m: e - islington · the space affordable and provided this can be achieved through conditions or a...

From: Anna StottTo: planningpolicyCc: Mathew Mainwaring; Lidija HoneggerSubject: Local Plan Proposed Submission (Reg 19) ConsultationDate: 18 October 2019 16:44:14Attachments: image681655.png

image904357.jpgimage779209.jpgimage371858.jpgrpt.002.LH Reps to Islington Local Plan Review final.pdf

Dear Planning PolicyPlease find attached representations to the Islington Local Plan Proposed Submission (Regulation19) consultation.We trust that these representations will be taken into consideration and request to be kept up to datewith the progress of the Local Plan.Kind regardsAnna

Anna Stott|Senior Planner

M: 07391 735 936E: [email protected]

Aldermary House 10‑15 Queen Street,London,EC4N 1TXT: 020 3848 2500W: www.indigoplanning.com

This e‑mail (including any attachments is intended only for the recipient(s) named above.It may contain confidential or privileged information and should not be read, copied or otherwise used by any other person.If you are not a named recipient, please contact the sender and delete the e‑mail from the system.

R19.0131

mailto:[email protected]:[email protected]:[email protected]:[email protected]:07391%20735%20936mailto:[email protected]://protect-eu.mimecast.com/s/DykuC6RKmH1NowlupnjXI?domain=indigoplanning.comtel:020%203848%202500https://protect-eu.mimecast.com/s/Ih82C7LVnCQgm7juW40G5?domain=indigoplanning.comhttps://protect-eu.mimecast.com/s/CkuTC86KoCzGj48s2P5n_?domain=twitter.comhttps://protect-eu.mimecast.com/s/pxwdC9QYpuM0m7VcODYnw?domain=linkedin.comhttps://protect-eu.mimecast.com/s/4JMnC0VD2UMx2P0cOYhnN?domain=vimeo.com

Regulation 19 ConsultationRepresentations on behalf of The Methodist Church

Local Plan Review for Bunhill andClerkenwell Area Action Plan, SiteAllocations & Strategic andDevelopment Management Policies

Local Plan Review for Bunhill and Clerkenwell Area Action Plan, Site Allocations & Strategic and Development Management Policies Regulation 19 Consultation Representations on behalf of The Methodist Church October 2019

WSP | Indigo

Aldermary House 10-15 Queen Street London EC4N 1TX T 020 3848 2500 E [email protected] W indigoplanning.com

Local Plan Review for Bunhill and Clerkenwell Area Action Plan, Site Allocations & Strategic and Development Management Policies Regulation 19 Consultation Representations on behalf of The Methodist Church

Contents Page

1. Introduction 1

2. Strategic and Development Management Policies– Reg 19 Draft 2 Policy SP1: Bunhill and Clerkenwell 2Policy H1: Thriving Communities 2Policy B1: Delivering business floorspace 2Policy B2: New business floorspace 2Policy B4: Affordable workspace 3Policy S3: Sustainable Design Standards 3

3. Bunhill and Clerkenwell Area Action Plan – Reg 19Draft 4 Policy BC1: Prioritising office use 4Policy BC2: Culture, retail and leisure uses 5Policy BC3: City Fringe Opportunity Area 5Site Allocation BC33: Oliver House, 51-53 City Road.EC1Y 1AU 5

4. Conclusion 7

Oliver House, 51-53 City Road, London Representations to Local Plan Review WSP | Indigo on behalf of The Methodist Church

1. Introduction

1.1. These representations are made on behalf of our client, The Methodist Church, in respect of the current Pre-Submission Consultation on the following documents:

• Local Plan: Bunhill and Clerkenwell Area Action Plan (September 2019); and

• Local Plan: Strategic and Development Management Policies (September 2019).

1.2. These documents are being consulted on under Regulation 19 of the Town and Country Planning (Local Planning) (England).

1.3. We set out our further representations in respect of the Regulation 19 documents in the following sections.


2. Strategic and Development Management Policies – Reg 19 Draft

Policy SP1: Bunhill and Clerkenwell

2.1. Bunhill and Clerkenwell is identified as a key area for development within the borough, in particular for office, cultural, retail and leisure uses.

2.2. The Methodist Church supports the anticipated growth of office floorspace in the area as well as the enhanced provision of retail and cultural floorspace. The allocation of Oliver House (Policy BC33) will be a strong contributor to this strategic objective and would be able to deliver a mix of uses in accordance with Policy SP1.

Policy H1: Thriving Communities

2.3. Policy H1 seeks to enhance the social value of development within the borough. The Methodist Church are supportive of part S and V of this policy which encourage the development of social and community infrastructure required to support the borough’s residents and the maximisation of social value on development sites.

2.4. Community floorspace is essential for the maintenance of strong, vibrant and healthy communities and the council should be supporting the provision of these uses as part of a mixed-use development across the borough.

Policy B1: Delivering business floorspace

2.5. Policy B1 seeks the ‘maximisation’ of business floorspace in the Central Activity Zone (CAZ) and Bunhill and Clerkenwell AAP. This includes the aim to deliver 400,000sqm of additional office floorspace by 2036.

2.6. The maximisation of business floorspace is, however, poorly defined in the draft policy wording. The Methodist Church agrees that new development in the CAZ and Bunhill and Clerkenwell AAP should be office-led however the policy wording should refer to ‘maximisation’ subject to design constraints and/or viability.

2.7. Part B. of the Policy should therefore be amended to ensure that office-led development can be realistically and viably delivered:

“New business floorspace will be focused in the CAZ, Bunhill and Clerkenwell AAP area, the CAZ fringe Spatial Strategy areas of Angel and Upper Street and Kings Cross and Pentonville Road, PELs and Locally Significant Industrial Sites. Proposals in these areas must maximise the amount of new business floorspace, subject to design constraints and/or development viability. Proposals which cannot demonstrate maximisation that the majority of new/additional floorspace is business floorspace will be considered to be an inefficient use of a site and will be refused.”

2.8. Without this amendment to loosen the required business floorspace provision in new developments, the Council will not be able to deliver their required employment floorspace and this would render the Plan unsound.

Policy B2: New business floorspace

2.9. We are supportive of the identification of the Bunhill and Clerkenwell AAP area as being a


priority area for new office uses. However, the inclusion of reference to office led mixed-use development would also be welcomed.

Policy B4: Affordable workspace

2.10. Policy B4 seeks to ensure the delivery of affordable B-use workspace in the borough. The policy seeks to ensure that 10% affordable workspace has to be leased to the council for a peppercorn period of at least 20 years. Furthermore, the policy requires all applicants to submit an Affordable Workspace Statement.

2.11. Whilst the need for affordable workspace to be accommodated within scheme is understandable from the council’s perspective, the draft policy requirement for the space to leased to the council is unreasonable and a conflict of interest. The key objective is to make the space affordable and provided this can be achieved through conditions or a planning obligation, there should be no requirement for the space to be leased to a particular organisation such as the council. The council would be using its role as the planning authority to directly benefit its property interest in the boroughs. This is inappropriate and the requirement to lease to the council should be removed from the policy.

2.12. We are also concerned at the requirement for financial contributions. This policy doesn’t seem to have been properly tested in viability terms and has the potential to make many schemes unviable which will make schemes undeliverable. This would result in more stagnation and sites being blighted.

Policy S3: Sustainable Design Standards

2.13. Policy S3 states that all non-residential and mixed use developments proposing more than 500sqm net additional floorspace are required to achieve BREEAM ‘Excellent’ standards and must make reasonable endeavours to achieve ‘Outstanding’.

2.14. Although this approach is commendable, the policy wording should be amended to provide greater flexibility and determined on a case-by-case basis subject to design constraints and viability.


3. Bunhill and Clerkenwell Area Action Plan – Reg 19 Draft

Policy BC1: Prioritising office use

3.1. Policy BC1 specifically supports office use in the Bunhill and Clerkenwell area with the intention to maximise office floorspace. This includes the aim to deliver 400,000sqm of additional office floorspace by 2036.

3.2. The Methodist Church support the strategic objective to deliver 400,000sqm office floorspace. However, at present, the Plan does not meet the Council’s own strategic objectives to deliver high quality office floorspace, maintaining and developing business and job growth.

3.3. The Oliver’s House site (proposed allocation BC33) is located within the City Fringe Opportunity Area.

3.4. Part B. (i) identifies that new development proposals providing 500sqm or more net increase in floorspace in the City Fringe Opportunity Area must comprise at least 90% office floorspace. Whilst the Methodist Church appreciate the primary objective of providing office floorspace in the City Fringe Opportunity Area, the policy should introduce more flexibility by ensuring that development viability is considered, and the individual circumstances of each development proposal is taken into consideration in the policy wording.

3.5. Part B. should therefore be amended as follows:

“All development proposals providing 500sqm or more net increase in floorspace (within any use class) must comprise at least:

(i) 90% office floorspace (as a proportion of the total net additional floorspace proposed) be office-led, meaning that the majority of floorspace (as a proportion of the total net additional floorspace proposed) must be office floorspace, in the City Fringe Opportunity Area and any other part of the Bunhill and Clerkenwell AAP area, and subject to design constraints and/or development viability; or

(ii) 80% office floorspace (as a proportion of the total net additional floorspace proposed) in any other part of the Bunhill and Clerkenwell AAP area, if considered viable.”

3.6. This amendment is necessary to ensure that employment-led development is not stymied by an arbitrary threshold and ensure that office-led development can continue to be delivered in the borough. As currently drafted, the policy is unjustified and is contrary to the emphasis in the National Planning Policy Framework (2019) that mixed use developments should be encouraged in appropriate locations.

3.7. Furthermore, Part C. seeks to ensure that new development proposals in the Bunhill and Clerkenwell area which are not compliant with Part B. are office-led. Even though the policy identifies the meaning of ‘office-led’, it remains unclear which other uses are acceptable and what the Policy defines as ‘majority’ of floorspace.

3.8. Part C. should therefore be amended as follows:

“Development proposals within the Bunhill and Clerkenwell area,


including the City Fringe Opportunity Area, under the threshold set out in Part B must be office-led, meaning that the majority of floorspace (as a proportion of the total net additional floorspace proposed) must be office floorspace, with the co-location of other main town centre uses considered appropriate where justified.

3.9. Without this added flexibility, the Council will not be able to deliver their required employment floorspace and this would render the Plan unsound.

3.10. The Methodist Church supports the inclusion of Part D of the policy which provides exceptions for sites where circumstances may prevent them from providing the quantum of floorspace currently prescribed by Parts B and C of the policy. However, a further circumstance should be included in the list which refers to:

“vi. proposals for mixed use development that would provide enhanced social value and enhanced provision of community facilities.”

3.11. An addition should also be made to circumstance iii. which recognises the importance of non-residential institutions as serving a public service.

“iii. where a proposal is publicly funded or serves a public service, such as educational, medical, or research institutions and non-residential institutions.”

3.12. These additions enable the delivery of mixed-use, employment-led schemes and ultimately supports the Council in meeting their identified office floorspace need within the plan period.

Policy BC2: Culture, retail and leisure uses

3.13. The Methodist Church supports the development of retail and leisure uses in predominantly commercial areas. We suggest, however, making it clearer that ‘predominantly commercial areas’ includes the City Fringe Opportunity Area.

3.14. Part D. (i) states that new A Class uses are permitted where they would not harm vitality, viability, character, function or amenity of the area. The Methodist Church would like to see further guidance on how the LPA defines ‘harm’ in these instances.

Policy BC3: City Fringe Opportunity Area

3.15. The Methodist Church supports the ‘maximisation’ of business floorspace as well as the importance of providing a range of business floorspace in the City Fringe Opportunity Area as encouraged by Part C of this policy.

3.16. However, as set out previously at BC1 above, this policy aspiration should not be overly prescriptive, in terms of the amount of floorspace required to be offices, and instead a focus on ‘office-led’ development should be prioritised.

Site Allocation BC33: Oliver House, 51-53 City Road. EC1Y 1AU

3.17. Site Allocation BC33 of the Bunhill and Clerkenwell Area Action Plan (Reg 19 Draft) allocates Oliver House for refurbishment/intensification of office use. This allocation has not materially changed from the Regulation 18 version of the Plan and our client welcomes the continued allocation of the site for development.

3.18. The estimated timescale for potential refurbishment/intensification is between 2021/22 to 2025/26 which is in line with our client’s aspirations for the site and their willingness to develop the site in the short term. The site allocation does not identify any site-specific development considerations.


3.19. We consider that it would be more effective to allocate this site for an officer-led mixed-use development to enable the provision of complimentary retail and community facilities to be provided at basement and ground floor levels which still maintaining the primacy of office use.

3.20. A more flexible approach to the range of uses on this site would allow development to come forward which is effective in responding to the demand for the business needs of the area and also the need to enhance the social value of development over the Plan period which would make it a more effective and justified plan.

3.21. The intensification of office use on the site could easily be achieved whilst also delivering other commercial uses, such as A Class retail uses and/or non-residential institutional uses (D1 use class), as part of a mixed-use scheme. This would require the demolition of the existing building and erection of a new, high quality building on site. The demolition of the existing building and the proposed high-quality design of a new building would be sympathetic to the nearby heritage assets and would enhance the setting of these assets, in keeping with London Plan policy and emerging Local Plan policy.

3.22. The site does have a number of heritage constraints. Therefore, a mix of uses, including A1, A3 and D1 uses should be included in the proposed policy wording in order to maintain flexibility and make the development site more viable.

3.23. The Site Allocation should therefore be amended to allocate the site for an office-led mixed use development. We would expect the redevelopment of the site to be able to provide 2,000 – 3,000sqm of office floorspace. The inclusion of Use Class A3 (restaurants and cafes) and Use Class D1 (non-residential institutions) would also deliver clear sustainability benefits by co-locating commercial and employment uses within one location and delivering greater consumer choice and floorspace of community benefit.


4. Conclusion

4.1. On behalf of our client, The Methodist Church, WSP | Indigo has assessed the Islington Local Plan Review and where appropriate, the supporting evidence base, against the test of soundness under Regulation 19:



4.2. Greater flexibility should be included in the proposed policies and they should be less prescriptive in terms of the amount of office floorspace to be provided.

4.3. However, concerns have been raised around the detail of the policy which may affect the delivery of allocation BC33 as presently drafted.

4.4. There is a lack of flexibility within allocation BC33 and, as drafted, the allocation does not allow for other commercial uses, which would be required to deliver the development.

4.5. Finally, policies BC1 and BC2 should be amended to reflect our representations in order to ensure that the Plan is deliverable, justified and effective.

www.indigoplanning.com

Regulation 19 ConsultationRepresentations on behalf of The Methodist Church

Local Plan Review for Bunhill andClerkenwell Area Action Plan, SiteAllocations & Strategic andDevelopment Management Policies

Local Plan Review for Bunhill and Clerkenwell Area Action Plan, Site Allocations & Strategic and Development Management Policies Regulation 19 Consultation Representations on behalf of The Methodist Church October 2019

WSP | Indigo

Aldermary House 10-15 Queen Street London EC4N 1TX T 020 3848 2500 E [email protected] W indigoplanning.com

Local Plan Review for Bunhill and Clerkenwell Area Action Plan, Site Allocations & Strategic and Development Management Policies Regulation 19 Consultation Representations on behalf of The Methodist Church

Contents Page

1. Introduction 1

2. Strategic and Development Management Policies– Reg 19 Draft 2 Policy SP1: Bunhill and Clerkenwell 2Policy H1: Thriving Communities 2Policy B1: Delivering business floorspace 2Policy B2: New business floorspace 2Policy B4: Affordable workspace 3Policy S3: Sustainable Design Standards 3

3. Bunhill and Clerkenwell Area Action Plan – Reg 19Draft 4 Policy BC1: Prioritising office use 4Policy BC2: Culture, retail and leisure uses 5Policy BC3: City Fringe Opportunity Area 5Site Allocation BC33: Oliver House, 51-53 City Road.EC1Y 1AU 5

4. Conclusion 7


1. Introduction

1.1. These representations are made on behalf of our client, The Methodist Church, in respect of the current Pre-Submission Consultation on the following documents:



1.2. These documents are being consulted on under Regulation 19 of the Town and Country Planning (Local Planning) (England).

1.3. We set out our further representations in respect of the Regulation 19 documents in the following sections.


2. Strategic and Development Management Policies – Reg 19 Draft

Policy SP1: Bunhill and Clerkenwell

2.1. Bunhill and Clerkenwell is identified as a key area for development within the borough, in particular for office, cultural, retail and leisure uses.

2.2. The Methodist Church supports the anticipated growth of office floorspace in the area as well as the enhanced provision of retail and cultural floorspace. The allocation of Oliver House (Policy BC33) will be a strong contributor to this strategic objective and would be able to deliver a mix of uses in accordance with Policy SP1.

Policy H1: Thriving Communities

2.3. Policy H1 seeks to enhance the social value of development within the borough. The Methodist Church are supportive of part S and V of this policy which encourage the development of social and community infrastructure required to support the borough’s residents and the maximisation of social value on development sites.

2.4. Community floorspace is essential for the maintenance of strong, vibrant and healthy communities and the council should be supporting the provision of these uses as part of a mixed-use development across the borough.

Policy B1: Delivering business floorspace

2.5. Policy B1 seeks the ‘maximisation’ of business floorspace in the Central Activity Zone (CAZ) and Bunhill and Clerkenwell AAP. This includes the aim to deliver 400,000sqm of additional office floorspace by 2036.

2.6. The maximisation of business floorspace is, however, poorly defined in the draft policy wording. The Methodist Church agrees that new development in the CAZ and Bunhill and Clerkenwell AAP should be office-led however the policy wording should refer to ‘maximisation’ subject to design constraints and/or viability.

2.7. Part B. of the Policy should therefore be amended to ensure that office-led development can be realistically and viably delivered:

“New business floorspace will be focused in the CAZ, Bunhill and Clerkenwell AAP area, the CAZ fringe Spatial Strategy areas of Angel and Upper Street and Kings Cross and Pentonville Road, PELs and Locally Significant Industrial Sites. Proposals in these areas must maximise the amount of new business floorspace, subject to design constraints and/or development viability. Proposals which cannot demonstrate maximisation that the majority of new/additional floorspace is business floorspace will be considered to be an inefficient use of a site and will be refused.”

2.8. Without this amendment to loosen the required business floorspace provision in new developments, the Council will not be able to deliver their required employment floorspace and this would render the Plan unsound.

Policy B2: New business floorspace

2.9. We are supportive of the identification of the Bunhill and Clerkenwell AAP area as being a


priority area for new office uses. However, the inclusion of reference to office led mixed-use development would also be welcomed.

Policy B4: Affordable workspace

2.10. Policy B4 seeks to ensure the delivery of affordable B-use workspace in the borough. The policy seeks to ensure that 10% affordable workspace has to be leased to the council for a peppercorn period of at least 20 years. Furthermore, the policy requires all applicants to submit an Affordable Workspace Statement.

2.11. Whilst the need for affordable workspace to be accommodated within scheme is understandable from the council’s perspective, the draft policy requirement for the space to leased to the council is unreasonable and a conflict of interest. The key objective is to make the space affordable and provided this can be achieved through conditions or a planning obligation, there should be no requirement for the space to be leased to a particular organisation such as the council. The council would be using its role as the planning authority to directly benefit its property interest in the boroughs. This is inappropriate and the requirement to lease to the council should be removed from the policy.

2.12. We are also concerned at the requirement for financial contributions. This policy doesn’t seem to have been properly tested in viability terms and has the potential to make many schemes unviable which will make schemes undeliverable. This would result in more stagnation and sites being blighted.

Policy S3: Sustainable Design Standards

2.13. Policy S3 states that all non-residential and mixed use developments proposing more than 500sqm net additional floorspace are required to achieve BREEAM ‘Excellent’ standards and must make reasonable endeavours to achieve ‘Outstanding’.

2.14. Although this approach is commendable, the policy wording should be amended to provide greater flexibility and determined on a case-by-case basis subject to design constraints and viability.


3. Bunhill and Clerkenwell Area Action Plan – Reg 19 Draft

Policy BC1: Prioritising office use

3.1. Policy BC1 specifically supports office use in the Bunhill and Clerkenwell area with the intention to maximise office floorspace. This includes the aim to deliver 400,000sqm of additional office floorspace by 2036.

3.2. The Methodist Church support the strategic objective to deliver 400,000sqm office floorspace. However, at present, the Plan does not meet the Council’s own strategic objectives to deliver high quality office floorspace, maintaining and developing business and job growth.

3.3. The Oliver’s House site (proposed allocation BC33) is located within the City Fringe Opportunity Area.

3.4. Part B. (i) identifies that new development proposals providing 500sqm or more net increase in floorspace in the City Fringe Opportunity Area must comprise at least 90% office floorspace. Whilst the Methodist Church appreciate the primary objective of providing office floorspace in the City Fringe Opportunity Area, the policy should introduce more flexibility by ensuring that development viability is considered, and the individual circumstances of each development proposal is taken into consideration in the policy wording.

3.5. Part B. should therefore be amended as follows:

“All development proposals providing 500sqm or more net increase in floorspace (within any use class) must comprise at least:

(i) 90% office floorspace (as a proportion of the total net additional floorspace proposed) be office-led, meaning that the majority of floorspace (as a proportion of the total net additional floorspace proposed) must be office floorspace, in the City Fringe Opportunity Area and any other part of the Bunhill and Clerkenwell AAP area, and subject to design constraints and/or development viability; or

(ii) 80% office floorspace (as a proportion of the total net additional floorspace proposed) in any other part of the Bunhill and Clerkenwell AAP area, if considered viable.”

3.6. This amendment is necessary to ensure that employment-led development is not stymied by an arbitrary threshold and ensure that office-led development can continue to be delivered in the borough. As currently drafted, the policy is unjustified and is contrary to the emphasis in the National Planning Policy Framework (2019) that mixed use developments should be encouraged in appropriate locations.

3.7. Furthermore, Part C. seeks to ensure that new development proposals in the Bunhill and Clerkenwell area which are not compliant with Part B. are office-led. Even though the policy identifies the meaning of ‘office-led’, it remains unclear which other uses are acceptable and what the Policy defines as ‘majority’ of floorspace.

3.8. Part C. should therefore be amended as follows:

“Development proposals within the Bunhill and Clerkenwell area,


including the City Fringe Opportunity Area, under the threshold set out in Part B must be office-led, meaning that the majority of floorspace (as a proportion of the total net additional floorspace proposed) must be office floorspace, with the co-location of other main town centre uses considered appropriate where justified.

3.9. Without this added flexibility, the Council will not be able to deliver their required employment floorspace and this would render the Plan unsound.

3.10. The Methodist Church supports the inclusion of Part D of the policy which provides exceptions for sites where circumstances may prevent them from providing the quantum of floorspace currently prescribed by Parts B and C of the policy. However, a further circumstance should be included in the list which refers to:

“vi. proposals for mixed use development that would provide enhanced social value and enhanced provision of community facilities.”

3.11. An addition should also be made to circumstance iii. which recognises the importance of non-residential institutions as serving a public service.

“iii. where a proposal is publicly funded or serves a public service, such as educational, medical, or research institutions and non-residential institutions.”

3.12. These additions enable the delivery of mixed-use, employment-led schemes and ultimately supports the Council in meeting their identified office floorspace need within the plan period.

Policy BC2: Culture, retail and leisure uses

3.13. The Methodist Church supports the development of retail and leisure uses in predominantly commercial areas. We suggest, however, making it clearer that ‘predominantly commercial areas’ includes the City Fringe Opportunity Area.

3.14. Part D. (i) states that new A Class uses are permitted where they would not harm vitality, viability, character, function or amenity of the area. The Methodist Church would like to see further guidance on how the LPA defines ‘harm’ in these instances.

Policy BC3: City Fringe Opportunity Area

3.15. The Methodist Church supports the ‘maximisation’ of business floorspace as well as the importance of providing a range of business floorspace in the City Fringe Opportunity Area as encouraged by Part C of this policy.

3.16. However, as set out previously at BC1 above, this policy aspiration should not be overly prescriptive, in terms of the amount of floorspace required to be offices, and instead a focus on ‘office-led’ development should be prioritised.

Site Allocation BC33: Oliver House, 51-53 City Road. EC1Y 1AU

3.17. Site Allocation BC33 of the Bunhill and Clerkenwell Area Action Plan (Reg 19 Draft) allocates Oliver House for refurbishment/intensification of office use. This allocation has not materially changed from the Regulation 18 version of the Plan and our client welcomes the continued allocation of the site for development.

3.18. The estimated timescale for potential refurbishment/intensification is between 2021/22 to 2025/26 which is in line with our client’s aspirations for the site and their willingness to develop the site in the short term. The site allocation does not identify any site-specific development considerations.


3.19. We consider that it would be more effective to allocate this site for an officer-led mixed-use development to enable the provision of complimentary retail and community facilities to be provided at basement and ground floor levels which still maintaining the primacy of office use.

3.20. A more flexible approach to the range of uses on this site would allow development to come forward which is effective in responding to the demand for the business needs of the area and also the need to enhance the social value of development over the Plan period which would make it a more effective and justified plan.

3.21. The intensification of office use on the site could easily be achieved whilst also delivering other commercial uses, such as A Class retail uses and/or non-residential institutional uses (D1 use class), as part of a mixed-use scheme. This would require the demolition of the existing building and erection of a new, high quality building on site. The demolition of the existing building and the proposed high-quality design of a new building would be sympathetic to the nearby heritage assets and would enhance the setting of these assets, in keeping with London Plan policy and emerging Local Plan policy.

3.22. The site does have a number of heritage constraints. Therefore, a mix of uses, including A1, A3 and D1 uses should be included in the proposed policy wording in order to maintain flexibility and make the development site more viable.

3.23. The Site Allocation should therefore be amended to allocate the site for an office-led mixed use development. We would expect the redevelopment of the site to be able to provide 2,000 – 3,000sqm of office floorspace. The inclusion of Use Class A3 (restaurants and cafes) and Use Class D1 (non-residential institutions) would also deliver clear sustainability benefits by co-locating commercial and employment uses within one location and delivering greater consumer choice and floorspace of community benefit.


4. Conclusion

4.1. On behalf of our client, The Methodist Church, WSP | Indigo has assessed the Islington Local Plan Review and where appropriate, the supporting evidence base, against the test of soundness under Regulation 19:



4.2. Greater flexibility should be included in the proposed policies and they should be less prescriptive in terms of the amount of office floorspace to be provided.

4.3. However, concerns have been raised around the detail of the policy which may affect the delivery of allocation BC33 as presently drafted.

4.4. There is a lack of flexibility within allocation BC33 and, as drafted, the allocation does not allow for other commercial uses, which would be required to deliver the development.

4.5. Finally, policies BC1 and BC2 should be amended to reflect our representations in order to ensure that the Plan is deliverable, justified and effective.

www.indigoplanning.com

R19.0131 - The Methodist Church_redactedR19.0131 - The Methodist Church_redacted1

m: e - islington · the space affordable and provided this can be achieved through conditions or a...

Documents