T
D
ST
Geology and Groundwater
Neutral
P
D
LT
Flood Risk
Minor / Moderate
P
D
LT
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Positive
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10. Ground Conditions and Contamination
Demolition and Construction
Surface Water
Minor
Positive
P
D
LT
Water and Drainage Infrastructure
Minor
Negative
P
D
LT
Effect of contamination on Demolition and Construction Workers
Negligible
Negative
P
D
MT / LT
Effect of contamination on Adjacent Site Users and Future Site Users (within earlier completed phases of the development)
Negligible
Negative
P
D
MT / LT
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11. Archaeology
Demolition and Construction
Effect of contamination on Controlled Waters receptors
Negligible
Negative
T
D
LT
Site preparation
Negligible
Negative
P
D
LT
Piles
Minor moderate
Negative
P
D
LT
Pile caps and connecting ground beams
Negligible
Negative
P
D
LT
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12. Daylight, Sunlight and Overshadowing
Demolition and Construction
Operation
Utilities trenches/tree planting
Negligible
Negative
P
D
LT
Daylight
Negligible to Major
Negative
Temporary
D
LT
Sunlight
Negligible to Major
Negative
Temporary
D
LT
Overshadowing
Negligible
Positive
Temporary
D
LT
Solar Glare
Negligible to Minor
Negative
Temporary
D
LT
Daylight
Negligible to Major
Negative
Permanent
D
LT
Sunlight
Negligible to Major
Negative
Permanent
D
LT
Overshadowing
Negligible
Negative
Permanent
D
LT
Solar Glare
Negligible to Minor
Negative
Permanent
D
LT
Light Pollution
Negligible
Positive
Permanent
D
LT
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13. Wind Microclimate
Demolition and Construction
Pedestrian Comfort and safety.
As per operational stage.
Operation (Detailed Element)
Receptors Ground Level
Moderate
Receptors Elevated (Balcony) Level On Site
Permanent
D
LT
Negligible
Permanent
D
LT
Receptors Elevated Level Off Site
Negligible
Permanent
D
LT
Receptors Ground Level
Negligible
Permanent
D
LT
Receptors Elevated Level On Site
Negligible
Permanent
D
LT
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Positive
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Receptors Elevated Level Off Site
Operation Receptors Ground (Detailed and Level Outline Element)
Negligible
Major
Receptors Elevated (Balcony)) Level On Site
Negligible
Receptors Elevated (Podium)) Level On Site
Major
Receptors Elevated Level Off Site
Negligible
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Negative
Negative
Permanent
D
LT
Permanent
D
LT
Permanent
D
LT
Permanent
D
LT
Permanent
D
LT
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14. Ecology
Demolition and Construction
Receptors Ground Level
Major
Receptors Elevated (Balcony) Level On Site
Negligible
Receptors Elevated (Podium) Level On Site
Moderate
Receptors Elevated Level Off Site
Negligible
Pollution, noise and vibration, dust
Negligible
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Negative
Negative
N/A
Permanent
D
LT
Permanent
D
LT
Permanent
D
LT
Permanent
D
LT
N/A
N/A
N/A
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Operation
15. Socioeconomics
Demolition and Construction
Disturbance and loss of habitat
Negligible
N/A
N/A
N/A
N/A
Disturbance and loss of habitat, loss of breeding resource
Negligible
N/A
N/A
N/A
N/A
Lighting, recreational pressure, shading
Negligible
N/A
N/A
N/A
N/A
Disturbance, loss of foraging and nesting habitat
Negligible
N/A
N/A
N/A
N/A
Loss of existing employment onsite
Minor
Negative
T
D
MT
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Operation
Demolition and Construction Employment
Negligible
Positive
T
D
MT
Employment Generation
Minor
Positive
P
D
LT
Housing Delivery
Moderate
Positive
P
D
LT
Healthcare
Negligible
Negative
P
D
LT
Primary Education
Negligible
Negative
P
D
LT
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16. Climate Change
Demolition and Construction
Secondary Education
Minor
Negative
P
D
LT
Open Space
Moderate
positive
P
D
LT
Playspace
Minor
Positive
P
D
LT
Additional Spending
Minor
Positive
P
ID
LT
GHG
Negligible
Negative
P
D
MT
CCR
Negligible
Negative
T
D
MT
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Operation
GHG
Negligible
Negative
P
D
LT
CCR
Overall Minor
Negative
P
D
LT
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Glossary of Terms and Abbreviations
Absorption (Acoustic)
The acoustic absorption derived from the multiplication of the absorption coefficient by the surface area of a given material.
Absorption Coefficient
The fraction of reverberant sound energy absorbed by a material. It is expressed as a value between 1.0 which equates to perfect absorption and 0 which equates to zero absorption. A static or moving image which shows the location of a proposed development as accurately as possible; it may also illustrate the degree to which the development will be visible, its detailed form or the proposed use of materials. AVRs are produced by accurately combining images of the proposed building with a representation of its context. Classification of sound absorbers into Sound Absorption Classes A-E, according to BS EN ISO 11654, including frequencies 200-5000 Hz. Atmospheric Dispersion Modelling System Roads is a line-source Gaussian dispersion model with the capability to model 3 point sources. The totally encompassing sound in a given situation at a given time, usually composed of a sound from many sources both distant and near (LAFeq,T). A pleasant or advantageous aspect of the environment. A measure of sunlight that a given window may expect over a year period.
Accurate Visual Representations
Acoustic Class A-E ADMS Roads Ambient Noise Level Amenity Annual Probable Sunlight Hours Aquifer Alluvium
Archaeological Priority Area Arisings A-weighting Sound Pressure Level Background Sound/Noise Level
Baseline Studies
Biodiversity
Borehole Brickearth
B.P. Bronze Age Brownfield Site Building Recording
Built Heritage
A below ground, water-bearing layer of soil or rock. Sediment laid down by a river. Can range from sands and gravels deposited by fast flowing water and clays that settle out of suspension during overbank flooding. Other deposits found on a valley floor are usually included in the term alluvium (e.g. peat). Area specified by Local Planning Authorities to help protect archaeological remains that might be affected by development. Material (often spoil) derived from the ground through excavation The sound pressure level with the A-weighting applied. The A-weighting is used for most environmental noise measurements and is used to weight a spectrum of sound to match the sensitivity of the human ear. These are amongst the lowest noise levels measured over a given period of time and exclude short term, intermittent noise sources. The background noise level is quantified by the LA90 descriptor and is therefore the level which is exceeded for 90% of a given period of time. Studies of existing environmental conditions which are designed to establish the baseline conditions against which any future changes can be measured or predicted. The diversity, or variety of plants and animals and other living things in a particular area of region. It encompasses landscape diversity, ecosystem diversity, species diversity and genetic diversity. A deep hole bored into the ground as part of intrusive geological investigations. A fine-grained silt believed to have accumulated by a mixture of processes (eg wind, slope and freeze-thaw) mostly since the Last Glacial Maximum around 17,000BP. Before Present, conventionally taken to be 1950 2,000–600 BC A site comprising previously developed land. Recording of historic buildings (by a competent archaeological organisation) is undertaken ‘to document buildings, or parts of buildings, which may be lost as a result of demolition, alteration or neglect’, amongst other reasons. Four levels of recording are defined by Royal Commission on the Historical Monuments of England (RCHME) and Historic England. Level 1 (basic visual record); Level 2 (descriptive record), Level 3 (analytical record), and Level 4 (comprehensive analytical record) Upstanding structure of historic interest.
Glossary of Terms and Abbreviations Carbon Dioxide (CO2)
Colluvium Combined Heat and Power Completed Development Conservation Area
Construction Environmental Management Plan (CEMP) Construction Logistics Plan Construction Method Statement Cropmarks
Cross-talk Ctr
Cumulative Schemes Cumulative Effects Cut Feature Decibel
Desk Study
Devensian
Directive
Carbon dioxide is a naturally occurring gas comprising 0.04% of the atmosphere. The burning of fossil fuels releases carbon dioxide fixed by plants many millions of years ago, and this has increased its concentration in the atmosphere by some 12% over the past century. It contributes about 60 per cent of the potential global warming effect of manmade emissions of greenhouse gases. A natural deposit accumulated through the action of rain-wash or gravity at the base of a slope. A low carbon technology which generates electricity whilst also capturing usable heat that is produced in the process. A development scheme which has been build out. An area designated by the Local Authority as being of special architectural or historic interest under the provisions of the Planning (Listed Buildings and Conservation Areas 1990) Act, the character or appearance of which it is desirable to preserve or enhance. A documented management system with environmental procedures to avoid, minimise, mitigate and/or monitor environmental impacts of the construction phase of a development. A documented travel/coordination plan specific for a construction site. A document which addresses the health and safety risks to workers and other personnel on-site during the construction phase of the development. Marks visible from the air in growing crops, caused by moisture variation due to subsurface features of possible archaeological origin (i.e. ditches or buried walls). Noise transmission between one room and another room or space via a duct or other path. A correction term applied to the sound insulation single-number values (Rw, Dw, and DnT,w). Applying the Ctr penalises a construction’s performance if its low frequency performance is poor in relation its performance at higher frequencies. Developments that have received planning permission and have a signed legal agreement in place. They are assumed to be in place by the time the Development being assessed is completed. Effects that result from incremental changes caused by other past, present or reasonably foreseeable actions. Archaeological feature such as a pit, ditch or well, which has been cut into the then-existing ground surface. A scale for comparing the ratios of two quantities, including sound pressure and sound power. The difference in level between two sounds s1 and s2 is given by 20 log10 (s1 / s2). The decibel can also be used to measure absolute quantities by specifying a reference value that fixes one point on the scale. For sound pressure, the reference value is 20Pa. A non-intrusive study and review of all available information pertaining to a site, including historical records, collated and monitored data, and consultation with relevant stakeholders. The most recent cold stage (glacial) of the Pleistocene. Spanning the period from c 70,000 years ago until the start of the Holocene (10,000 years ago). Climate fluctuated within the Devensian, as it did in other glacials and interglacials. It is associated with the demise of the Neanderthals and the expansion of modern humans. European Union (EU) Directives impose legal obligations on European Member States. They are binding as to the results to be achieved, but allow individual states the right to decide the form and methods used to achieve the results. An example of this is the EU Air Quality Framework Directive (1996) that is brought into legal effect in the UK by the Air Quality (England) Regulations (2000).
Glossary of Terms and Abbreviations Dynamic Insertion Loss Early Medieval (Saxon) EIA Scoping
EIA Scoping Opinion EIA Screening
Embodied Energy Emission Environmental Impact Assessment Environmental Statement Equivalent Continuous AWeighted Sound Pressure Level Evaluation (Archaeological) Excavation (Archaeological)
Facade Findspot Fit-out Free-Field Frequency
Frequency Weightings Geotechnical
Glare Grade I Listed Building Grade II Listed Building
The reduction of noise level due to the presence of a noise control device such as an attenuator, including any regeneration noise created by its presence. Historic time period from AD 410-AD 1066. An initial stage in determining the nature and potential scale of the environmental impacts arising from a proposed development and assessing what further studies are required to establish their significance. A written statement of the opinion of the relevant planning authority as to the information to be provided in the Environmental Statement. An initial stage in which the need for EIA is considered in respect of a development. Some developments are automatically subject to EIA by means of their inevitable size, nature and effects (Schedule 1 developments). Other projects are made subject to EIA because it is anticipated that they are likely to have significant environmental effects (Schedule 2 developments). Energy used in the sourcing, manufacture, transportation and assembly of goods and materials. A material that is expelled or released to the environment. Usually applied to gaseous or odorous discharges to the atmosphere. A process by which information about the environmental effects of a development is collected and taken into account by the relevant decisionmaking body before a decision is given on whether the development should go ahead. A statement that includes such information that is reasonably required to assess the environmental effects of a development. The LAeq is an energy average and defined as the level of sound which, over a given period of time, would equate to the same A-weighted sound energy as the actual fluctuating sound. A field evaluation is ‘a limited programme of non–intrusive and/or intrusive fieldwork which determines the presence or absence of archaeological features, structures, deposits, artefacts or ecofacts within a specified area’. A programme of controlled, intrusive fieldwork with defined research objectives which examines, records and interprets archaeological remains, retrieves artefacts, ecofacts and other remains within a specified area. The records made and objects gathered are studied and the results published in detail appropriate to the project design. The front or face of a building. Chance find/antiquarian discovery of artefact. The artefact has no known context, is either residual or indicates an area of archaeological activity. Installation of all non-substructure and non-superstructure items such as electrical water services, as well as final internal finishings. Far from the presence of sound reflecting objects (except the ground), usually taken to mean at least 3.5 m In sound, the number of cycles per second of a pressure fluctuation and frequency in sound is proportional to its pitch. Different frequen-cies are divided into octave and one third octave bands. Weightings can be applied to a spectrum of sound and act as a filter to account for different sensitivities and conditions. Ground investigation, typically in the form of boreholes and/or trial/test pits, carried out for engineering purposes to determine the nature of the subsurface deposits. The uncomfortable brightness of a light source or illuminated area when viewed against a dark background. A listed building that is of exceptional interest. A listed building that is of special interest.
Glossary of Terms and Abbreviations Grade II* Listed Building Gross External Area Gross Internal Area Maximum Noise Level Mechanical Ventilation Heat Recovery
Mesolithic Minimum Noise Level Mitigation Mitigation Measure National Planning Policy Framework
National Record for the Historic Environment Neolithic Nitrogen dioxide
Noise Rating Level
Non-Technical Summary Normalised Element Level Difference No-sky Line Octave Bands Open Space
Ordnance Datum Overshadowing
Palaeochanel Palaeoenvironmental Palaeolithic
A listed building that is of particular importance and of more than special interest. A measure of floor space calculated in accordance with the Royal Institution of Chartered Surveyors (RICS) Code of Measuring Practice. A measure of the area of a building measured to the internal face of the perimeter walls at each floor level. The maximum instantaneous noise level measured during a given period of time. The time weighting to which the meter is set for this measurement parameter is always indicated by either an F or S. An energy recovery ventilation system using equipment known as a heat recovery ventilator, heat exchanger, air exchanger, or air-to-air heat exchanger which employs a cross flow or counter-flow heat exchanger (countercurrent heat exchange) between the inbound and outbound air flow. The system provides fresh air and improved climate control, while also saving energy by reducing heating (and cooling) requirements. 12,000 BC-4,000 BC The minimum instantaneous noise level measured during a given period of time. The time weighting to which the meter is set for this measurement parameter is always indicated by either an F or S. Any process, activity of thing designed to avoid, reduce or remedy adverse environmental impacts likely to be caused by a development project. Measure aiming at reducing an adverse environmental effect. Came into force on 27 March 2012. It sets out the Government’s economic, environmental and social planning policies for England and summarises, in a single document, all previous national planning policy advice (Planning Policy Statements and Planning Policy Guidance notes). National database of archaeological sites, finds and events as maintained by Historic England in Swindon. Generally not as comprehensive as the country Historic Environment Record. 4,000 BC-2,000 BC Road transport and the burning of fossil fuels for power are the main sources of Nitrogen dioxide. In addition to being a greenhouse gas it also contributes to photochemical smog formation. It is an irritant to the respiratory system. This is a single figure value derived by plotting a noise spectrum against a set of curves. The curve under which the spectrum fits is the resulting Noise Rating Level. A summary of the Environmental Statement in ‘non-technical language’. The normalised difference in sound level between a pair of rooms via a small element such as a trickle ventilator. The level difference in octave bands is normalized to a reference amount of absorption. A measure of the distribution of diffuse daylight within a room. A band of frequencies in which the upper limit of the band is twice the frequency of the lower limit. Includes all open spaces, plus other spaces that provide a break from the densely built-up urban form, such as pedestrianised areas and station concourses; hard-landscaped areas with private access; pedestrian/cycle and wildlife routes; and all the green infrastructure that links open spaces together, including green corridors, private residential gardens, trees, green roofs, and green landscaped areas. Land levels are measured relative to the average sea level at Newlyn, Cornwall. This average level is referred to as ‘Ordnance Datum’. Overshadowing occurs when a structure blocks out sunlight from neighbouring properties on the northern side of that structure. It can affect the amount of daylight let into neighbouring properties when the shadow cast falls across windows or glazed doors. A former/ancient watercourse. An environment at a period in the geological past. 700,000 BC-12,000 BC.
Glossary of Terms and Abbreviations Particulate Matter Pathways Peat
Pedestrian Level Wind Microclimate Percentile Level
Permeability
Pile Plant Planning Practice Guidance Pleistocene Post-Medieval Prehistoric Preservation by Record
Preservation in situ
Public Realm Rating Noise Level Receptor (Sensitive) Registered Historic Parks and Gardens Residual (Archaeology) Residual Effects Reverberation Time
Risk Assessment Roman Scheduled Monument Site Site Codes
Discrete particles in ambient air, sizes ranging between nanometres (nm, billionths of a metre) to tens of micrometres (μm, millionths of a metre). The routes by which impacts are transmitted through air, water, soils or plants and organisms to their receptors. A build-up of organic material in waterlogged areas, producing marshes, fens, mires, blanket and raised bogs. Accumulation is due to inhibited decay in anaerobic conditions. Mean or gust wind speed measured at 1.5 m above ground level. A-weighted sound pressure level obtained using time-weighting F, which is exceeded for N% of a specified time interval. An example of this is background noise which is quantified with the LA90 descriptor, which is the A-weighted level which is exceeded for 90% of the measurement period. The extent to which an environment allows people a variety of access routes through it. A permeable environment is one where there is ease of movement and where people have a choice of the routes they may use. A timber, steel or concrete post which is driven, jacked or cast (bored) into the ground to carry vertical or horizontal loads. A building’s generator, heating, ventilation, and/or electricity-production system. A web-based resource that came into force in 2014. It seeks to consolidate existing technical guidance into a consolidated online format and provides further detail on the policies contained within the NPPF. Geological period pre-dating the Holocene. Historic time period from AD 1485-present Historic time period from 7500,000-AD AD43 Archaeological mitigation strategy where archaeological remains are fully excavated and recorded archaeologically and the results published. For remains of lesser significance, preservation by record might comprise an archaeological watching brief or evaluation. Archaeological mitigation strategy where nationally important (whether Scheduled or not) archaeological remains are preserved in situ for future generations, typically through modifications to design proposals to avoid damage or destruction of such remains. The space between and within buildings that are publicly accessible, including streets, squares, forecourts, parks and open spaces. The specific noise level plus any adjustment for the characteristic features of the noise (LAr,T). A component of the natural, created, or built environment such as human being, water, air, a building, or a plant that is affected by an impact. Designed landscapes of note. When used to describe archaeological artefacts, this means not in situ, i.e. Found outside the context in which it was originally deposited. Those effects of a development that cannot be mitigated following implementation of mitigation proposals. The time that would be required for the sound pressure level to de-crease by 60 dB after the sound source has stopped. The descriptor T, often includes other nomenclature to describe the type of reverberation time measurement or if the reverberation time is an average taken for specific frequencies. An assessment of the likelihood and severity of an occurrence. Historic time period from AD 43-AD 410. Site of archaeological or historic interest included in the Schedule of Monuments compiled by the Secretary of State under the Ancient Monuments and Archaeological Areas Act 1979. The extent of the Masterplan Application, as defined by the red-line boundary plan. Unique identifying codes allocated to archaeological fieldwork sites, e.g. evaluation, excavation, or watching brief sites.
Glossary of Terms and Abbreviations Setting Severance Sites and Monuments Record Solifluction
Sound Exposure Level Sound Power Level
Sound Pressure Level
Sound Reduction Index Specific Noise Level
Standardized Weighted Level Difference Statutory Consultees Strata Stratigraphy Structure Borne Noise Study Area
Substructure Superstructure Supplementary Planning Document Sustainable Development Tactile
Time Weightings
The Applicant Topography Transport Assessment
The context in which a building or area can be appreciated. The perceived divisions that can occur within a community when it becomes separated by a traffic route. A computerised record of information for all statutorily listed buildings, known archaeological sites and stray finds, parks and gardens of special interest in England Creeping of soil down a slope during periods of freeze and thaw in periglacial environments. Such material can seal and protect earlier land surfaces and archaeological deposits which might otherwise not survive later erosion. A level of a sound, of 1 s duration, that has the same sound energy as the actual noise event considered. This is the total sound energy radiated from a given source. The sound power Level is 10 times the logarithm to base 10 of the ratio of the reference sound power level (1x10-12) and the measured power. This is the unweighted or linear level which is measured prior to any weightings being applied. The sound pressure level is 20 times the logarithm to base 10 of the ratio of the reference sound pressure (2x10- 5) and the measured sound pressure. The laboratory measured sound insulation properties of a material or building element in octave or third octave bands. The equivalent continuous A-weighted sound pressure level at the assessment position produced by the specific noise source (the noise source under investigation) over a given time interval (LAeq,T). The standardized, weighted difference in sound level between a pair of rooms, stated as a single figure. The level difference in octave bands is first normalized to a reference reverberation time and then plotted against a set of reference curves to establish a single figure value. Groups or bodies that, by law, must be consulted as part of the planning application process for EIA development. Layer of rock or soil. A term used to define a sequence of visually distinct horizontal layers (strata), one above another, which form the material remains of past cultures. Audible noise caused by the vibration of elements of a structure, the source of which is within a building or structure with common elements. Defined area surrounding the Masterplan Application in which archaeological data is collected and analysed in order to set the Site into its archaeological and historical context. Elements of a development below ground level, typically basements and foundations. Elements of a development above ground principally the mega frame, supporting northern core and outer shell cladding. Documents which seek to give guidance and support on the Council’s planning processes and are one of the material considerations in determining planning applications. Development that meets the needs of the present generation without compromising the ability of future generations to meet their own needs. A system of textured ground surface indicators found on many footpaths, stairs and pedestrian walkways to assist and guide pedestrian movement around an area. A time weighting to denote the response of the sound level meter. For most measurements the Fast time weighting is selected (F) how-ever, a slow time weighting (S) is often used to for the measurement train noise and vibration. The person or entity making the planning application. The natural and man-made features of an area collectively. Prepared and submitted alongside planning applications for developments likely to have significant transport implications. For major proposals, assessments should illustrate the following: accessibility to the site by all modes, the likely modal split of journeys to and from the site and proposed measures to improve access by public transport, walking and cycling.
Glossary of Terms and Abbreviations
α °C 3D AADT
BPM BS
Micrograms per cubic metre Absorption Coefficient Degrees Celsius Three Dimensional Annual Average Daytime Traffic Flows Annual Average Weekly Traffic Flows Asbestos Containing Materials Anno Domini Atmospheric Dispersion Modelling System Arboricultural Impact Assessment Above Ordnance Datum Archaeological Priority Area/Zone Annual Probable Sunlight Hours Automatic Traffic Counts Air Quality Assessment Level Air Quality Action Plan Air Quality Management Area Air Quality Objective Air Source Heat Pumps Above Ground Storage Tanks Automatic Traffic Counts Accurate Visual Representations Black, Asian and Minority Ethnic Biodiversity Action Plan Before Christ Bat Conservation Trust Below Ground Level British Geological Survey Building Management Systems Basic Noise Level Birds of Conservation Concern Red List Species Best Practicable Means British Standard
BSI BUG C&V CA CAA CABE CAZ CCTV CDM CDLP
British Standard Institute Bicycle Users Group Cottrell & Vermeulen Compass Archaeology Civil Aviation Authority Commission Activity for the Architecture and the Built Environment Central Activities Zone Closed Circuit Television Construction Design and Management Construction and Demolition of Logistics Plan
AAWT ACMs AD ADMS AIA AOD APA or APZ APSH ATCs AQAL AQAP AQMA AQO ASHP AST ATC AVRs BAME BAP BC BCT bgl BGS BMS BNL BoCC Red
Glossary of Terms and Abbreviations CDTE CEMP CFA CFD CFMP CHP CIBSE CIE CIEEM CIFA CIL CDLP CMP CO2 COCP COMAH CoPA COSHH CLP CLT CLOCS CRTN CS4
Completed Development traffic Emissions Construction Environmental Management Plan Continuous Flight Auger Computational Fluid Dynamics Catchment Flood Management Plan Combined Heating and Power Chartered Institute of Building Services Engineers Commission on Illumination Chartered Institute of Ecology and Environmental Management Chartered Institute of Archaeologists Community Infrastructure levy Construction and Demolition Logistics Plan Construction Management Plan Carbon dioxide Code of Construction Practice Control of Major Accident Hazards Sites Control of Pollution Act 1974 Control of Substances Hazardous to Health Construction Logistics Plan Cross Laminated Timber Construction Logistics and Community Safety Calculation of Road Traffic Noise Cycle Superhighway 4
CSE CTMP DnT’w Dne Dnew
Confirmed Space Entry Construction Traffic Management Plan Standardized Weighted Level Difference Normalised Element Level Difference Weighted, Normalised Element Level Difference Weighted, Normalised Flanking Level Difference Weighted Level Difference Decibels A-Weighted Decibels Department for Communities and Local Government Department for Culture Media and Sport Development Consent Order De-contamination Unit Disability Discrimination Act Department of Environment, Food and Rural Affairs Department of Greater London Archaeology Dynamic Insertion Loss Dust Management Plan Design Manual for Roads and Bridges Dust Risk Assessment Delivery and Servicing Management Plan Environment Agency
DnFw Dw dB dB(A) DCLG DCMS DCO DCU DDA DEFRA DGLA DIL DMP DMRB DRA DSMP EA
Glossary of Terms and Abbreviations EC EcIA ECoCP EFA EIA ELR EPA EPUK ES EU EUBC FE FEH FM FRA FSC Ft FTE FWMA GCRA GEA GIA GIA GiGL GIS GLA GLAAS GLHER GLVIA GP GQA g/m2 ha HAP HCA HE HEA HER HDV HGV HIU HMSO hrs HSE HUDU HURNVC HV
European Commission Ecological Impact Assessment Environmental Code of Construction Practice Education Funding Agency Environmental Impact Assessment Employment Land Reviews Environmental Protection Act Environmental Protection UK Environmental Statement European Union EU Biodiversity Strategy Form Entry Flood Estimation Handbook Facilities Management Flood Risk Assessment Forest Stewardship Council feet Full Time Equivalent Flood and Water Management Act Ground Contamination Risk Assessment Gross External Area Gordon Ingram Associates Gross Internal Area Greenspace Information for Greater London Geographic Information System Greater London Authority Greater London Archaeological Advisory Service Greater London Historic Environmental Record Guidelines for Landscape and Visual Impact Assessment General Practitioner General Quality Assessment Grams per squared metre Hectare Habitat Action Plan Homes and Communities Agency Historic England Historic Environment Assessment Historic Environment Record Heavy Duty Vehicles Heavy Goods Vehicle Heat Interface Unit Her Majesty’s Stationery Office Hours Health and Safety Executive Healthy Urban Development Unit Handbook of Urban Rail Noise and Vibration Control High Voltage
Glossary of Terms and Abbreviations Hz IAQM IEA IEMA IL ILP IPC ISO JNCC JSA kg/m² kg khz km KPF kph kV kW kWth l/s LA90 LAE LAeq,T LAFmax LAFmin LAN,T LAr,Tr LnT,w Lp LpA Lw LAQM LBL LCC LDF LEZ L&GR LLAQM LLFA LHA LIGS LNR LOAEL LPA LSIS LT LTHW LUL
Hertz Institute of Air Quality Management Institute of Environmental Assessment Institute of Environmental Management and Assessment Insertion Loss Institute of Lighting Professionals Infrastructure Planning Commission International Organization for Standardization Joint Nature Conservation Committee Job Seeker’s Allowance Kilograms per squared metre Kilograms Kilohertz Kilometres Kohn Pedersen Fox Associates Kilometres per hour Kilovolts kilowatt Kilowatt thermal Litres per second Background Sound / Noise Level Sound exposure level Equivalent continuous A-weighted sound pressure level Maximum noise Level Minimum noise Level Percentile level Rating Level Weighted standardized impact sound pressure level Sound Pressure Level A-weighted sound pressure level Sound Power Level Local Air Quality Management London Borough of Lewisham London Cycling Campaign Local Development Framework Low Emission Zone London & Greenwich Railway London Local Air Quality Management Lead Local Flood Authority London Heathrow Airport Locally Important Geological Sites Local Nature Reserve Lowest Observed Adverse Effect Level Local Planning Authority Locally Significant Industrial Sites Long Term Low Temperature Hot Water London Underground Limited
Glossary of Terms and Abbreviations LV LVMF m m2 & sqm m3 m/s m/s2 M AOD MAGIC max mbgl mg/Nm3 min mins mm mm/s MMC MOLA and MOLAS MOLAA MP mph MT MTS MUGA MVHR N/A NAQO NERC NGR NHL NHS NIA NJUG Nm3/h NMA NNR NOAEL NO2 NOx NOR NPPF NPPG NPSE NR NRC NRMM NSL NSR NTS ONS
Low Voltage London View Management Framework Metre Square metre Cubic metre Metres per second Metres per squared second Metres Above Ordnance Datum Multi Agency Geographic Information for the Countryside Maximum Metres below ground level milligrams per normal cubic metre Minimum Minutes Millimetre Millimetres per second Modern Methods of Construction Museum of London Archaeology (service) Museum of London Archaeological Archive Member of Parliament Miles per Hour Medium Term Mayor’s Transport Strategy Multi Use Games Area Mechanical Ventilation and Heat Recovery Not applicable National Air Quality Objectives Natural Environment and Rural Communities National Grid Reference National Heritage List for England National health Service Net Internal Area National Joint Utilities Group Normal Metres Cubed per Hour Non-Material Amendment National Nature Reserve No Observed Adverse Effect Level Nitrogen Dioxide Nitrogen Oxides Number on Roll National Planning Policy Framework National Planning policy Guidance Noise Policy Statement for England Noise Rating Noise Reduction Coefficient Non-Road Mobile Machinery No-Sky Line Noise Sensitive Receptor Non-Technical Summary Office of National Statistics
Glossary of Terms and Abbreviations OS PAH PANs PCA PCBs PE PEFC PFRA PINS PM2.5/PM10 PPE PPG PPS PPV PTAL PV R Rw RAMS ref RICS RIGS SAC SAP SCI SEN SFRA SI SIL SINC SOAEL SPA SPD SPG SPZ SSSI ST SuDS SWMP T TA TCA TEB TfL TGN TLRN TPH TPO TTD
Ordnance Survey Polycyclic Aromatic Hydrocarbons Published Admissions Numbers Pre-Construct Archaeology Polychlorinated Biphenyls Physical Education Programme for the Endorsement of Forest Certification Preliminary Flood Risk Assessment Planning Inspectorate Particulate Material of a particular size fraction Personal Protective Equipment Planning Practice Guidance Planning Policy Statements Peak Particle Velocity Public Transport Accessibility Level Photovoltaic Sound Reduction Index Weighted Sound Reduction Index Risk Assessments and Method Statements Reference Royal Institute of Chartered Surveyors Regionally Important Geological Sites Special Area of Conservation Species Action Plan Statement of Community Involvement Special Education Needs Strategic Flood Risk Assessment Statutory Instrument Strategic Industrial Locations Site of Importance for Nature Conservation Significant Observed Adverse Effect Level Special Protection Area Supplementary Planning Documents Supplementary Planning Guidance (Groundwater) Source Protection Zone Site of Special Scientific Interest Short Term Sustainable Drainage Systems Site Waste Management Plan Reverberation Time Transport Assessment Townscape Character Area Transport Emissions Benchmark Transport for London Technical Guidance for Noise Transport for London Road Network Total Petroleum Hydrocarbons Tree Protection Order Thames Tidal Defences
Glossary of Terms and Abbreviations TTT TVBHA TWUL UAEL UDP UK UK BAP UKPN UNESCO UST UXO VDV VRF VSC VDV WAC WCA
WFD WHO WHS WSI
Thames Tideway Tunnel Townscape and Visual and Built Heritage Assessment Thames Water Utilities Limited Unacceptable Adverse Effect Level Unitary Development Plans United Kingdom United Kingdom Biodiversity Action Plan UK Power Networks United Nations Educational, Scientific and Cultural Organization Underground Storage Tank Unexploded Ordnance Vibration Dose Value Variable Refrigerant Flow Vertical Sky Component Vibration Dose Value Waste Acceptance Criteria Wildlife and Countryside Act 1981 Water Framework Directive World Health Organisation World Heritage Site Written Scheme of Investigation