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1. Introduction
In February 2016, RMC (LH) Co. Limited (the ‘Applicant’) submitted a full planning and listed building consent application (reference PA/16/00479) (the ‘February 2016 Application’) for a commercial development at Royal Mint Court (the ‘Site’). The Site comprises an area of approximately 2 hectares (ha), as shown on Figures 1 and 2. It is located within the north west of the London Borough of Tower Hamlets (LBTH), close to the boundary with City of London (CoL).
Figure 1: Site Location
The Applicant’s proposals (the ‘Development’) would retain, modify and refurbish various existing buildings
and structures on the Site, whilst also providing new-build elements to the Site. Accordingly, partial demolition
and dismantling would be required. The Development would provide office and retail land uses within four
buildings referred to as the Johnson Smirke Building, the Registry Building, Murray and Dexter House and the
Staff House. The total floorspace provided by the Development would be 80,708 sq.m Gross External Area
(GEA). A gym, plant areas, parking and landscaping areas are also proposed as part of the Development.
An Environmental Impact Assessment (EIA) was undertaken to assess the likely significant environmental
impacts of the Development. The EIA was reported in an Environmental Statement (ES) which was prepared
to accompany the planning application. It was submitted in February 2016 (the ‘February 2016 ES’). The ES
described the methodologies used to carry out the EIA and set out the likely significant environmental impacts
of the Development, taking account of a range of mitigation measures proposed to prevent, reduce or offset
any adverse environmental effects.
Following submission of the February 2016 Application, the Applicant engaged with LBTH and other
consultees, in particular with the Greater London Authority, Historic Royal Palaces, Historic England and the
Georgian Group. In response, a number of revisions and clarifications are proposed to the February 2016
Application. These revisions principally relate to a reduction in height of Murray and Dexter House and
changes to the dormer windows on the Registry Building.
In view of the revised design, further EIA work has been undertaken to ensure that all likely significant
environmental effects of the Development have been identified. This work has been reported in an ES
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Addendum. The February 2016 ES and the ES Addendum therefore form the ES for the purposes of the
Development. This document (the Non-Technical Summary (NTS)) provides a summary of the findings of the
entire EIA in non-technical language. For ease of reading and to avoid referring to multiple documents, this
NTS supersedes and replaces the NTS prepared as part of the February 2016 ES and is submitted alongside
an ES Addendum to reflect the minor design changes and responses to the clarifications made by LBTH.
Figure 2: Site Plan
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2. EIA Methodology
An EIA aims to ensure that the potential likely significant environmental effects of a new development (which
can be beneficial and adverse) are given due consideration in the determination of a planning application. In
accordance with relevant legislative requirements and best practice guidelines the EIA has been undertaken
using established methods and criteria. This involved site visits and surveys, data reviews, consultation with a
number of relevant authorities and specialist assessments undertaken by a team of qualified and experienced
consultants.
The first stage of the EIA process involved undertaking a ‘scoping study’. This study identified the likely
significant environmental issues associated with the Development and therefore the focus of the EIA and
content of the February 2016 ES. The proposed content of the EIA was discussed with LBTH and CoL and it
was considered that the EIA would need to in include an assessment of the following environmental topics: the
environmental effects of the demolition and construction process; socio-economics; noise and vibration; air
quality; transportation and access, ground conditions and contamination; built heritage; townscape and visual
amenity, archaeology; daylight; sunlight and overshadowing and solar glare; the pedestrian wind environment;
and cumulative effects (the effects of the Development combined with the effects of other presently or
reasonably foreseeable schemes).
Each of the environmental assessment topics listed above is reported in the February 2016 ES and the ES
Addendum (where relevant), with a chapter dedicated to each of these issues. Each chapter describes how
the assessment has been undertaken, the current conditions on and adjacent to the Site and the potential
effects of the Development. Each chapter also describes a range of measures that would be incorporated to
avoid, reduce, or offset any identified adverse effects, and / or enhance potential beneficial effects. Such
measures are referred to as ‘mitigation measures’. The resulting effects (known as ‘residual effects’) following
the implementation of mitigation are also described.
3. Site History and Existing Land Uses
Archaeological works undertaken within the Site during the 1980s, prior to the construction of the existing
office development, revealed substantial archaeological remains pertaining to a Black Death cemetery (mid-
14th century) and the Cistercian Abbey of St Mary Grace (mid-14th to mid-16th century). Following the
Reformation, the remaining buildings of the Abbey were used by the Royal Navy as a victualling yard
principally to store tobacco. The Royal Mint moved to the Site in the early 19th century from the Tower of
London.
The Johnson Smirke building was built in 1811 and rebuilt during the 1880s to accommodate the expanding
Royal Mint. The Seaman’s Registry Building (the Registry Building) was designed as staff accommodation for
the Royal Mint and was completed in 1805.
By 1875, the western half of the Site was predominantly occupied by offices, officers’ quarters, a police station
and a courtyard. The north east area of the Site was occupied by a gold and silver refinery, which included a
chimney. The central / eastern area of the Site was occupied by various stores, engine and boiler houses,
forges, grinding and melting rooms and rolling, coining and sizing rooms.
By 1933, a number of the warehouses’ uses had changed, for example they were used as storage, printers
and stables at this time. During World War II, the Site suffered some bomb damage and by the 1960s, little of
the original Royal Mint remained, apart from the Johnson Smirke building, the Registry and the two
gatehouses at the entrance.
In 1976, it was announced that the Royal Mint would move to a new facility in south Wales and the Site was
cleared of much of the buildings housing the machinery for coin making. Following the move of the Royal Mint,
in the 1980s, the Site was extensively redeveloped into offices, including the completion of Murray and Dexter
House in 1987. The Site became known as Royal Mint Court and functioned as a financial centre. Alterations
to the Seaman’s Registry were made at this time, with the Grade II listed façade retained (see Figure 3
below). The façades facing north were demolished, along with the majority of the building within them. The
façade was then extended to the east in the Georgian style of the Grade II listed south and east elevations.
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The overall footprint was enlarged to include the majority of the former large rectangular building that can be
seen to the north.
Figure 3: Existing buildings and structures on Site.
The Site currently comprises vacant buildings that have been used for office space. There are areas of
hardstanding and ornamental planting around the buildings. Although the office space has been vacated, there
are a few staff members occupied with maintaining the Site. As illustrated on Figure 2, the features currently
on-site include:
The Grade II* listed three storey Johnson Smirke Building (Photograph 1 of Figure 4) was formally used for
office space and has been separated into numerous spaces for this use.
The Grade II listed Seaman’s Registry Building (Photograph 2 of Figure 4) comprising four storeys, with a
lower ground floor consisting 10 parking spaces and an electrical substation.
A Security Office is situated at the main entrance which is predominantly single storey with the exception of
the southern part which is two storeys.
Two Grade II listed cast iron lamp stands.
Two Grade II listed gatehouses are at the main entrance to the Site. This is the main pedestrian entrance
to the Site, across the forecourt in front of the Johnson Smirke Building leading onto Tower Bridge
Approach/ Mansell Street. Vehicles can access the Site at the main entrance, but it is primarily for drop-
offs.
Murray House (south) and Dexter House (north) (Photograph 3 of Figure 4) occupy the eastern area of the
Site. For the purposes of this application this building is referred to as Murray and Dexter House as both
‘Houses’ are joined above ground by a central glass atrium. The lower ground floor (basement) contains a
former gym, pub and storage areas. The gym basement extends beyond the ground floor footprint, and is
overlain by the central courtyard area. This area of basement is irregularly-shaped to avoid the
archaeological remains of the Cistercian Abbey.
A servicing road runs to the east of Murray and Dexter House at a lower level and has 35 parking spaces
along it. Access to this road can be gained from East Smithfield. An exit then runs from this road onto
Royal Mint Street which is a one-way system.
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A central courtyard area (Photograph 4 of Figure 4) with seating is located between Johnson Smirke and
Murray and Dexter House.
A fenced-off grassed area is present to the west of the Johnson Smirke building.
There are a number of trees along the west and south-west perimeters of the Site, and an area of
ornamental planting is located to the south-west of the Site.
A listed perimeter wall surrounds the majority of the west, north and south of the Site.
The main pedestrian entrance to the Site is located to the west of the Site. The pedestrian-only entrances onto
Royal Mint Street, East Smithfield and Cartwright Street are currently closed to general public access. The
subway that runs from the Site beneath East Smithfield to Tower Bridge Approach is also closed.
1. Johnson Smirke Building 2. The Seaman’s Registry Building
3. Murray and Dexter House 4. Central Courtyard
Figure 4: Photographs of the Existing Site
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There are a variety of features surrounding the Site (as shown in Figure 5) including:
Approximately 20m to the north of the Site, off Royal Mint Street, is the cleared Royal Mint Street
development site where planning permission is sought for a mixed-use development;
Extensive cycle infrastructure including Transport for London’s (TfL’s) Cycle Superhighway 3 running
immediately to the north of the Site and further works planned for completion in summer 2016;
An office building containing a Telephone Exchange is located off Royal Mint Street to the east of the
Seaman’s Registry. This building does not form part of the Development (see Figure 2);
Residential properties located on Cartwright Street to the east and in St Katherine Docks to the south.
DreamMaker Children’s Nursery and Mosaique Hair Salon are also located to the east of the Site on
Cartwright Street and there are a variety of other businesses housed in proximity to the Site including the
London School of Business and Finance and Societe Generale investment bank;
The Tower of London World Heritage Site, Scheduled Ancient Monument and listed buildings from Grade I
to Grade II is approximately 100m south west of the Site;
The River Thames is approximately 290m to the south of the Site, with Tower Bridge (Grade I listed)
crossing the river into the London Borough of Southwark;
Local transport infrastructure to the Site includes Tower Hill Station (District and Circle London
Underground Lines), Tower Gateway Station, Fenchurch Street National Rail Station serving out of London
to Essex and Tower Millennium Pier for riverboat services.
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Figure 5: Location of Potentially Sensitive Receptors
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4 Alternatives and Design Evolution
In line with the EIA Regulations, the ES provides a description of the main alternatives to the Development, considered by the Applicant. These include:
The ‘No Development’ alternative;
Alternative sites;
Alternative uses; and
Alternative designs.
No development at the Site was not considered to be a viable option by the Applicant. Without redevelopment,
the Site would likely remain underused and the buildings would undergo further deterioration which would
result in increasing maintenance costs of the vacant buildings and Site structures. In addition, there would be
continued vacancy of employment space in a central London location well serviced by public transportation.
These factors would mean that regional and local planning objectives would not be met in relation to the Site.
Furthermore, local socio-economic benefits of regeneration, in terms of retail provision, employment and other
commercial opportunities would not be achieved, and aspirations to integrate the Site better within the wider
area would not be realised.
The Site is already in the Applicant’s ownership and since the existing buildings are vacant, it is considered
necessary to redevelop the land to ensure the Site is utilised. Consequently, the Applicant’s objectives for the
Development specifically relate to the Site and its specific opportunities and constraints. Accordingly, no
alternative locations have been considered for the Development.
The existing buildings on-Site are in a poor condition with dated internal finishes and cladding. Mechanical and
electrical systems and lifts are now at the end of their economic lives. In addition, the toilets are underprovided
and don’t comply with current regulations. The buildings are therefore in need of upgrading and re-imaging in
order to be suitable for use.
The Development enables these improvements to be made. The provision of high quality office uses and retail
space is therefore considered appropriate for the Site and would accord with strategic development planning
policy. Alternative uses would therefore not be supported and have not been explored further.
Several alternative designs were considered by the Applicant. Each design option was based around outlined
principles of the redevelopment including:
Utilise the building form and heritage of the Grade II* Johnson Smirke Building as the centrepiece to the
new public realm;
Increase permeability: open up and connect the Site to the rich surrounding context of the Tower of
London, St Katharine Docks, City of London and residents to the east of the Site on Cartwright Street and
beyond;
Develop an office led mixed-use response to enliven the public realm;
Rework the Registry Building to provide new offices with an ‘active’ ground floor;
Provide a landscaping scheme in response to the history of the Site;
Sustainably develop new office buildings reusing much of the existing structure of the buildings on-Site,
including the retention of existing basement slabs and most of the existing foundations.
Each of the options was tested against a series of townscape views to review the balance between the new
elements of the Development and the relationship to the existing retained façades and structures. As such,
several alternative designs that revised the bulk and mass of the Development, as well as the elevation
treatment were considered.
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5 The Proposed Development
The full planning application and application for listed building consent (where relevant) seeks consent for the
partial demolition of the existing buildings and other structures on the Site and part redevelopment and
refurbishment and construction of a new building an employment-led mixed use development of up to
81,000m2 of office, retail, restaurant and gym space.
Design Changes between February 2016 ES Submission and June 2016 ES Addendum
As set out previously, following submission of the February 2016 ES, minor design changes have been made
as a result of consultation with the Greater London Authority (GLA), Historic Royal Palaces (HRP), Historic
England and the Georgian Group, as follows:
A 3.34m reduction in height of Murray and Dexter House. The reduction in height has been achieved by
reducing the floor to floor heights for the 6th and 7th floors. These floors have also been ‘cutback’ in places
to reduce the visibility of Murray and Dexter House from the south west of the Site. The office floor areas
have been maintained by reducing the size of internal ‘voids’;
The movement of one of the proposed boiler flues on Murray and Dexter House, so it is hidden from views
to the south west of the Site;
Retention of the railings between the entrance porticos;
Changes to the dormer windows on the Seaman’s Registry; and
Rainwater collection features, present on the roof of Murray and Dexter House for the February 2016
application, would now be located in the basement.
These changes have been included in the Development description set out in the following paragraphs.
The Development does not involve the entire demolition of the existing buildings on the Site. Figure 6
indicates the existing building outlines with the proposed outlines, including the new and retained / modified
elements.
The Johnson Smirke Building
In relation to the Grade II* listed Johnson Smirke Building, some external alterations would be required to the
rear façade at the lower ground and ground floor level to create a new external seating area at the lower
ground floor and to improve the access to the rear courtyard by reinstating two access bridges. This would link
the retail units at the lower ground and ground floor level with the public realm to the east. Office units would
be provided from first to third floor levels.
The height of the Johnson Smirke Building would not alter and the maximum height of the building would be
remain as approximately 34.26m AOD to the top of the highest chimney. The roof structure would be rebuilt,
with the original chimneys moved forward by approximately 0.5m. Alterations are proposed to the third floor
rear façade to create the improved roof terrace area.
Internal listed features, including the stairs between the ground and first floor and the clock tower would be
retained and refurbished as part of the Development.
The Seaman’s Registry Building
The demolition activities proposed at the Seaman’s Registry Building involve the removal of the 1980s
extension behind the Grade II listed façade. The existing 1980s extension and mansard roof of the Seaman’s
Registry Building behind the retained façade would be replaced. Minimal modifications are proposed to the
Grade II listed façade on the south and west of the Seaman’s Registry Building. These modifications relate to
replacing an existing window with a door at the ground floor level, which is in accordance with the original
design. The existing ramp and steps at the ground floor to the south of the building would be removed (these
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Figure 6: Existing and Proposed Building Outlines
are assumed to be a 1980s addition). Four new entrances are proposed from Mansell Street through the listed
curtilage wall of the Site.
The maximum height of the Registry Building would be 34.165m AOD (including roof plant above the
mansard) from the ground to the fourth floor, an increase of 1.965m from the existing building.
Useable office space would be introduced from the first to the fourth floors, with retail / office uses at ground
level. A replacement UK Power Network (UKPN) substation would be situated within the north-east corner of
the Seaman’s Registry Building.
Murray and Dexter House
The main demolition works at the Site would be at Murray and Dexter House, including the demolition of the
west facing three structural bays of the building, the floors, the northern, western and southern façades and
the roof. Full recladding of the building’s exterior is also proposed. Changes to the massing of this building are
shown on Figure 5.1 which shows how both Dexter House to the north and Murray House to the South would
be ‘pulled back’ from the Johnson Smirke Building. Overall, the maximum height would alter from +44.95m
AOD as existing, to +45.56 m AOD as proposed.
Murray and Dexter House would include office floorspace from the ground to the seventh floor. The lower
ground floor of Murray and Dexter House extends under the rear courtyard and would contain a gym plant
rooms, storage and parking areas.
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The Staff House
The Staff House is an entirely new structure and is in the same location as a building which was in this
location and demolished in the 1940s. Three storeys of flexible floorspace are proposed with the building
extending to a proposed maximum height of 32.765 m AOD.
The Gatehouses and Security Office
The two Grade II listed gatehouses (porticos) positioned at the entrance to the Site would be retained and
refurbished. The Security Office, which is at the western end of the Grade II listed Seaman’s Registry Building
would also be retained and refurbished.
Transport and Access
Vehicular access to the Site would be minimised where possible. A taxi route and drop-off would be provided
at the main entrance from Tower Bridge Approach / Mansell Street (A1210). This entrance would be limited to
drop-off only.
Car parking would be within the lower ground floor of the Development, which would be accessed via the
lower level service road at the eastern edge of the Site (behind Murray and Dexter House). The entrance to
the lower level service road would be via East Smithfield. A total of 25 parking spaces, seven of which would
be designated for people who are disabled.
On the Site, there would be a total of 943 cycle spaces. Long-stay cycle parking for staff would be provided in
the form of double stacking racks and facilities including showers, lockers and changing areas would be
provided adjacent to the cycle parking areas. Visitor cycle parking would also be provided. Access to the cycle
parking facilities within Murray and Dexter House and the Seaman’s Registry Building would be via lifts from
the ground floor levels.
The Development seeks to enhance the permeability of the Site by creating new pedestrian routes,
encouraging visitors to access the Development and respond to increased movement patterns to and from
Tower Hill and Tower Gateway Stations. The main entrance to the Site would remain the same as the existing
entrance, from Tower Bridge Approach / Mansell Street (A1210). The entrances from Royal Mint Street and
East Smithfield would also be improved to enhance the north-south permeability of the Site. In addition, there
would be four new access points through the perimeter wall of the proposed retail units within the Seaman’s
Registry. Pedestrian access from Cartwright Street would include reopening and enhancing the route to allow
step-free access from the east through the Site. A new graded route would therefore be provided in place of
the stepped route which would aim to encourage existing residents to the east to access the Site. The entry to
the existing pedestrian subway under East Smithfield to St Katharine Docks, Tower Hill Station and the Tower
of London would be upgraded as part of the Development. A new external lift would be provided in addition to
the existing stepped access. The entrance to the pedestrian subway would be located at the south-west
corner the Staff House (at Ground Floor Level).
Landscaping and Ecological Enhancement
The Development would provide a total of approximately 730m2 of soft landscaping (planting) and
approximately 6,500 m2 of hard landscaping (walkways, vehicular routes) (refer to Figure 7). It is proposed to
remove the existing railings at the main entrance of the Site in order to improve access and permeability. The
design of the front lawn would be sculptured with raised ‘lipped’ seating areas and water features. The existing
two mature London Plane trees at the entrance of the Site would also retained. The majority of the Site would
be repaved using materials appropriate to the Site. The design of the rear courtyard area between the
Johnson Smirke Building and Murray and Dexter House includes informal seating areas and tree groves,
grouped in clusters. Glass paving would be incorporated into the stone paving of the rear courtyard used in
order to view the archaeological remains of the Cistercian Abbey. A walled garden to the west of the Registry
Building is proposed which would be accessed from the proposed retail units at the ground floor. Roof
terraces, are proposed on Murray and Dexter House. A roof terrace with planting features is also proposed on
the Johnson Smirke Building. Planting would comprise native species to provide habitats for bats, birds and
invertebrates.
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Figure 7: Overall Landscape Plan
Sustainability
To reduce carbon dioxide (CO2) emissions from the Development, consideration has been given to a range of
energy technologies and energy conservation measures have been incorporated within the Development
including a Combined Heat and Power (CHP) led heating system and photovoltaic panels (PV). PV panels
would be provided at on the roof of Murray and Dexter House (530m2 in total).
The Development would provide a number of features in order to accord with the principles of sustainable
design including a target BREEAM Rating of ‘Excellent’; the use of green/ sustainable building materials,
minimising waste generation during construction and operation by promoting recycling; creation of
construction and long-term employment; the provision of suitable ‘access for all’ including the mobility
impaired; the provision of extensive facilities for cyclists; the provision of water efficient fittings and
incorporation of energy efficient measures to reduce water and energy consumption; the provision of low and
zero carbon and energy technologies, and; improvement of biodiversity.
6 Development Programme, Demolition, Refurbishment and Construction
The current expectation is that the demolition, modification, refurbishment and construction (‘the Works’) for the Development would span approximately 30 months, with the Development anticipated to be completed in the early 2019. The following sequence of the Works phases would take place:
Pre-commencement surveys;
Service diversions;
Site enablement;
Demolition and dismantling;
Piling and substructure;
Superstructure (refurbished and new build elements of the Development);
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External works;
Mechanical, Electrical and Plant (MEP) and Building Works; and,
Fit out.
Site enabling works would include works to the archaeological remains situated under the Site. It is evident
that parts of the remains would require repair or stabilisation to ensure their survival. The specification would
be agreed with LBTH’s Archaeological Advisor (Greater London Archaeological Advisory Service (GLAAS)).
The archaeological remains would be protected for the duration of the works, so that they remain in optimal
condition for exposure in their final condition. It is envisaged that protection would consist of wrapping the
remains in sheeting and / or geotextiles as the initial layer of protection and would then be buried in clean
silica sand. Where necessary, additional support in the form of timber shoring (sheet plywood) would be
provided. Archaeological remains enabling works can be carried out at any time prior to the start on-Site of the
main contractor, as a separate enabling works package, to avoid any unnecessary interface with the main
works.
Figure 8: Demolition Plan
As identified within Figure 8, the Development does not involve the entire demolition of the existing buildings
on the Site. Therefore, the demolition and dismantling works are incorporated into an integrated construction
sequence where the buildings would be carefully stripped-out, including any removal of asbestos, as needed.
Care would be given to protect and temporarily support the retained elements of the existing buildings and
dismantle elements as needed.
In order to control and manage the potential environmental impacts typically associated with the Works, a site-
specific Outline Construction Environmental Management Plan (CEMP) has been developed and would be
implemented throughout the duration of the works. This would specify a range of measures to manage the
environmental impacts that could arise and would provide, for example, details of controls in relation to noise
and vibration, dust and the safeguarding of the retained façades and structures of the Development.
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The CEMP would be prepared in line with relevant legislative and best practice guidelines including LBTH’s
‘Code of Construction Practice’. The CEMP would be agreed with the LBTH and contractors would be required
to implement the CEMP, ensuring that monitoring and auditing is undertaken where this has been specified.
CEMPs are an established method of managing environmental effects resulting from demolition and
construction works and they are successfully adopted for other major schemes in urban areas.
7 Socio-Economics
It is estimated that the Development would generate approximately 222 full time equivalent (FTE) jobs during
the demolition, refurbishment and construction period. In addition, an annual spend of approximately £300,000
is anticipated from the construction workers, much of which would be spent in the local area, and would further
benefit the economy.
Once completed, the net direct employment generation from the Development (taking into account leakage
and displacement effects) would be 3,569 FTE jobs. However, the Development would not just generate direct
employment. Employment would also be generated from indirect and induced effects. These jobs would be
generated both directly from the Development and indirectly as a result of supply chain effects to local
businesses. The Development is predicted to generate a total net employment of 6,067 new FTE jobs. Jobs
generated both directly and indirectly are expected to bring in over £216 million into the Greater London
economy annually.
The proposed mix and layout of land uses and publicly accessible open spaces would result in increased
activity levels within the Site throughout the day thereby reducing the opportunity for crime and improving
perceptions of safety and wellbeing. This would contribute towards a safer environment for pedestrians and
visitors to the Site.
8 Noise and Vibration
A review of potential noise and vibration effects has been undertaken as part of a wider for the Development.
To provide baseline data, a detailed survey has been undertaken to establish the existing noise and vibration
climate on and off-Site. Noise monitoring was carried out in a number of locations and included: short-term
attended measurements carried out during the day and at night; and unattended noise measurements lasting
from several days up to a week.
An assessment of potential noise and vibration effects has been undertaken and it has been found that without
appropriate mitigation measures the following adverse effects could occur:
Potential temporary effects on local residents, businesses, and users of the nursery as a result of noise and
vibration from construction / demolition works;
Potential permanent effects on archaeological remains and retained features of heritage importance due to
vibration from nearby demolition and construction works;
Potential long-term effects on local residents, businesses and users of the nursery as a result of delivery
and servicing activities generated by the Development; and
Potential long-term effects on the new office users as a result of noise from existing transportation sources
(roads and the local railway).
A number of mitigation measures have been proposed to minimise the potential adverse effects identified
above, including (but not limited to) the following:
Best practicable means noise and vibration control techniques would be utilised during construction e.g.
noise and vibration monitoring, use of noise barriers etc.;
Implementation of a construction noise management plan (as part of the Construction Environmental
Management Plan (CEMP)) throughout the works. The final CEMP would be agreed with LBTH;
A ‘consent to work agreement’ would be prepared to allow LBTH to review the contractor’s proposals in
advance to control and minimise noise and vibration effects;
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Future items of fixed plant and equipment would be selected, installed, mitigated and maintained to meet
the specific plant noise limits, in line with LBTH’s requirements;
Appropriate building envelope and ventilation system design is implemented at the Development.
Through the use of appropriate mitigation measures it has been concluded that effects in relation to noise and
vibration would be reduced. With the completed Development, there would be some slight adverse effects
noticed by occupants of Cartwright Street in relation to the movement of service vehicles. However, there
would be no significant effects as a result of traffic noise, plant noise or from existing vibration sources.
9 Air Quality
The construction works have the potential to create dust. During construction it would therefore be necessary
to apply a package of mitigation measures to minimise dust emission. With these measures in place, it is
expected that any effects would be insignificant.
The operational effects of increased traffic emissions arising from the additional traffic on local roads, due to
the Development, have been assessed. On account of the existing poor air quality around the Site, the
Development would have an insignificant effect on roadside air quality, although along Royal Mint Street the
effects would be slightly worse. However, the actual change in concentrations along Royal Mint Street would
be very small: less than 1% of the air quality objectives set by the government for Nitrogen Dioxide (NO2) and
Particulate Matter (PM10 and PM25) pollutants. Therefore, the effect of air quality off Royal Mint Street would
also be insignificant.
The operational effects of the energy plant to be installed within the Development have also been assessed.
The assessment has demonstrated that the impacts of the CHP, boiler and humidifier plant emissions would
be insignificant and a statistical model has been used to demonstrate that the backup diesel generators would
not lead to any exceedences of the air quality objectives.
The Development would be air quality neutral in terms of transport emissions, but without mitigation it would
not be air quality neutral in terms of building emissions. Appropriate mitigation would be provided for the
standby diesel generators at the detailed design stage to ensure that the Development can become air quality
neutral.
Taking into account all of the above, the overall air quality impacts are deemed to be not significant.
10 Ground Conditions and Contamination
A ground conditions and contamination assessment has been undertaken to establish the likely contamination
risks posed to human health (including future users of the Site and construction and maintenance workers)
controlled waters (including the groundwater contained within the underlying aquifers) and property (including
on-Site and off-Site structures, foundations and services). The assessment used a range of information
sources including a review of historical maps, geological maps, and information provided by the Environment
Agency and other organisations.
A desk-based study of the potential for soil and groundwater contamination at the Site has been assessed
based on previous historical activities that have taken place over the last 750 to 800 years. The only previous
ground investigations at the Site took place in 1971 and 1986 and while no contamination testing of the soils
and groundwater was undertaken as part of those investigations, the borehole logs did not describe any
ground contamination to be present. In 1987 some contamination was identified during demolition works and
although no chemical testing results are available, high levels of some contaminants were reported in the
north eastern section of the Site.
Made Ground present on-Site would be a likely source of ground contamination, however due to the presence
of a basement beneath the current on-Site buildings, it is expected that much of the Made Ground was
removed in areas of the Site. Residual areas of potentially contaminated Made Ground are therefore reduced
but remain in areas outside the basement extent.
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During the Works, any existing contamination on the Site could be exposed and disturbed, potentially resulting
in harm to human health and the underlying aquifers. However, all Works would be undertaken in accordance
with measures set out in the CEMP.
The future supplementary ground investigation would further assess potential risks and provide additional
information of the ground conditions at the Site. Additional mitigation and / or vapour protection may be
required if solvents or gases are encountered.
11 Built Heritage
Analysis has been carried out of the heritage significance of the buildings on the Site and of other heritage
assets including the nearby Tower of London World Heritage Site and its constituent heritage assets (the
Tower of London scheduled ancient monument and listed buildings), and the contribution of the Site to the
Tower Conservation Area.
A detailed assessment of the effects of the proposed Development in regard to the effect on these heritage
assets has been undertaken. This included a desk based assessment of published sources of information on
the historic built environment in the area, in the form of statutory information and studies, histories and
research; physical inspection and fieldwork on the Site and the surrounding area, and consultation with LBTH,
Historic England and Historic Royal Palaces.
There would be adverse effects during the demolition and construction phases of the Development, although
these would be mitigated by the visual protection of the Site by hoarding, management of construction traffic,
and other measures contained within the CEMP to be secured through planning conditions and implemented
by the contractor.
Overall, once the Development is complete, it was found that the proposals made in regards to the retention,
alteration or removal of buildings and structures on the Site would be beneficial within specific local area but
affecting heritage assets of a national heritage significance. The Grade II* listed Johnson Smirke Building and
the Grade II listed façade of the Seaman’s Registry would be retained and incorporated into the proposals, in
addition to the refurbished entrance lodges and cast iron lamp stands. The siting and proposed architectural
design aims to ensure the new elements of the scheme respect these listed elements. Similarly, the design of
the proposed Development aims to preserve and enhance the character and appearance of the Conservation
Area, the setting of the World Heritage Site and its constituent heritage assets, and the setting of nearby listed
buildings.
12 Archaeology
A detailed desk based archaeological impact assessment has been undertaken in order to determine the
potential for important archaeological assets to exist at the Site. The assessment has included the analysis of
relevant data including historical records, maps and geological information, together with several site visits.
The Site lies within a designated Area of Archaeological Importance, as defined by LBTH. It was
archaeologically excavated during the later 1980s, when substantial Medieval, Post Medieval and Modern
remains were identified. The Site is considered to have a generally low archaeological potential for the
prehistoric, Roman and Anglo-Saxon periods.
The Site became one of two designated emergency burial grounds for the Black Death epidemic in London of
1348-50 AD. Following the creation of the cemetery, the Cistercian Abbey of St Mary Graces was founded by
Henry II at the Site, which lasted from c.1350 until the Dissolution of the Monasteries.
Past development on the Site is considered likely to have removed archaeological assets formerly present,
under the existing buildings. However, it is estimated that of the estimated total of circa 2,400 burials present,
circa 2,000 are known to remain within the western part of the Site. In addition, in situ remains of the Abbey
buildings remain beneath the central / eastern and southwestern parts of the Site. Figure 9 illustrates the
areas of known, potential, recorded and removed archaeology.
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The Site also has a known archaeological potential for the Post Medieval and Modern periods, relating to its
use as a Victualling Yard, warehousing and subsequently as the Royal Mint.
In the absence of mitigation, intrusive ground works (e.g. piling) would have the potential to destroy
archaeological assets within the footprint of the demolition and construction works. The greatest unmitigated
effect would occur in the areas of highest archaeological asset potential (i.e. areas of the remains of the
Cistercian Abbey and Black Death Burial Ground).
With the protection of the in situ remains along with recording and the preservation of the known and potential
archaeological resource within the Site during the demolition and construction process, all effects would be
mitigated to a likely insignificant level. Preservation of the in situ Medieval remains, together with
enhancement of their setting, provision of further interpretation and access, and the adoption of a long-term
management strategy would lead to a significant beneficial effect.
Figure 9: Area of known, potential, recorded, and removed archaeology
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13 Daylight, Sunlight, Overshadowing and Solar Glare
An assessment of the likely significant effects on daylight and sunlight amenity, and on overshadowing to the
existing surrounding residential properties and amenity spaces, was undertaken.
The main methods of assessment included the Vertical Sky Component (VSC), No Sky Contour and Average
Daylight Factor (ADF) for daylight analysis, the Annual Probable Sunlight Hours (APSH) for sunlight analysis,
permanent shadow analysis for overshadowing of amenity areas, and the Sunlight Availability analysis for
solar glare; all using a 3D computer software model.
The level of likely effect to daylight and sunlight availability on surrounding properties and overshadowing to
surrounding amenity spaces would vary throughout the demolition, refurbishment and construction works,
depending on the level of obstruction, but would be limited as most of the buildings are being retained within
the Development.
Overall the daylight analysis shows that the neighbouring residential properties adjacent to the east and south
of the Site would experience either insignificant or an adverse effect within some of the properties on levels of
daylight when measured against specific daylight guidelines. On the whole, there would be no significant effect
on levels of sunlight within these properties although some adverse effects would be noticed in a few
properties off Cartwright Street, in St Mary Graces Court.
With regard to the shadows cast by the Development, whilst there would be some modest reductions to the
amenity areas immediately adjacent to the development site the Development would not have any significant
effects on surrounding amenity areas in terms of overshadowing. The likely effects are considered to be
acceptable and appropriate. This is on account of the urban context and planning policy aspirations of the Site
and the wider area.
The solar glare analysis illustrates that the development would have the potential to generate some highly
localised temporary instances of glare but these would be limited and by no means unduly excessive given the
Site’s urban context. This would not be detrimental to safe movement of pedestrians and vehicular users on
the pavements and roads surrounding the Development.
14 Wind
A desk based assessment of the likely wind conditions as a result of the Development and the acceptability of
these in terms of pedestrian comfort and safety has been undertaken.
The existing Site is expected to experience conditions acceptable for its intended use due to the low-medium
rise nature of the existing buildings and its surroundings.
As the Development involves reconstruction and refurbishment of the existing buildings on Site and the
construction of a five storey building, wind conditions around the Development are expected to be similar to
that of the baseline. Due to the limited change in massing of buildings, demolition and construction works are
not expected to significantly affect the wind microclimate of the Site.
Thoroughfare locations are expected to be acceptable for their intended use as the occasional exceedances of
strong winds are anticipated to be infrequent.
The majority of entrances of the Development are expected to observe acceptable conditions except at the
entrance to the gym of Murray and Dexter House. This entrance would require mitigation to lower wind
speeds.
Ground level amenity spaces are generally acceptable for their intended use during the summer season;
however the large amenity space located centrally between Murray and Dexter House and the Johnson
Smirke building would require mitigation in the form of landscaping to achieve acceptable wind conditions.
Terrace level amenity spaces would not require mitigation measures to reduce the effect of the prevailing
south-westerly winds because these would be used weather permitting.
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15 Transport and Access
During the demolition and construction works there would be a short-term increase in traffic flow, particularly
heavy goods vehicles (HGVs), associated with general plant and materials deliveries and the removal of waste
from the Site. The construction traffic routes would be agreed in advance with LBTH and other relevant
authorities (e.g. TfL). On-Site logistic plans would be operated to ensure free flow of vehicles to avoid
unnecessary congestion at access points on public highways. Deliveries are planned and co-ordinated in line
with the detailed construction programme reducing vehicle movements and ensuring maximum efficiency
during the construction process. It is anticipated that construction flows would generally take place out of peak
highway hours when traffic levels on the local highway network are lower.
To effectively manage this traffic, management measures are set out within a CEMP. This would include
measures such as the use of agreed appropriate routes to and from the Site for construction vehicles (see
Figure 10) and restrictions on the largest vehicles arriving and departing from the Site during off-peak times of
the day. Appropriate signage would be implemented around the Site as well as communication to inform local
residents of activities.
Figure 10: Proposed Route to and from the Site during the Works
Once the Development is completed and occupied, it is predicted to result in increases in traffic flows on the
local road network. It is proposed to retain 25 car parking spaces, seven of which would be designated for
people who are disabled. The proposed level of car parking represents a 45% reduction in the amount of car
parking from the existing 45 car parking spaces available on Site. Electric Vehicle Charging Points (EVCPs)
would be provided in accordance with standards in the London Plan (March 2015). No changes are proposed
to the existing vehicular access points, however, it is proposed that car use within the Site is restricted to
private hire taxis/private car set-down/ pick-up in a limited area. This is to ensure that the public realm within
the Site provides an attractive environment for pedestrians. The existing taxi rank which accommodates three
licenced taxis at the entrance to the Site on East Smithfield would be retained.
There are a number of existing pedestrian access points around the perimeter of the Site would be retained
and improved to make the Site more welcoming to the public. A new pedestrian access point would be created
from Royal Mint Street, which would create a new high quality north-south route through the Site to the A1203
East Smithfield. The proposed route would be beneficial in improving local pedestrian connectivity. It is
proposed to modify the exiting subway access at the point it meets the Development to provide an accessible
lift. This would complete the step-free route between the Site and Tower Hill station.
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At present servicing takes place from a number of places around the Site. The servicing strategy for the
Proposed Development is that all servicing would now take place from the existing service road to the east of
the Site, with additional loading bays created to accommodate a greater number of vehicles. This would
contribute to improving the public realm on the Site by concentrating service vehicle movements in one area.
The Development is predicted to generate additional walking and cycle trips on the local network surrounding
the Site. However, as outlined above, the Development provides new pedestrian routes through the Site and
enhances the Site’s permeability and connectivity for pedestrians and cyclists. The pedestrian environment
within the Site would be of high quality with the provision of an attractive open space, well-maintained and
legible pathways, lighting and animated ground floor uses, thus providing natural surveillance. Long-stay and
short-stay cycle parking for employees and visitors respectively would be provided in accordance with the
London Plan (March 2015) standards. A total of 780 long stay cycle parking spaces and 163 short term cycle
parking spaces would be provided. Cycle parking would be provided at various locations within the Site. It is
proposed that cyclists would gain access to the Site from any of the Site access points, where cyclists will then
be required to dismount and then push their bicycle to the appropriate long-stay or short-stay cycle parking
area. This is to ensure that the public realm remains a safe, high quality space for both pedestrians and
cyclists.
A Framework Travel Plan has been developed in support of the planning application. This sets out a
framework for the delivery of new transport initiatives and measures for users that travel to and from the
Development on a regular basis. The aim of the Plan is to reduce reliance on private car use and to encourage
travel by more sustainable modes of transport.
16 Townscape and Visual Impact Assessment
The townscape and visual impact assessment was undertaken to assess the potential impacts of the EIA
Development on the character of the townscape, the townscape setting of heritage assets and the composition
and character of views. The Development is located within The Tower Conservation Area and a number of
listed buildings are present on Site. The local townscape character is dominated by the Grade I listed Tower of
London which is also a World Heritage Site.
During preparation and construction works for the Development, plant and construction equipment would be
visible from the surrounding local area and therefore have a temporary but adverse effect on the townscape
character and visual amenity of the area. Adherence to standards and procedures set out in the CEMP, such
as hoarding, would manage such impacts.
15 viewpoints were assessed in relation to the potential visual effects for the February 2016 ES submission.
For each of the identified views, accurate visual representation images (AVRs) of the view 'as existing', 'as
proposed' and ‘as proposed with cumulative schemes’ were produced to aid in the assessment. An extra
viewpoint was added for the April 2016 ES Addendum and some original views re-assessed to reflect the
design changes. One view of the Development is shown in Figures 11 and 12.
The assessment concludes that the Development has been designed to provide urban design benefits and to
contribute positively to the distinctive character of the Site and its boundary, as well as the varied townscape
character of the townscape character areas that adjoin the Site; that the Development would result in a
significant improvement to the Site in terms of architectural quality; and that the Development would enhance
the quality of open spaces on Site, opening it up to the surrounding area and to the public.
There would be significant effects on 10 of the 16 views studied – in the other cases, either the effect would be
insignificant, or the Development would not be seen at all and therefore there would be no effect. In the 10
views where there are significant effects, these effects are, as a result of the positive qualities noted above,
either beneficial or neutral in qualitative terms; there are no adverse effects.
Due to the modest increase in scale of the Development in comparison to other proposed schemes nearby
which are seen in the same views, the effect of the Development in some of the views assessed was reduced
when the cumulative condition was considered. Informed by the views analysis, the effect of the Development
on five local townscape character areas was assessed which was found to be beneficial.
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There would be an enhanced outlook from the remainder of The Tower Conservation Area towards the Site (in
cases where the Development is visible). The overall effect is limited due to the modest increase in scale of
the Development and the size and townscape character of the Conservation Area.
Figure 11: Existing view of the Site from Tower Bridge Approach
Figure 12: Proposed view of the Site from Tower Bridge Approach
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17 Cumulative Effects
Two types of cumulative effects have been assessed in relation to the Development:
The combination of individual environmental effects arising from the Works of the Development. For
example, noise, dust and visual intrusion; and
The combination of effects resulting from the completed Development and other present or reasonably
foreseeable schemes.
During the demolition and construction period, there would be some temporary combined impacts
predominantly associated with noise, vibration, dust, accidental pollution events and visual effects. However,
the Site-specific CEMP would ameliorate these construction related cumulative impacts as far as practically
possible.
A total of 30 ‘other’ schemes have been considered cumulatively with the Development at the Site (see Figure
13 below). These schemes were selected on the basis that they had valid planning permission, were within
1km of the Site and had a floorspace uplift of greater than 10.000m2 gross external area. Schemes within 1km
with an uplift of less than the criteria above, but which introduced sensitive receptors near to the Site were also
considered. The exception to this is the proposed scheme to the north of Royal Mint Street on account of its
proximity to the Site where the EIA has considered both the consented scheme and the scheme yet to be
determined by LBTH.
The cumulative effects of the Development in conjunction with these schemes were generally found to be
insignificant. However, it was concluded that there would be:
Temporary and long-term beneficial socio-economic effects as a result of employment creation, increased
local expenditure, provision of additional open spaces for the local communities, provide an improvement in
community safety and crime prevention;
Temporary adverse effects as a result of cumulative noise and vibration effects from the use of construction
site plant and machinery;
Temporary adverse effects on heritage assets as a result of construction activities including construction
infrastructure e.g. scaffolding and tower cranes;
At most, temporary beneficial effects on the daylight and sunlight received by neighbouring properties
during the demolition phase;
Some highly localised long-term adverse effects on some properties in St Mary Graces Court, Cartwright
Street and the Royal Mint Street development;
Long-term beneficial effects in regard to townscape, visual amenity and above ground heritage assets; and,
Long-term beneficial effects on pedestrian and cyclist movement in and around the Site.
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Figure 13: Location of Cumulative Schemes
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If you would like to receive further copies of this Non-Technical Summary or would like to purchase a copy of the Environmental Statement and the Environmental Statement Addendum, please contact:
Waterman Infrastructure & Environment Ltd
Pickfords Wharf
Clink Street
London
SE1 9DG
Tel: 0207 928 7888
Email: [email protected]