Planning Application Sub-Committee 11 June 2024 Subject

Committee:

Date:

Planning Application Sub-Committee

11 June 2024

Subject:

Change of use of existing deep level tunnels (Sui Generis)

to visitor and cultural attraction (Use Class F1(b)(c)),

including bar (Sui Generis); demolition and reconstruction

of existing building at 38-39 Furnival Street; redevelopment

of 40-41 Furnival Street, for the principal visitor attraction

pedestrian entrance at ground floor, with ancillary retail at

first and second floor levels and ancillary offices at third

and fourth levels, excavation of additional basement levels

at 40-41 Furnival Street and 38-39 Furnival Street, and

widening of lift shaft at 38-39 Furnival Street; creation of

new, pedestrian entrance at 31-33 High Holborn, to

provide secondary visitor attraction entrance (including

principal bar entrance), deepening of lift shaft at 31-33

High Holborn; provision of ancillary cycle parking,

substation, servicing and plant, and other associated

works (Duplicate application submitted to the London

Borough of Camden as the site area extends across the

borough boundary). Re-consultation: Due to amended

details (Duplicate application submitted to the London

Borough of Camden as the site area extends across the

borough boundary).

Public

Ward: Farringdon Without

For Decision

Registered No: 23/01322/FULMAJ

Registered on:

01 December 2023

Conservation Area: Chancery Lane

Listed Building: No

Summary

Existing site

The site is located in the northwest of the City to the south of High Holborn. It

comprises below and above ground level elements. The underground element of the

application site consists of a network of tunnels (formally named the Kingsway

Tunnels) that run underneath High Holborn and cross the City of London and the

London Borough of Camden boundaries. The tunnels are managed by British Telecom

who are responsible for their maintenance. Above ground, the application site

comprises three buildings. Two buildings are located within the City of London

boundary at 38-39 and 40-41 Furnival Street and the third is located in the London

Borough of Camden at 31-33 High Holborn, accessed via Fulwood Place.

The existing building at 38-39 Furnival Street forms part of the tunnels access, hosting

a goods shaft and various ventilation ducts serving the eastern part of the tunnels and

is currently not in use given the vacant nature of the application site. The building at

40-41 Furnival Street is in office use.

Proposals

The application proposes to change the use of the existing deep-level subterranean

tunnels (Sui Generis) to a visitor and cultural attraction (Use Class F1 (b),(c)) including

a bar (Use Class Sui Generis). The demolition and reconstruction of the existing

vacant building at 38-39 Furnival Street and offices at 40-41 Furnival Street is being

proposed in order to link the two buildings internally and use the ground floor as the

principal entrance to the cultural attraction. The new buildings would also provide

ancillary retail space, including a gift shop at the first and second floor levels and

ancillary office accommodation, at the fourth level, to be used by staff. Public realm

improvements, including a shared surface and widening of the pavement in front of

the principal entrance at Furnival Street are proposed.

A duplicate application has been submitted to the London Borough of Camden as the

site area extends across the borough boundary. A secondary pedestrian entrance to

the deep-level tunnels would be retained at 31-33 High Holborn via Fulwood Place

(falling within LB Camden boundary) and upgraded to form the main entrance to the

proposed bar and an additional emergency exit.

The existing and proposed floorspace for different parts of the site is set out in the

following table:

Schedule of Areas

Building

sqm (GIA)

Existing

Proposed

Difference

38-39 Furnival Street (City of London)

194

942

+ 748

40-41 Furnival Street (City of London)

1,229

1,525

+ 296

31-33 High Holborn (Camden)

329

Tunnels Complex (City of London &

Camden)

7,829

Total

9,581

10,625

+ 1,044

The following table provides the proposed GEA (Gross External Area) and GIA (Gross

Internal Area) figures split between the two Local Planning Authorities. Approximately

71% of the site area created by the proposed development belongs within the City’s

boundaries.

GEA

GIA

Level

COL

(GIA)

Camden(GIA)

38-41 Furnival Street

3,020

2,467

Fulwood Place

386

329

Tunnel Network

9,828

7,829

5,111

2,718

TOTAL

13,234

10,625

7,578

3,047

Consultations

On the 10

January 140 letters were sent to residential properties in addition to site

notices posted on different locations around the proposed main and secondary

entrances to the site. Following some minor updates and amendments to the proposed

scheme a 14 days re-consultation round was carried out in April 2024.

A total of 57 letters of support have been received supporting the efforts of the proposal

to utilise existing infrastructure by embracing and preserving the history of Kingsway

Tunnels, boosting the local economy by bringing footfall in the area, creating new jobs

and overall, creating a benchmark development of national importance.

A total of 24 letters of objection have been received, with the key themes of objections

being residential and business amenity, traffic and highways, and the harm to the

conservation area.

Two neutral responses have been received with comments made about noise and

traffic.

A total of 12 statutory responses have been received none of which were objecting to

the proposed development. Given the somewhat unique nature of the site, the

subterranean layout and the long underground distances London Fire Brigade have

indicated various measures that would need to be considered post planning stage.

While there is no formal objection to the scheme under the Planning Act, it has been

considered that further details of the fire strategy would only be known at the

Qualitative Design Review (QDR) processes and therefore the applicant has made

commitments to actively consult with London Fire Brigade and other emergency

services to addresses all matters raised post planning application stage (i.e. under

Building Regulations).

From the above, nine were received during the first round of formal public consultation.

The second round of public consultation was carried out following receipt of

amendments to the proposals, mainly with updates to the transport assessment and

servicing plan. Only one new representation has been received following the proposal

updates from the Transport for London Spatial Planning team which did not raise any

objections to the proposed development.

The representations holding planning material consideration have been addressed in

the report and relevant conditions have been recommended wherever necessary.

Loss of office

The planning application proposes the loss of office space at 40-41 Furnival Street in

order to provide additional ancillary space for the operation of the proposed cultural

use. In addition to the submitted Planning Statement supporting information for the

proposed loss has been provided over the course of the application. While limited

Viability Assessment documentation has been submitted as part of the proposal, the

loss of the modest office has been weighed against the exceptional re-use of the

adjoining heritage asset (38-39 Furnival Street and the existing tunnels), the inherent

requirement of 40-41 Furnival Street for access/ancillary space and the wider

economic benefits the cultural use would bring to the City as a whole. Whilst the Local

Plan generally resists the loss of office floorspace, the scale of the loss on this site

(1,229sqm) would not prejudice the overall supply of office space in the City, nor

prejudice the potential for future site amalgamation or result in the loss of existing stock

for which there is demand or longer-term viable need. The proposed cultural and visitor

use would not compromise the primary business function of the City as it would provide

alternative complementary activities to the City’s business function offering a unique

experience for its workers, residents and visitors, and add a significant cultural supply

to the City’s stock meeting Destination City’s aspirations. It is considered that the loss

of office floorspace would therefore be acceptable in this instance.

Cultural Use

The Local Plan and London Plan supports the delivery of cultural uses. The proposal

would include the provision for permanent and temporary cultural exhibition spaces to

bring a new dynamic to the City and facilitate a 7/7 City, increasing footfall and

becoming an inclusive destination. The proposal would assist in achieving the City’s

aspirations for Destination City that focuses on enhancing the leisure and cultural offer

in the Square Mile and increase its appeal to existing audiences by creating fun,

inclusive, innovative, and sustainable ecosystems. The proposed permanent ‘Heritage

Experience’ would directly reference the historic tapestry of the City and the flexible

exhibition spaces, known as ‘The Streets’, would provide a unique and distinctive

space for cultural events within the Square Mile. The proposed bar would further

facilitate a 7/7 City and represent a complimentary use to the City’s main function

although it is noted that this element is located with the London Borough of Camden.

In addition to the above, the development would also bring about a series of social

benefits including the provision of enhanced access for disabled people, free school

trips, discounted tickets for special groups, training programmes, and opportunities to

engage with the local community to shape the design of the exhibitions. Is considered

to be an enhancement to the City's cultural provision and provide significant public

benefit to residents, workers, and visitors.

Design and Heritage

The disposition of the final massing and bulk has followed a design-led approach

considering macro and local townscape impacts with multiple pre-application

negotiations to mitigate adverse impacts on surround heritage assets. In respect of

massing, height and materiality, the distinctive sense of separate buildings, materials,

the celebration of industrial heritage and intended quality would introduce a well-

considered, refined, neighbourly architectural set piece. The bold architectural

expression would reflect the unique cultural use of the buildings and the subterranean

tunnel network.

The proposal would preserve the historic and rarity interest of the Kingsway Tunnels

as a non-designated heritage asset and any harm which arises as a result of the

development would be mitigated by the improvement to the accessibility and visibility

of this currently unknown heritage asset to a wide public audience.

Public Access and Inclusivity

The tunnels form an existing infrastructure which the proposed development seeks to

utilise. Accessibility standards were not included in their design at the time of their

construction given the original intent of the structures. The proposal seeks to retain

and restore the infrastructure without any construction works taking place in the tunnel

network other than general fit-out works. Providing a highly accessible environment

for the site therefore comes with its own challenges. The proposed cultural use would

offer step-free access along the site and provisions have been made for ground level

accessible cycle space and a parking space for staff arriving on outdoor scooters.

Large passenger lifts would provide access to the cultural space and the gift shop at

the first and second floors and separate lifts would serve the upper levels including the

staff accommodation at level four which is designed with accessible standards. The

arrival to the site has been also considered, with improvements to the public realm

focusing on pedestrian environment and capacity of the street. Details of the

accessibility and inclusivity of the cultural development as well as the operational

details for the site would be secured by conditions and Section 106 obligations to

ensure highest levels of accessibility would be applied.

Public Realm

The proposal aims to deliver public realm works to improve the pedestrian

environment and the capacity of Furnival Street. It sets the building line of No. 40-41

Furnival Street back to provide an inside foyer and increase the footway width of the

main entrance. The original submission has been revised following Transport Officer’s

comments to align with the City’s Healthy Steet scheme, specifically under the Fleet

Street Area, Healthy Steets Plan which incorporates Chancery Lane neighbourhood

improvements including Furnival Street. Improvement works would be subject to a

design scheme by the Highways Authority which should take into consideration a

shared surface along Furnival Street, parking arrangements and cycle lane revisions,

provision of accessible seating available along the approaches to the development,

repair works and greenery. Under the Healthy Streets initiative, the Local Authority

would potentially consider time closures of Furnival Street to restrict vehicle access

and create a more welcome and safer environment for pedestrians as well as

maximising the capacity of the local street for the increased footfall generated by the

proposed development, however this would be subject to further consultation with

residents and local occupiers.

Transport

In term of public transport provision, the site has the highest level of Public Transport

Accessibility Level (PTAL) of 6B. The submitted Transport Assessment (TA) in support

of this application, included details on the trip generation and modal splits. The

proposal aims to mitigate its impacts by including various public realm improvement

works along the Furnival Street, in conjunction with the City of London’s Healthy Street

aspirations for the area, as discussed above. The general aim of the Healthy Street

plan for Furnival Street is to redesign the street and manage access to make streets

more accessible, engaging and providing safe places for people to walk, cycle and

spend time. These highway improvements are to be secured through S278 works and

its scope via the S106 legal agreement.

The proposal includes a compliant number of 12 long stay cycle parking spaces for

the proposed cultural use and an additional 2 spaces for the bar should be provided,

however short stay cycle parking for visitors would have to be provided on the public

highway given the constraints of the site. Considering the London Plan and Local

policy, officers consider that for this type of use, short cycle parking spaces standards

are of a provision of 1 space per 100sqm, thus 125 cycle parking spaces would be

required. Due to the constraints of the development located on the Furnival Street and

the large number of spaces required, it is not possible to provide these spaces within

the development itself. Nevertheless, the application includes a S106 legal agreement

to secure the provision of cycle parking spaces on the public highway, including

improvements of the cycle infrastructure in the vicinity of this development. Over the

course of the application, it was agreed to split the visitor cycle parking between the

two LPAs, with LBC agreeing to provide 20% of the total requirement in their highways.

Finally, the Construction Logistics Plans (CLP) and Delivery and Servicing Plans

(DSP) are proposed to be developed in accordance with TfL guidance and the latest

standards and as such both plans would be monitored throughout the demolition and

construction phase and thereafter when the development becomes operational.

Daylight/Sunlight and Lighting Scheme

With regard to daylight sunlight impacts, the surrounding residential and commercial

buildings have been assessed against the existing and proposed massing of the

proposed buildings. In particular 1 to 6 Dyers Buildings, residential properties

immediately to the east of the site, have been assessed with other properties

surrounding properties being given a lesser weight in the assessment due to their non-

domestic nature and windows not orientated within 45 degrees of the uplift of the

proposed development. 1-3 Dyers Building assessment results demonstrate a

moderate to high level of BRE compliance. Where there are technical breaches of the

BRE guidelines, these can be attributed to the low existing levels of daylight currently

received by the neighbouring residential properties assessed, which would be

sensitive to proportionately higher percentage reductions. 4 –6 Dyers Buildings have

been included in later responses on daylight sunlight assessments and showed BRE

compliance similar to that of the above.

While the application proposes to demolish the existing buildings at Furnival Street,

the proposal seeks to redevelop the buildings in-line with the existing massing and

height. This has been intentionally designed as such to ensure a limited impact on the

amenity of surrounding neighbours and this is reflected in the very modest alterations

to daylight/sunlight within the submitted assessment.

Overall, the daylight and sunlight available is considered to be sufficient and

appropriate to the context, and acceptable living standards would be maintained. As

such, the overall impact (including the degree and extent of harm) is not considered

to be such that it would conflict with any of the relevant development plan policies.

Sustainability

The Local Plan and London Plan requires development to support environmental,

economic, and social sustainability. The Plans also require that developments are

designed to maximise operational efficiency and minimise associated carbon

emissions throughout the buildings’ lifetimes.

The proposed development is a retrofit led proposal to bring a historic and well-storied

asset, currently under-utilised, back into common usage of high cultural value.

Demolition is mostly limited to Furnival Street where the practicalities of construction

and accommodating services required make retention unviable. This proposed

change of use does come with its own challenges. Built as air-raid shelter and

telephone exchange, the tunnels were not designed for ease of access or extended

occupation by large numbers of people. The access, ventilation, and cooling

requirements to facilitate the proposed visitor numbers have been carefully designed

to optimise energy efficiency and minimise waste heat but still come at a high carbon

cost with large amounts of equipment, spanning the full length of the tunnels. The

potential audio-visual equipment associated with the immersive cultural offering has

been demonstrated to increase the carbon impact of the development significantly.

However, the new building at Furnival Street has been designed following circular

principles, with future flexibility, maintenance and disassembly in mind.

CIL and Planning Obligations

The scheme would provide benefits through CIL for improvements to the public realm,

housing and other local facilities and measures. That payment of CIL is a local finance

consideration which weighs in favour of the scheme. In addition to general planning

obligations there would be site specific measures secured in the S106 Agreement.

Conclusion and Recommendation

The proposal has been assessed in accordance with the relevant statutory duties and

having regard to the development plan (i.e., the London Plan and Local Plan) and

relevant policies and guidance, SPDs and SPGs, relevant advice including the NPPF,

the draft Local Plan and considering all other material considerations.

It is almost always the case that where major development proposals come forward

there is at least some degree of non-compliance with planning policies, and in arriving

at a decision, it is necessary to assess all the policies and proposals in the plan and

to come to a view as to whether in the light of the whole plan the proposal does or

does not accord with it.

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

development. For decision taking that means approving development proposals that

accord with an up to date development plan without delay.

In this case, the proposals are considered to be in accordance with the development

plan as a whole. In addition, the Local Planning Authority must determine the

application in accordance with the development plan unless other material

considerations indicate otherwise.

It is the view of officers that as the proposal complies with the Development Plan when

considered as a whole and taking into account all material planning considerations, it

is recommended that planning permission be granted subject to all the relevant

conditions being applied and Section 106 obligations being entered into in order to

secure public benefits and minimise the impact of the proposal.

Recommendation

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

of the matters set out under the heading ‘Planning Obligations’ the Planning

and Development Director be authorised to issue a decision notice granting

planning permission for the above proposal in accordance with the details set

out in the attached schedule;

2. That your officers be instructed to negotiate and execute obligations in respect

of those matters set out in "Planning Obligations" under Section 106 of the

Town and Country Planning Act 1990 and any necessary agreements under

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

out in the report;

Or;

3. In the event that a legal agreement satisfactorily securing cross boundary

obligations is not completed within 12 months of the date of the resolution

officers be instructed to REFUSE permission for the substantive reason that the

scheme fails to mitigate the adverse impacts noted within the officer report and

is therefore contrary to the policies contained within the Development Plan.

Image 1: View looking north down Furnival Street

Image 2: View looking north across High Holborn towards 31-33 High Holborn

Image 3: Existing equipment with in the Kingsway Tunnels

Image 4: Existing canteen with in the Kingsway Tunnels

Image 5: Visual of proposed development looking south

Image 6: Visual of proposed Furnival Street entrance

Image 7: Visual of proposed heritage exhibition

Image 8: Visual of proposed bar

APPLICATION COVER SHEET

38-41 Furnival Street

TOPIC

INFORMATION

1. HEIGHT

EXISTING

PROPOSED

AOD Heights:

39 Furnival Street: +32.25

AOD

40 Furnival Street: +43.89

AOD

Fulwood Place: +49.09

AGL Heights:

39 Furnival Street: 12.4m

40 Furnival Street: 24m

Fulwood Place: 27.5m

AOD Heights:

39 Furnival Street: +35.63

40 Furnival Street: +41.75

Fulwood Place: +49.09

AGL Heights:

39 Furnival Street: 15.8m

40 Furnival Street: 21.95m

Fulwood Place: 27.5m

2. FLOORSPACE GIA

(SQM)

USES

EXISTING

PROPOSED

Class F1

(Visitor

Attraction)

10,341

Sui Generis

(Bar)

248

Sui Generis

(Tunnels)

8,352

Class E

(Office)

1,229

TOTAL

9,581

TOTAL:

10,625

TOTAL UPLIFT:

1,044

3. OFFICE PROVISION

IN THE CAZ

Existing: 1,229 sqm

Proposed: 0 sqm

Office uplift: -1,229 sqm

4. EMPLOYMENT

NUMBERS

EXISTING

PROPOSED

Circa. 65

Circa. 85

5. VEHICLE/CYCLE

PARKING

EXISTING

PROPOSED

Car parking

spaces

Car parking

spaces

Accessible

car parking

Accessible car

parking

Cycle long

stay

Cycle long stay

Cycle short

stay

Cycle short stay

125

Lockers

Staff: 18

small

lockers

Visitors: 9

large

object

lockers / 18

small

lockers

Showers

Staff: 2

Changing

facilities

Changing facilities

Staff: 2

Visitors: 1

6. HIGHWAY LOSS /

GAIN

No loss or gain of highway proposed.

7. PUBLIC REALM

S278 agreement to secure improve pedestrian environment and

capacity of Furnival Street, to include a shared surface.

8. STREET TREES

EXISTING

PROPOSED

9. SERVICING

VEHICLE TRIPS

EXISTING

PROPOSED

N/A

8 deliveries on a typical day and

up to 14 vans during times

when exhibition set up is required.

10. SERVICING HOURS

All delivery activity will take place outside of opening hours and

predominantly between 20:00-22:00.

11. RETAINED FABRIC

90% of total site by area (Furnival St., Tunnels, & Fulwood Place)

0% of Furnival Street by area

14.2 m3 of brick, 1.4m3 of precast louvres (subject to condition)

12. OPERATIONAL

CARBON EMISSION

SAVINGS

Improvements against Part L 2021: 41.4% (30.7 tCO2)

GLA requirement: 35 %

13. OPERATIONAL

CARBON

EMISSIONS

B6 & B7 = 1,090 kgCO2e/m2

11,582,588 kgCO2e

Based on medium scenario as set out in Sustainability section

14. EMBODIED

CARBON

EMISSIONS

PROJECT LIFE CYCLE EMISSIONS COMPARED TO GLA

RETAIL BENCHMARKS (No benchmarks available for cultural

buildings)

Total upfront embodied carbon 7,911.8 tonnes CO

e /

745 kgCO

e per sqm

15. WHOLE LIFE-

CYCLE CARBON

EMISSIONS

Total whole life-cycle carbon emissions: 29,137 tonnes CO

Whole life-cycle carbon emissions per square meter: 2.742

tonnes CO

/sqm

16. WHOLE LIFE-

CYCLE CARBON

OPTIONS

Furnival Street

Options

Option 1

Major

refurb

Option 2

Major

refurb with

extension

Option 3

Redevelop-

ment

1. Gross Internal

area (GIA) m²

1979

2125

2589

2. Increase in GIA

(over existing)

10%

35%

60%

3. Substructure %

retained by mass

100%

4. Superstructure %

retained by area

(frame, upper

floors, roof, stairs,

ramps)

55%

35%

5. Upfront Embodied

Carbon (A1-A5)

(kgCO₂e/m² GIA)

666

616

818

6. In-use & End of

Life Embodied

Carbon (B-C)

(kgCO₂e/m² GIA)

excl. B6 & B7

464

461

453

7. Life-cycle

Embodied Carbon

(A1-A5, B1-B5,

C1-C4)

(kgCO₂e/m² GIA)

1,130

1,077

1,271

8. Fuel source

Electricity

9. Operational

Energy Use (B6) of

the Tunnels +

Furnival St.

(divided by GIAm

of Furnival St.

only) (kWh/m²/yr

GIA)

424

395

324

10. Estimated Whole

Building

Operational

Carbon for building

lifetime (B6)

(kgCO₂e/m² GIA)

883

822

675

11. Total WLC

Intensity (incl. B6 &

pre-demolition)

(kgCO₂e/m² GIA)

Module B7 is not

considered

2,026

1,918

1,977

12. Upfront embodied

carbon (A1-A5)

(tCO₂e)

1,318

1,309

2,118

13. In-use embodied

carbon (B-C, excl.

B6 & B7) (tCO₂e)

918

980

1,173

14. Operational carbon

for building lifetime

(B6) Tunnels +

Furnival St.

(tCO₂e)

1,747

1,748

1,746

15. Total WLC (incl.

B6 and pre-

demolition)

(tCO₂e) Module B7

is not considered

4,009

4,077

5,117

17. TARGET

BREEAM

RATING

Targeting a high-score “Very Good” BREEAM rating.

18. URBAN

GREENING

FACTOR

0.13

19. AIR QUALITY

As there are no anticipated operational emissions associated with

the Proposed Development it is considered to be Air Quality

Neutral.

Main Report

Assessing a cross-boundary planning application

1. The application site straddles the City of London and the London Borough of

Camden boundaries.

2. The National Planning Practice Guidance provides that where a site, which is

the subject of a planning application, straddles one or more local planning

authority boundaries, the applicant must submit identical applications to each

local planning authority.

3. Each planning application falls to be assessed under the Town and Country

Planning Act 1990. S70 provides that in dealing with a planning application the

local planning authority should have regard to the development plan, any local

finance considerations and any other material considerations. Planning and

Compulsory Purchase Act S38 (6) provides that where regard is to be had to

the development plan the determination should be in accordance with the

development plan unless material considerations indicate otherwise.

4. Duplicate planning applications for the proposed ‘Change of use of existing

deep level tunnels (Sui Generis) to visitor and cultural attraction (Use Class

F1(b)(c)), including bar (Sui Generis); demolition and reconstruction of existing

building at 38-39 Furnival Street; redevelopment of 40-41 Furnival Street, for

the principal visitor attraction pedestrian entrance at ground floor, with ancillary

retail at first and second floor levels and ancillary offices at third and fourth

levels, excavation of additional basement levels at 40-41 Furnival Street and

38-39 Furnival Street, and widening of lift shaft at 38-39 Furnival Street;

creation of new, pedestrian entrance at 31-33 High Holborn, to provide

secondary visitor attraction entrance (including principal bar entrance),

deepening of lift shaft at 31-33 High Holborn; provision of ancillary cycle

parking, substation, servicing and plant, and other associated works’ have been

submitted to the London Borough of Camden (LBC) and the City of London

(CoL) Local Planning Authorities (LPA). Each LPA will determine the application

in accordance with the considerations below. Each planning application is

assessed independently by each LPA, with each being entitled to reach its own

decision on the application in the usual way.

5. The majority of the application site would fall within the City of London, with the

northern 31-33 High Holborn site, providing the primary access to the bar and

secondary emergency access to the tunnels, falling within the LBC’s

administrative area. However, the Planning Applications Sub-Committee is

required to consider the application as a whole and not just those elements

which are within the City of London.

6. In considering this application the development plan comprises the City Local

Plan 2015, the London Plan 2021 and other policies which apply in the City as

referred to in this report. The emerging draft City Plan 2040 is currently in

consideration. CoL officers have been in continuous liaison with LBC officers

over the course of the application process, having shared the planning material

considerations of the development and the assessment taken by each LPA to

ensure any concerns or objections have been adequately addressed to the

satisfaction of both LPAs. The application submitted to the LBC is due to be

determined by its planning application committee on the 11

of July 2024.

7. If both authorities grant planning permission, each authority will grant

permission in so far as it relates to land in their respective administrative area.

Site and Surroundings

8. The application site is 0.9ha in size of which approximately 0.7ha is

subterranean and extends along two Local Planning Authorities, the City of

London Corporation (CoL) and the London Borough of Camden (LBC). The

underground element consists of a network of tunnels (formally named the

Kingsway Tunnels) that run underneath High Holborn and Holborn, parallel and

below the London Underground Central Line, and to the south below Staple Inn

Buildings and Took’s Court.

9. The Kingsway Tunnels were built in the early 1940s underneath Chancery Lane

tube station with the purpose of sheltering 10,000 people during WWII. The

original tunnels offered approximately 7,000 sqm of internal floor space

including two 5.1m diameter tunnels known historically as ‘North’ and ‘South’

‘Street’ that run parallel and below the Central Line beneath High Holborn.

While originally constructed and intended to be used as a deep-level shelter,

the tunnels were instead used by the British government as a secret

telecommunications centre, including use by the Special Operations Executive

(SOE). In 1949 the tunnels were given to the General Post Office (GPO). The

two-tunnel shelter was extended by the addition of four tunnels of 7.2m

diameter, known as the ‘Avenues’, at right-angles to the originals and a

perpendicular service avenue of the same diameter connecting to all four. The

additional tunnels were completed by 1954, and in 1956 it became the

termination point for the first transatlantic telephone cable - TAT1. From the

1960s until the early 1980s, Kingsway Trunk Switching Centre (as it became

known) was a trunk switching centre and repeater station with Post Office

engineering staff totalling over 200 at its peak. At that point, the tunnels were

closed following findings of large quantities of blue asbestos on the site. The

tunnels are currently not accessible by the public. British Telecom has a

maintenance team accessing the tunnels via Fulwood Place.

Figure 1. Tunnels network – light-blue portion in LB Camden, yellow

portion in City of London

10. The original public access to the shelters was from Chancery Lane tube station

and the historical entrance was located at 31-33 High Holborn. When the tube

station moved to its present location, the original connection to the tunnels was

blocked off, leaving only two access points at 38-39 Furnival Street (City) and

at Fulwood Place (Camden) which were not designed for public use.

11. Currently the tunnels include historic elements such as mechanical equipment,

a canteen, a games room, a bar, and other historic remains. Much of the historic

equipment, such as the telecommunications board, are stored elsewhere.

12. Above ground, the site comprises of three buildings. Two buildings are located

in the City of London boundary at No.38-39 and 40-41 Furnival Street and the

third is located in the London Borough of Camden at 31-33 High Holborn,

accessed via Fulwood Place.

13. The buildings at No.38-39 and 40-41 Furnival Street are located approximately

60m to the south of Holborn and they are bounded by Furnival Street to the

west, the building at 36-37 Furnival Street to the south, 1-6 Dyer’s Buildings to

the east and 14-18 Holborn to the north. They are also located in the Chancery

Lane Conservation Area which has a recognisable network of street from the

century, Southampton Buildings, Furnival Street, Cursitor Street, Took’s

Court and others. Within the north of the Conservation Area a great number of

narrow building plots survive as originally set out in the medieval period, such

as at 38-41 Furnival Street.

14. The building at 38-39 Furnival Street comprises of three storeys above ground

and forms the east entrance to the tunnels, which is currently closed. It is seen

to have a positive contribution to the conservation area as it offers a strikingly

industrial aesthetic to the street, contrasting with the refined architecture of

No.10 opposite. It combines concrete tiles at ground level and red brick at the

upper levels. The two sides of the building step away from the neighbouring

buildings creating a sense of a utilitarian brick block sitting on a concrete wall.

Another unique element of the building is the louvred large concrete ventilation

grille section in the middle of the brick ‘block’ on the front elevation. Internally

the building houses a goods shaft and ventilation ducts serving the eastern part

of the tunnels.

15. No.40-41 Furnival Street, is a late ‘90s six-storey office building including a

basement level. It is one of the tallest buildings on Furnival Street and has a

commercial appearance of its time. It has beige bricks at the ground levels, a

glazed section in the middle of the upper levels with red bricks at either side

and it gradually steps in at the uppermost levels. Contrary to No.38-39, the

character of No.40 is out of keeping with the prevailing architectural aesthetic

of Furnival Street due to its large bow front and is not deemed to be a positive

contributor to the conservation area.

16. Together Nos 38-39 and 40-41 offer an area of 1,423 sqm.

17. Furnival Street comprises a mix of residential and commercial occupiers. There

are residential premises near the site, with the closest being the adjoining 36-

37 Furnival Street (Aston House), 34-35 Furnival Street and the Dyer’s

Buildings to the east. The premises across the street and immediately to the

north of 40-41 Furnival Street are in commercial use.

18. Holborn is a prominent broad thoroughfare with a variety of uses and active

frontages at ground level. It has a mix of historic and contemporary building

stock with larger modern offices dominating parts of the street. Holborn serves

a dual carriageway with double lanes for cars and bus routes. It has wide

pavements and regular crossings, near the site, with a central island running

along the street hosting cycle and motorbikes parking at locations towards the

east side of the site. Bike lanes run along the edges of each carriageway

offering east and west connections. Holborn extends to High Towards the west

of Holborn is 31-33 High Holborn, the west entrance to the tunnels, comprising

an area of 364 sqm with a mix of office and residential uses on the upper levels.

19. Chancery Lane Underground Station, Farringdon Station and City Thameslink

are the nearest transport facilities to the site’s entrances. The nearest public

cycle parking spaces are located in High Holborn and Took’s Court.

20. The site is located in the Chancery Lane Conservation Area. No.38-39 Furnival

Street building, as an original part of Kingsway Tunnels, is considered to be a

non-designated heritage asset due to its rarity and historic interest. The

development site does not contain any statutory listed buildings. The nearest

listed buildings and scheduled monuments to the site are 32 & 33 Furnival

Street (Grade II listed), 10 Furnival Street and 25 Southampton Buildings (all

Grade II* listed), and Barnard's Inn Mercers' School Hall (Scheduled Ancient

Monument).

Relevant Planning History

21. This section is only relevant to the planning history of the part of the site located

in the City of London.

22. The building at 38-39 Furnival Street is one of the original assets of the

Kingsway Tunnels which was built in the 1950’s to ventilate the tunnels. There

is no planning history linked to this asset.

23. The existing building 40-41 Furnival Street was built by virtue of planning

permission 1205D granted on 2

December 1988 for the demolition of the

previous buildings at 40-41 Furnival Street and construction of a new office (B1)

building.

24. There is no additional relevant planning history to the site.

Proposal

25. Planning permission is sought for:

• The use of the Kingsway Tunnels as a visitor and cultural attraction (Use

Class F1(b)(c)), including a bar (Sui Generis);

• The demolition of 38-39 Furnival Street and reconstruction of the building

with four-storeys above ground and an outdoor amenity space to the roof

level;

• The demolition of 40-41 Furnival Street and erection of a five-storey building

with plant room to the roof level;

• Use of the new building at 38-41 Furnival Street as ancillary to the

tunnels/cultural attraction including a principal entrance at the ground floor,

hosting of MEP and plant equipment, ancillary retail (gift shops) and staff

accommodation;

• Creation of a secondary entrance at 31-33 High Holborn via Fulwood Place

(only relevant to London Borough of Camden);

• Provision of ancillary cycle parking, substation, servicing and plant; and

• Public Realm works on Furnival Street.

26. The following table provides the proposed GEA (Gross External Area) and GIA

(Gross Internal Area) figures split between the two Local Planning Authorities.

Approximately 71% of the site area created by the proposed development

belongs within the City’s authority boundary.

Table 1. Proposed GEA and GIA figures between CoL and LBC

GEA

GIA

Level

CoL

(GIA)

Camden

(GIA)

38-41 Furnival Street

3,020

2,467

Fulwood Place

386

329

Tunnel Network

9,828

7,829

5,111

2,718

TOTAL

13,234

10,625

7,578

3,047

27. The overall uplift in space would be 1,044sqm of GIA floorspace created by the

redevelopment works at Furnival Street. There is no other uplift in floorspace in

the tunnels or at the London Borough of Camden entrance.

Table 2. Schedule of Areas

Schedule of Areas

Building

sqm (GIA)

Existing

Proposed

Difference

38-39 Furnival Street (City of London)

194

942

+ 748

40-41 Furnival Street (City of London)

1,229

1,525

+ 296

31-33 High Holborn (Camden)

329

Tunnels Complex (City of London & Camden)

7,829

Total

9,581

10,625

+ 1,044

28. The uses of the proposed development would comprise:

Table 3. Breakdown of proposed areas floorspace

Use

Floorspace (GIA)

Bar (Sui Generis)

284 sqm

Visitor Attraction (F1)

includes tunnels (excl bar), above-ground areas,

and ancillary uses

10,341 sqm

Ancillary Office – Staff Office Space (F1)

58.2 sqm

Ancillary Retail – Gift Shop, Storage & Stair (F1)

227 sqm

Total Floorspace

10,625 sqm

Camden

3,047 sqm

City of London

7,578 sqm

29. The height of the proposed development would be 41.75m AOD at its highest

part. The demolition of the buildings at 38-41 Furnival Street is being proposed

instead of retention to allow an open excavation and enlargement of the existing

lift shaft at 38-39 Furnival Street. The new buildings would share the same

floorspace but their external appearance would indicate their individuality by

articulating two facades. 40-41 Furnival Street would maintain its commercial

aesthetic by featuring translucent glass bricks on the façade, whilst the brick

façade and concrete louvre at No.38-39 would be reused and/or replicated to

ensure the continuation of the building's historical character.

30. The ground floor elevation at 40-41 Furnival Street will be recessed to allow for

more external space and a sheltered area at the proposed principal entrance.

The ground floor of the combined building would provide step-free access to

the underground cultural spaces via a round lift shaft which follows the form of

the existing historic shaft at the same location. A reception check-in desk would

be located next to the entrance and an X-ray scanner would be placed in the

corridor that leads to the waiting lobby area to securely let people in the building.

31. The tunnels would be split into three different areas. These are described in the

following table and depicted in the plans below.

Table 4. Proposed areas in the tunnels

Heritage Exhibition (shared

between CoL and LBC – red

area) – Permanent exhibition

area focusing on the history

of the tunnels and the people

who occupied them.

Integrates a mix of immersive

experiences with the use of

technology and the exhibition

of historic remains.

Main exhibition area: ‘Streets’

the two longest horizontal

sections of the tunnels.

Cultural Exhibition (solely in

CoL – yellow area) –

Temporary exhibition area

using cutting-edge

technology that creates fully

immersive environments. To

be adaptive for multiple

cultural events.

Main exhibition area:

‘Avenues’ the three parallel

avenues that run in the

southern part of the tunnels.

Bar (solely in LBC – orange

area) – The deepest bar in

the UK. Accessed via

Fulwood Place.

The green area above the

bar has been marked as a

multifunction space which

could be used as an

Orientation/Classroom space

during school trips.

32. The Heritage Exhibition space makes up approximately 53% (1,965sqm of

3,713 sqm) of the total exhibition area (excluding front and back of house,

ancillary uses, toilets, lobbies), and the Cultural Exhibition space makes up

approximately 47% (1,748sqm of 3,713 sqm).

33. The Heritage and Cultural Exhibition spaces would be accessed via the new

Furnival building, whereas the secondary entrance via Fulwood Place forms the

main access point to the new deep-level bar. The exhibition spaces in the

tunnels have been designed to accommodate a peak occupancy of 750 visitors

at any given time which is only expected to occur 20 days (the busiest days) of

the year. The typical occupancy is estimated at 490 people per hour in the

tunnels (760pp/hr across the site) who are anticipated to spend one hour and

twenty minutes in the exhibition areas. The technical occupancy of the tunnels

(defined by evacuation, fresh air supply, and fire strategy) has been designed

to exceed the occupancy numbers.

34. At the first and second floor levels of the new Furnival building ancillary retail

space would be provided, to allow for a gift shop (on level one) and a gallery

(on level two mezzanine) in connection with the cultural experience as the last

part of the visitor’s journey. Level three would be used to house mechanical

equipment and would not be accessible to the members of the public. A staff

room would be provided at level four with access to a roof terrace, utilising the

roof of the new 38-39 Furnival Street building. The roof of the new 40-41

Furnival Street would be used as a plant room to host equipment that serves

the tunnels which requires natural ventilation. Most of the plant equipment

would be located above ground to facilitate its maintenance and accessibility.

Two separate lifts would be provided at the rear of the building, one to be used

by the members of the public leaving the gift shop area and the other for staff

and goods transfer across all levels. Evacuation lifts, dedicated Fire-Fighters

lifts, and evacuation stairs would be provided at each shaft (at both Camden

and City entrances).

35. There would be three basement levels mainly used as plant rooms, including

other facilities such as refuse storage and housing the new round lift shaft to

the south side. Visitors would be taken to basement level three from where they

enter the tunnels and begin their tour. The diagram below shows the visitor

route in the exhibition areas.

Figure 2. Diagram showing Visitor Heritage Trail & Exhibitions circulation routes

36. A total of 12 long-stay cycle parking has been proposed for the entire cultural

use to be split across the ground floor and basement level, including an

accessible space, accessed through the south side emergency exit. Visitor

cycle parking is proposed off-site. Sperate cycle parking is proposed in Fulwood

Place, Camden.

37. The proposed development would also provide public realm improvements to

mitigate the impact on the public highway from the increased traffic and provide

a safer welcoming pedestrian environment.

Consultations

Statement of Community Involvement

38. The Applicants have submitted a Statement of Community Involvement (SCI)

outlining their public engagement with stakeholders including: a traditional

public exhibition held in October 2023; a consultation website

(www.thelondontunnels.com); special preview events; 4,473 newsletters

posted to local addresses around the site including residents, businesses and

community groups; a social media campaign was held alongside a further

organic promotion to reach international coverage.

39. The public exhibition lasted for a calendar week and was held on Saturday 7

Tuesday 10

, Thursday 12

and Saturday 14

of October 2023 at St Albans

Centre, Leigh Place, Baldwin’s Gardens, London, EC1N 7AB. The exhibition

invited people to go to St. Alban’s Centre and see the detailed design proposals

in person and meet with the team. In total 119 members of the public attended

all six consultation events including key stakeholders and local residents.

40. A Ward Member Preview Event took place on Thursday 5 October 2023 and

the Local Neighbour Preview Event on Saturday 7 October 2023. A list of

stakeholders' names, their organisation and type/day of engagement is

provided in full in the SCI.

41. 222 surveys were completed from the online and in-person engagement of

which 99% were either positive or neutral about the proposal. The social media

and website consultation also generated 48 emails and phone calls which have

helped to inform the proposed development evolution.

42. The main areas of focus on consultation responses were accessibility, historic

value and preservation, art and culture, technology and construction impact.

The applicant sets out that consultees would like to see a highly accessible

development that is inclusive for everyone not only physically but also

financially, specifically ensuring the attraction remains open and accessible to

a wide group of people. The history of the site has intrigued many consultees

who would like to see it preserved and celebrated by retaining its authenticity

and heritage/cultural value. Proposals from consultees to use technology for

sustainability achievements were made that focus on climate change solutions

and renewable energy but also a way to educate people on that field. Concerns

were raised as to the increased footfall to the local area, causing disturbance

and how that would be managed and mitigated by the development. Similarly,

other concerns focused on the construction impacts affecting local traffic and

noise levels along Furnival Street.

Consultation and notification

43. Following receipt of the application, it has been advertised on site on 21

December 2023 and in the press on 9

January 2024. Residents near the two

entrances were included in consultations. On 10

January 2023, 140 letters

were sent to residential properties, in addition to the publicity carried out as set

out above. The relevant statutory consultees have been consulted following the

validation of the application.

44. Following consultation feedback, the applicant made some design and

highways amendments and updates on the accessibility and daylight sunlight

reports. These were received on the 2

April 2024. Accordingly, a 14-day re-

consultation has been undertaken. On 23

April 2024, re-consultation letters

were sent to the same residential properties to inform them on the minor

amendments to the scheme. Copies of all representations are appended in full

and appended to this report at Appendix A. A summary of the representations

received and the consultation responses is set out in the tables below.

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

responses. The applicant’s responses should be referenced as background

papers at Appendix A.

46. The views of other City of London departments have been taken into account

in the preparation of this report and some detailed matters are addressed by

the proposed conditions and the terms of the S106 agreement.

Statutory Consultation

47. A total of 12 statutory responses have been received which are summarised in

the following table.

Table 5. Statutory consultation responses

Consultee

Summary of comments

GLAAS

The comments make reference to the submitted

archaeological desk-based study submitted as part of the

current application. GLASS comments that remains of the late

Century were excavated on the southern half of the site

which may have removed any evidence for the earlier inn. All

archaeological remains have likely been removed from 40-41

Furnival Street.

In relation to excavation works at 38-39 Furnival Street, it is

likely that some archaeological potential remains and therefore

further archaeological work is recommended in advance of the

excavation of the new basement.

Despite limited works being proposed for the tunnels, GLAAS

notes that the tunnels are of high heritage interest and

recommends that historic building recording for the site is

carried out for them in advance of development. A condition

has been recommended along these lines.

In accordance with NPPF paragraph 205 the applicant should

record the significance of any heritage assets that the

development harms. Applicants should improve knowledge of

assets and make this public.

GLAAS advices that the development could cause harm to

archaeological remains and field evaluation is needed to

determine appropriate mitigation. It is considered a two-stage

archaeological condition comprising firstly of evaluation to

clarify the nature and extent of surviving remains and followed,

if necessary, by a full investigation.

Officer response: The matter is addressed in the Archaeology

section of the report.

Historic England

(Inspector of

Ancient

Monuments)

HE has commented on designated heritage assets only. It has

been noted that the development site sits close to the

scheduled monument of Barnards Inn. The proposed

development does not physically affect the Inn. However,

Barnards Inn is encapsulated within a mass of more recent

buildings, experiencing overshadowing. The proposed

development would not compromise the setting of the Inn any

further, although HE notes that care should be taken to ensure

access to it remains easily navigated and signage is not

impacted. As long as the application would not materially

change, HE would not need to be re-consulted.

Officer response: The proposed buildings' height and mass

remained the same over the course of the application.

Therefore, HE has not been re-consulted.

TfL

(Infrastructure

Protection)

TfL (Infrastructure Protection) has no objection to the proposed

development in principle. The consultee has however set out

a number of potential constraints linked to the proximity of the

development site with London Underground railway

infrastructure. A set of conditions have been recommended

that require consultation with TfL Infrastructure Protection

through submission and approval by the LPA.

Officer response: Conditions are recommended.

TfL (Spatial

Planning)

Pedestrian Comfort

TfL (Spatial Planning) deems the pedestrian comfort levels

submitted acceptable.

PT Impact

TfL suggests that wayfinding measures in the station would

help people exiting the station more easily will help offset this

impact (and improve their experience of the venue), as would

wayfinding on the street to help people find the destination,

and on return raise awareness of proximity to other

destinations and public transport, improving their experience.

Cycle Parking

TfL advises that further work should be carried out to improve

the long-stay cycle parking design and access.

Car Parking

Subject to both LPA’s deeming the location and operation of

the blue-badge bay being acceptable, TfL consider this

appropriate. However, the applicant is encouraged to identify

blue badge locations on the Camden access point.

Taxi and Coach Access

TfL requests for more clarity on how or if taxi’s/ private hire

vehicles would be restricted from accessing Furnival Street.

They request a more robust coach management plan is

provided. The TfL Coach team have highlighted that a current

plan could lead to illegal parking on street which in turn would

impact safety and operation of Holborn. It has been suggested

that coaches could use Bedford Row as an official parking bay

or consider the provision of a bay on northbound element of

Kingsway. Further discussion on this element should be

provided and the relevant review mechanisms in the travel

plan and operational strategy should be put in place to allow

amendments where deemed necessary.

Delivery and Servicing

TfL have concerns over the feasible operation of the Delivery

and Servicing Plan particularly on Furnival Street and

clarification is sought on how this will be managed. The final

DSP should be secured by condition and should also consider

when the needs of the occupier may change for special events

etc.

Construction Logistics

TfL acknowledge the Outline Construction Logistics Plan, but

has serious concerns over the proposed management,

operation and feasibility of carrying out this plan. This should

have the earliest engagement in order to provide

suitable mitigation as this may impact pedestrian, bus

operations and London Underground Infrastructure. TfL

recommends that the access proposal is supported by a road

safety audit, also that for pedestrian and cycle routing during

construction, these should subject to detail assessment in

accord with Construction Logistics and Community Safety

standard and appropriate pedestrian comfort levels. The final

Construction Logistics Plan should be provided in accordance

with TfL guidance and discharged in consultation with TfL.

Wayfinding

A Wayfinding Strategy is recommended to be secured by

condition. This should include updates to wider Legible

London Signage and the provision of additional signage where

appropriate on street and potentially within LU Stations.

Travel Plan

TfL welcome the provision of the revised travel plan which

includes a range of soft and hard measures. Suggested

additional measures which may form part of their travel plan

could be the provision of a wayfinding strategy which would

encourage people to walk from key transport nodes and to

reduce pedestrian congestion in key locations. Another

measure which could be included as part of the plan and/or

upon review of the plans, could be to incorporate Santander

Cycle Hire with tickets. TfL offer innovative ways to work with

business to provide sustainable transport options such as this.

Given the site is well served via cycle hire and cycling

infrastructure, this could be a suitable option.

Operational Management Strategy

TfL advises that the applicant should provide an operational

management plan which should be secured via condition. This

should provide sufficient mechanisms and proposals which

can be adapted once the venue is operational.

Dockless Bikes

TfL request the City of London and the LB of Camden work

with the dockless bike providers to provide a no parking zone

surrounding the access locations. Whilst this is not within the

control of the future occupier, the reason behind this request

is due to the constraint nature of the access points and

potential implications of the bikes being in these inconvenient

locations.

Cycle Hire

On this occasion TfL are not requesting a cycle hire

contributions given the expect impact of the development will

be outside of peak hours when the system experiences most

pressure. However, measures mentioned above via the Travel

Plan should be secured appropriately.

Officers response: The comments are taken into

consideration – the Transport and Highways section of this

report addresses the above matters. Conditions have been

recommended.

Thames Water

Thames Water has raised no objections and has requested

conditions to be included to require a piling method statement.

Thames Water advises that any significant work near their

sewers must minimize the risk of damage. Works should be

guided in accordance with the Thames Water ‘guide working

near or diverting our pipes’.

As required by Building regulations part H paragraph 2.36,

Thames Water requests that the Applicant should incorporate

within their proposal, protection to the property to prevent

sewage flooding, by installing a positive pumped device (or

equivalent reflecting technological advances), on the

assumption that the sewerage network may surcharge to

ground level during storm conditions.

If as part of the basement development there is a proposal to

discharge ground water to the public network, this would

require a Groundwater Risk Management Permit from Thames

Water. Any discharge made without a permit is deemed illegal

and may result in prosecution under the provisions of the

Water Industry Act 1991. They would expect the developer to

demonstrate what measures will be undertaken to minimise

groundwater discharges into the public sewer. Permit

enquiries should be directed to Thames Water’s Risk

Management Team by telephoning 02035779483 or by

emailing [email protected] .

With regard to the COMBINED WASTE WATER network

infrastructure capacity, Thames Water would have no

objection based on the information provided.

Thames Water would expect the developer to demonstrate

what measures will be undertaken to minimise groundwater

discharges into the public sewer. Groundwater discharges

typically result from construction site dewatering, deep

excavations, basement infiltration, borehole installation,

testing and site remediation. Any discharge made without a

permit is deemed illegal and may result in prosecution under

the provisions of the Water Industry Act 1991. They have

requested an informative to be included to advise on the

requirement for a Groundwater Risk Management Permit from

Thames Water for discharging groundwater into a public

sewer. Any discharge made without a permit is deemed illegal

and may result in prosecution under the provisions of the

Water Industry Act 1991. They would expect the developer to

demonstrate what measures he will undertake to minimise

groundwater discharges into the public sewer. Permit

enquiries should be directed to Thames Water’s Risk

Management Team by telephoning 020 3577 9483 or by

emailing [email protected].

Thames Water would advise that with regard to water network

infrastructure capacity, they would not have any objection to

the above planning application and have requested to include

an informative to advise that Thames Water will aim to provide

customers with a minimum pressure of 10m head (approx 1

bar) and a flow rate of 9 litres/minute at the point where it

leaves Thames Waters pipes. The developer should take

account of this minimum pressure in the design of the

proposed development.

The proposed development is located within 5m of a strategic

water main. Thames Water do NOT permit the building over or

construction within 5m, of strategic water mains and have

requested to include a condition for ‘no construction shall take

place within 5m of the water main.’ The condition requests

details of how the developer intends to divert the asset / align

the development, so as to prevent the potential for damage to

subsurface potable water infrastructure, to be submitted to the

Local Planning Authority in consultation with Thames Water.

Thames Water advises works have the potential to impact on

local underground water utility infrastructure. They would like

the developer to read their guide ‘working near our assets’ to

ensure the works will be in line with the necessary processes

the development needs to follow if considering working above

or near Thames Water pipes or other structures.

There are water mains crossing or close to the development.

Thames Water do NOT permit the building over or construction

within 3m of water mains. If the developer is planning

significant works near Thames Water mains (within 3m),

Thames Water will need to check that the development doesn’t

reduce capacity, limit repair or maintenance activities during

and after construction, or inhibit the services they provide in

any other way. The applicant is advised to read Thames Water

‘guide working near or diverting our pipes.’

Thames Water has requested an informative to be included to

advise that Thames Water will aim to provide customers with

a minimum pressure of 10m head (approx 1 bar) and a flow

rate of 9 litres/minute at the point where it leaves Thames

Waters pipes. The developer should take account of this

minimum pressure in the design of the proposed development.

Officers response: Conditions and informatives are

recommended.

Environmental

Agency

No comments – Environmental Agency has advised that the

planning application is consulted upon with the Local

Authority’s Environmental Health department.

Officer response: City of London Environmental Health team

have been consulted on the proposed development.

Health &

Wellbeing Policy

No comments to date.

Development

Manager

Lead Local Flood

Authority

Conditions are recommended requiring further details of SuDs

system and flood prevention measures.

Officer response: Conditions are recommended.

Counter-

Terrorism

Security Advisor

(CTSA)

CTSA has visited the site and read through the submitted

Security Report. Separate advice has been provided to the

applicant that does not require any planning conditions to be

imposed, however, the applicant is advised to consult CTSA

as the plans evolve. Details of the security measures for the

site are confidential, and not available in the public domain.

Officer response: An informative has been added.

City of London

Police (Design

Out Crime

Officer)

City of London officers have been consulted and commented

on their requirements for the external security of the venue and

recommended alternative options/standards that would be of

their satisfaction if adopted at the more detailed design stage.

A comment was made about the constraint nature of the

existing lifts at Fulwood Place for emergency services access.

It has been clarified that the proposal seeks to enlarge the

existing lifts increasing the capacity of people by 3 times which

has been deemed acceptable at this stage. A point was made

about the ability to close the tunnel system to afterhours

drinkers in reference to the proposed bar in Camden. The

agents have responded that the area outside of the bar will be

physically locked off to prevent bar patrons getting access to

any area outside of the bar space. CoL Police Officer has

found this approach acceptable. They have noted that subject

to any matters that the CTSA’s may raise, they are satisfied

with the response and the fact that other issues can be

resolved at the detailed design stage.

Officer response: An informative has been added to consult

CoL Police at detailed design stage.

Conservation

Area Advisory

Committee

(CAAC)

Officers presented the proposed scheme to the CAAC on the

of February 2024. No objections were raised with a formal

non-objection letter submitted to the application on 1

of March

2024.

London Fire

Brigade

General fire safety design approach and consultation with key

stakeholders

London Fire Brigade (LFB) understands that it is proposed that

the methodology outlined in BS 7974:2019 will be applied and

they support this approach. As part of this methodology, LFB

advises that a Qualitative Design Review (QDR) process

should be undertaken and LFB would expect to be involved in

this process as a key stakeholder, both in their capacity as an

emergency response agency for fires and other emergencies

but also as the future enforcing authority for The Order.

However, they emphasise that it cannot be assumed that

following any particular methodology, in and of itself,

automatically leads to acceptable solutions or outcomes. The

detail of any risks identified, and decisions made, may need

revision throughout the design and construction phases as

previously unknown circumstances arise, and may not be

easily or suitably resolved.

LFB advise that caution is taken if applying the

recommendations of BS 9992 to tunnels that do not form part

of railway infrastructure, whilst some of the recommendations

of the code of practice may be applicable, the assumptions

made for sub-surface railway infrastructure in particular are

quite different than those for other types of purpose

group/occupancy. LFB expects – subject to the outcome of the

performance-based design process and associated

stakeholder engagement – that suitable smoke

ventilation/control systems will be provided, in conjunction with

suitable and compatible automatic fire suppression systems.

Critical fire safety design issues that LFB would expect to be

addressed as the design is developed

LFB wish to highlight a number of fire safety design issues that

we would expect to be addressed as the fire safety design

process progresses. This is not intended to be exhaustive.

- Extended travel distances for occupant means of

escape and firefighter access/intervention;

- Inclusive design and means of escape for persons with

relevant protected characteristics;

- Radio communications coverage for firefighters and

other emergency responders;

- Electric Powered Personal Vehicles;

- Construction phase fire safety.

LFB informs that it is not possible to advise if London Plan

Policies D12 and D5 can be considered to have been met

without assurances being sought that the design will progress

in consultation with LFB and other emergency services.

Officer response: Noted – these comments are addressed in

the Fire Statement section of the report.

British

Telecommunicati

ons

No comments to date.

City of

Westminster

No objection.

London Borough

of Camden

Duplicate planning applications have been submitted to the

City of London and LB of Camden for the proposed

development. LB of Camden has made no comments

regarding the proposed works taking place within the City of

London, however, their Committee Report recommendations

form material considerations in the report’s assessment.

Letters of Representation

Support

48. A total of 57 letters of support from the public have been received over the

course of the planning application. Among them, there were two Business

Improvement Districts, local residents and business owners, as well as people

from around London, Britain and the globe. The topics of support for the

proposed development have been summarised as follows:

• Embracing and preserving the history of the Kingsway Tunnels;

• Educational Opportunities providing visitors of all ages with opportunities

to learn and engage through interactive exhibits, guided tours and

educational workshops.

• Public-private partnerships, collaboration between public agencies,

private investors and community organisations;

• Cultural Enrichment;

• Seven-day destination in line with City’s destination vision;

• Revitalise/Boost the local economy with positive effect to businesses

and communities;

• Facilitates post-pandemic recovery of the local area;

• Increase tourism;

• Potential to bring growth in the area;

• Creation of new jobs;

• Repurposing of existing redundant infrastructure;

• Provision of accessible spaces;

• Design and Sympathetic to its surroundings;

• Provision of innovative and attractive environments;

• Creation of a benchmark development;

• Help London to continue being perceived as a world-class city and adds

to its competitiveness.

Central District Alliance

49. Officers received an email from the Central District Alliance (CDA), Business

Improvement District comprising of Holborn, Clerkenwell, Farringdon,

Bloomsbury, and St Gile, which informed they have submitted comments and

a letter of support to Camden Council on the parts of the development which

impact their footprint. CDA is supporting the proposed development coming

forward, which consequently includes City’s application, and the wider

economic benefits it brings ‘rejuvenation of local business, increased tourism,

and educational engagement, projecting an economic uplift of £60-£80 million

annually for the area’. The letter of support refers to the proposed development

as ‘a significant opportunity for economic, cultural, and historical enrichment in

our community’ and urges the LPA to recognise the ‘transformative potential’ of

the development to bring ‘lasting benefits to their district, fostering a vibrant,

culturally rich, and economically robust economy’.

50. CDA’s email states: “The area of Holborn is well placed to guide visitors to and

from main transport hubs located on the tri-borough boundary and to cater for

footfall to and from the attraction. We are dedicated to see economic growth in

this particular part of central London and welcome this as a new cultural venue

in the area.”

Fleet Street Quarter

51. A comment was made by a representative of Fleet Street Quarter (FSQ), a BID

with footprint in the western part of the City of London. FSQ recognises the

need for a visitor attraction at this part of the City to create a destination to a

part of London that has been suffering due to lack of competitive offer compared

to other more prestigious attractions in London such as St Paul’s Cathedral and

Covent Garden. FSQ considers that the proposed cultural scheme would

complement and support the needs of workers and along with the Museum of

London they would ‘put the area on the map’. The anticipated number of visitors

is welcomed by FSQ as it would strengthen the retail offer along Holborn and

support other retail businesses in the area and boost the weekend economy to

a much needed business district.

Objections

52. A total of 24 objections have been received over the course of the planning

application including a letter of representation prepared by Daniel Watney

consultants, on behalf of the neighbouring commercial occupiers at 10 Furnival

Street (Chancery Exchange), comprising of transport (by Haskoning DHV) and

daylight and sunlight (by Joel Michaels Reynolds) comments about the

submitted information. Officers have fully reviewed all the objections and

selected key themes as summarised below. Some comments are referenced in

full where necessary.

Table 6. List of objections and officer responses

Issues

Number of

objections

relating to

this issue

Officer responses

including paragraph of

report where issues are

addressed

Noise linked to demolition,

construction of the proposed

development (detrimental to

residential and others amenity)

Impact on the amenity

Transport and Highways

Noise/Disturbance linked to

operation of the proposed

development (detrimental to

residential and others amenity) -

main sources: increased footfall,

external queuing, anti-social

behaviours, operational

traffic/servicing, hours of operation

Impact on the amenity

Transport and Highways

Litter and dirt in the local area caused

by increased footfall

Conditions have been

recommended for the

operational management of

the development.

Noise linked to late evening activities

and/or bar (detrimental to residential

and others amenity)

Impact on the amenity

Vibration

Impact on the amenity

34-35 Furnival Street have flats

extend under the private area of the

pavement with vulnerable pavement

lights

This comment is not clear.

The proposed development

shares no boundaries with

No.34-35, flats on this

address will be protected from

works.

Incompatible with area’s Character

(residential/pedestrian character and

Conservation Area)

Principle of cultural use

Transport and Highways

Accessibility

Design and Heritage

Design/Visual Appearance &

Heritage (negative impact on the

conservation area and settings of

historical buildings)

Design and Heritage

Increased traffic and congestion

generated by the proposed

development. Chancery Lane and

Transport and Highways

Holborn are characterised as already

congested areas.

Delivery/Servicing and parking,

including taxi drop-offs, would be of

high demand when the proposed

development comes to operation

which would impact traffic flow as

cars would park outside the premises

with long delays blocking the whole

width of the street and causing stress

to local network.

Transport and Highways

No provision for vehicle access by

residents and businesses is apparent

in the proposal. Loss of vehicle

access would be a hardship and

detrimental for residents and

businesses who rely on service

deliveries and building maintenance

services.

Transport and Highways

Damages to the (conservation) local

area mainly due to construction

works

Transport and Highways

Loss of existing cycle lane

Transport and Highways

Blue Badge space would be lost with

no additional spaces proposed

Transport and Highways

No on-site visitor cycle parking –

proposed location at High Holborn

central reserve would increase the

barrier to pedestrian movement

across the street.

Transport and Highways

Physical incapacity of Furnival St to

accommodate development

Transport and Highways

Accessibility

Impact of the proposed kerb build out

along the site frontage to the

surrounding area.

Transport and Highways

Human Safety - issues are

connected with the proposed

evacuation strategy, queuing on the

streets and servicing vehicles at the

same time along Furnival Street; and

asbestos airborne particles

Transport and Highways

Accessibility

Proposed contamination

conditions

Emergency services access

Transport and Highways

Accessibility

Security and terrorism

Security and Statutory

Consultation

Structural damage to adjoining

properties

Party Wall Agreements do not

fall under the legislative

framework relevant to the

assessment of planning

applications. Nevertheless,

Structural Assessments have

been submitted that address

the issue.

Daylight Sunlight impact on opposite

commercial building at 10 Furnival

Street (Chancery Exchange).

Daylight and Sunlight

Light Pollution

Air Quality

Drainage and Ventilation

Sustainability

Precedent with respect to land use

Any future planning

application would be

assessed on its own merits

and against the most up-to-

date national, London and

local plan policies.

Principle of Development: Land Use

(loss of office and provision of

conflicting uses to the local context)

Principle of development

Principle of Development: Bar

The proposed bar is located

in LB Camden and will be

accessed only via the

secondary entrance in High

Holborn. The relevant Local

Planning Authority would be

assessing the principle of the

bar use against their own

policies, however, pubic

concerns would be shared

with LB Camden officers.

Fire Safety (risk of explosion in

pressurised areas)

Fire Statement

Waste Management (provision for

further disposal; plans do not show

access and refuse collection from

below ground levels)

Waste Management

The development needs to be

balanced against the interests of

local residents and the preservation

of the conservation area

Heritage and Design

Human Rights Act 1998

The Public Sector Equality

Duty (section 149 of the

Equality Act 2010)

32 & 33 Furnival Street have listed

cellars that run under the road and

pavement areas along Furnival

Street which could be damaged

It is acknowledge there are

listed basements to 32 and

33. Officers would expect

localised vaults under the

pavement and road but would

not expect these to extend

beyond the immediate

context and significantly

along Furnival Street. Please

also refer to Archaeology

section and relevant

conditions.

The proposal fails to convince that

the area would benefit from such

tourist attraction

Cultural Use and Cultural

Strategy

The development would have a

negative impact on the local

economy and would be detrimental

to the social fabric of the community.

Cultural Use and Cultural

Strategy

Not preserving the historic

environment/tunnels

Please refer to the Proposal,

Cultural Use and Cultural

Strategy. The proposed

development seeks to

preserve the heritage

element and make it

accessible.

Impact on keeping or finding new

tenants

Not a material planning

consideration.

Compliance with planning policies

Please refer to the

assessment part of the report

and the Conclusions. Officers

have assessed the

application against the

adopted and emerging

development plan policies.

53. It is noted that all material planning considerations raised in the representations

above are addressed within this report.

Neutral

54. Three neutral comments have been received including one from a local

businessman who supports the application and requests mitigation measures

to be considered in relation to construction traffic, increase number of visitors

leading to demand for parking and the preservation of the historic features in

the tunnels. The second neutral comment requests to know more about the

expected noise levels of the concrete acoustic louvre. In both cases, relevant

assessment has been undertaken and conditions have been recommended for

further details and mitigation measures when deemed appropriate.

Policy Context

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

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

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

report.

56. The City of London (CoL) has prepared a draft plan, the City Plan 2036, which

was published for Regulation 19 consultation in early 2021. The City does not

intend to proceed with this plan and therefore it is of very limited weight and will

not be referred to in this report. The draft City Plan 2040 was published for

Regulation 19 consultation in April 2024 which is expected to end on 17

June

2024. It is anticipated that the draft City Plan 2040 will be submitted to the

Secretary of State in Autumn 2024. Emerging policies are considered to be a

material consideration with limited weight with an increasing degree of weight

as the City Plan progresses towards adoption, in accordance with paragraph

48 of the NPPF. The draft City Plan 2040 policies that are most relevant to the

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

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

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

amended from time to time.

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

“Planning Law requires that applications for planning permission must be

determined in accordance with the development plan unless material

considerations indicate otherwise”.

National Planning Policy Framework (NPPF)

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

three overarching objectives, being economic, social and environmental.

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

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

at paragraph 11. For decision-taking this means:

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

development plan without delay; or

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

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

permission unless:

• the application of policies in this Framework that protect areas or assets

of particular importance provides a clear reason for refusing the

development proposed; or

• any adverse impacts of doing so would significantly and demonstrably

outweigh the benefits, when assessed against the policies in this

Framework taken as a whole.

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

policies in emerging plans according to:

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

preparation the greater the weight that may be given);

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

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

be given) and

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

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

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

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

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

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

accessible and enable and support healthy lifestyles.

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

recreational and cultural facilities and services the community needs.

65. Paragraph 101 states that planning decisions should promote public safety and

should take into account wider security and defence requirements by:

a) anticipating and addressing possible malicious threats and natural hazards,

especially in locations where large numbers of people are expected to

congregate… and the layout and design of developments, should be

informed by the most up-to-date information available from the police and

other agencies about the nature of potential threats and their implications.

This includes appropriate and proportionate steps that can be taken to

reduce vulnerability, increase resilience and ensure public safety and

security; and

b) recognising and supporting development required for operational defence

and security purposes, and ensuring that operational sites are not affected

adversely by the impact of other development proposed in the area.”

66. Chapter 9 of the NPPF seeks to promote sustainable transport. Paragraph 105

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

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

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

emissions and improve air quality and public health”.

67. Paragraph 116 states that applications for development should give priority first

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

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

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

that are safe, secure and attractive and which minimise the scope for conflicts

between pedestrians, cyclists and vehicles; it should allow for the efficient

delivery of goods and access by service and emergency vehicles.

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

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

application should be supported by a transport statement or transport

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

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

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

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

and improving the environment and ensuring safe and healthy living

conditions.”

70. Chapter 12 of the NPPF seeks to achieve well designed places. Paragraph 126

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

and places is fundamental to what the planning and development process

should achieve. Good design is a key aspect of sustainable development,

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

acceptable to communities.”

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

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

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

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

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

surrounding built environment and landscape setting, while not preventing or

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

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

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

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

accommodate and sustain an appropriate amount and mix of development

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

inclusive and accessible and which promote health and wellbeing.

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

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

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

overall form and layout of their surroundings.

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

Paragraph 157 states that the planning system should support the transition to

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

ways that contribute to radical reductions in greenhouse gas emissions,

minimise vulnerability and improve resilience; encourage the reuse of existing

resources, including conversion of existing buildings.

74. Paragraph 159 states that new developments should avoid increased

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

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

taken to ensure that risks can be managed through suitable adaptation

measures.

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

environment. Paragraph 201 of the NPPF advises that Local Planning

Authorities should identify and assess the particular significance of any heritage

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

the setting of a heritage asset) taking account of the available evidence and

any necessary expertise. They should take this into account when considering

the impact of a proposal on a heritage asset, to avoid or minimise any conflict

between the heritage asset’s conservation and any aspect of the proposal.

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

planning authorities should take account of:

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

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

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

sustainable communities including their economic vitality; and c) the

desirability of new development making a positive contribution to local

character and distinctiveness.”

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

proposed development on the significance of a designated heritage asset, great

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

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

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

harm to its significance.”

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

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

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

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

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

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

determining the application. In weighing applications that directly or indirectly

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

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

heritage asset”.

80. Paragraph 212 of the NPPF states “Local planning authorities should look for

opportunities for new development within Conservation Areas and World

Heritage Sites, and within the setting of heritage assets, to enhance or better

reveal their significance. Proposals that preserve those elements of the setting

that make a positive contribution to the asset (or which better reveal its

significance) should be treated favourably.”

Statutory Duties

81. The Corporation, in determining the planning application has the following main

statutory duties to perform:

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

to the application, to local finance considerations, and to any other material

considerations. (Section 70 Town & Country Planning Act 1990);

• To determine the application in accordance with the development plan

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

the Planning and Compulsory Purchase Act 2004).

Main Considerations

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

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

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

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

Conservation Areas) Act 1990).

83. Account has to be taken of the documents accompanying the application, the

further information, any other information and consultation responses, the

development plan, and other material considerations including SPGs, SPDs

and emerging policy.

84. The principal issues in considering this application are:

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

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

b) The principle of development and proposed uses.

c) The loss of office floorspace.

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

residential and other occupiers.

e) The impact of the proposal on public safety and security in the City.

f) The economic impact of the proposal.

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

conservation area and the design of the building itself.

h) The impact of the development on designated and non-designated heritage

assets.

i) The impact of the development on public realm.

j) The impact of the development on ecology.

k) The accessibility and inclusivity of the development.

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

beneath the site.

m) The impact of the development on highway and transportation terms.

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

change.

o) The impact of the development on air quality.

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

q) The impact of the development on fire safety.

r) The impact of the development on flood risk.

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

Act 2010).

t) The Human Rights Act 1998.

u) The requirement of financial contributions and other planning obligations.

Principle of Development

85. The NPPF places significant weight on ensuring that the planning system

supports sustainable economic growth, creating jobs and prosperity.

86. Paragraph 96 of the NPPF states that planning decisions should aim to achieve

healthy, inclusive and safe places and provide social, recreational and cultural

facilities and services the community needs.

87. The Local Plan Core Strategic Policy states that when considering development

proposals, the City Corporation will take a positive approach that reflects the

presumption in favour of sustainable development contained in the NPPF. It will

always work proactively with applicants jointly to find solutions which mean that

proposals can be approved wherever possible, and to secure development that

improves the economic, social and environmental conditions in the area.

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

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

connected by existing or planned public transport; proactively explore the

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

workspaces, promoting higher density development, particularly in locations

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

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

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

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

making, strengthening London’s distinct and varied character.

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

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

economic competitiveness and ensure that economic success is shared

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

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

employment and industrial space in the right locations to support economic

development and regeneration; promote and support London’s rich heritage

and cultural assets, and its role as a 24-hour city; and makes the fullest use of

London’s existing and future public transport, walking and cycling network, as

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

activity.

90. London Plan Policy SD4 outlines that within the Central Activity Zones (CAZ) a

mix of strategic functions and local uses should be promoted and enhanced.

Cultural, arts, entertainment, night-time economy and tourism functions are

some of these functions.

91. London Plan Policy D3 states that a site’s capacity is optimised by a design-led

approach that requires going through an optioneering process of the most

appropriate form of development for the site considering its context and

capacity for growth including its infrastructure capacity form and layout,

experience and quality and character. Higher-density developments should be

located in areas with well-connected jobs, services, infrastructure and

public/sustainable transport.

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

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

Policy CS1 aims to increase the City’s office floorspace by 1,150,000sq.m gross

during the period 2011-2026, to provide for an expected growth in workforce of

55,000. The Local Plan, policy DM1.2 further encourages the provision of large

office schemes, while DM1.3 encourages the provision of space suitable for

SMEs.

93. Strategic Objective 3 in the City of London Local Plan 2015 is to promote a

high-quality heritage environment with supporting and continued development

of the City as a cultural destination. The Local Plan envisions the continuity of

cultural and leisure destinations in the City for workers, residents and visitors

with equal opportunities, accessibility and involvement for everyone.

94. Strategic Objective 5 in the City of London Local Plan 2015 is to ensure the

provision of inclusive facilities and services that meet the high expectations of

the City’s business, resident, student and visitor communities, aiming for

continuous improvement in the City’s rating in satisfaction and quality of life

surveys. The Local Plan seeks to ensure high quality training and learning

opportunities are accessible to all. City and City fringe residents will develop

the skills needed to enter careers in the City and benefit from the City’s

prosperity.

95. The Strategic Priorities of the emerging City Plan 2040 sets out that the City

Corporation will facilitate significant growth in office development of the highest

quality to meet project economic and employment growth and protecting

existing office floorspace to maintain the City’s role as a world leading financial

and professional services centre and to sustain the City’s strategically important

cluster of commercial activities within the Central Activities Zone; broadening

the City’s appeal by ensuring new office developments deliver flexible, healthy

working environments and meet the needs of different types of businesses

including Small and Medium Enterprises, supporting specialist clusters such as

legal and creative industries and promoting a range of complementary uses;

creating a more vibrant and diverse retail economy; balancing growth with the

protection and enhancement of the City’s unique heritage assets and open

spaces and creating an inclusive, healthier and safer City for everyone.

96. The Strategic priorities of the emerging City Plan 2040 also focus on

maintaining and enhancing the City’s cultural, leisure and recreational offer,

visitor experiences and infrastructure and the City’s evening and weekend

economies to position the Square Mile as a key cultural and leisure destination.

To do so the emerging policies seek to encourage cultural placemaking and

creation of inclusive places contributing to residents, workers and visitors'

experiences; develop cultural, leisure and recreation facilities that offer unique

experiences across the City and during the whole day and week; protect and

enhance existing areas of cultural significance; provide accessible and

inclusive infrastructure and facilities that complement the cultural uses; place

heritage ay the heart of cultural placemaking and create cultural offer that

celebrates the City’s rich history; and encourage public realm improvements to

accommodate cultural events.

97. The above aims are reflected in the ‘Destination City’ vision for the future of the

Square Mile as a world-leading destination for workers, visitors and residents.

This initiative aims to create fun, inclusive and innovative spaces and places

that attract people and investment to the City.

Loss of Office Floor Space

98. The proposed development seeks to repurpose the existing historic tunnels

(formerly known as the Kingsway Tunnels) with the main focus being the

provision of a large subterranean heritage exhibition space that would curate

the history of the tunnels. The re-use of the tunnels coupled with high-end

technology is proposed to provide a unique learning experience for the visitors

along with the display of historic findings in a highly interactive environment.

99. A flexible exhibition space would also be provided in the tunnels with a

temporary nature for various exhibitions to take place independently of the

historic exhibition area, as well as the proposed repurposing of the historic bar.

100. As the main cultural spaces would be situated below ground. The development

requires the formation of a ground level entrance that would be appropriate for

this unique cultural use. There are currently two existing entry points to the

tunnels. On Furnival Street (located within the City of London) the building at

number 38-39 forms part of the historic tunnels, it offers 194sqm floorspace and

currently houses a goods shaft that leads to the eastern part of the tunnels,

forming one of the existing access points. A secondary existing access shaft to

the tunnels is situated at 31-33 High Holborn (London Borough of Camden).

This is located beneath residential and commercial accommodation and is

accessed via a narrow alley. The latter access point has very limited flexibility

given the constrained nature of the building/access and is therefore proposed

to work as the secondary entrance to the tunnels development. Therefore, the

principal visitor entrance is proposed to be located on Furnival Street.

101. The tunnels complex that runs along the City and Camden boundaries

measures approximately 7,829 sqm in floorspace which would be restored and

preserved. The proposed submission estimates that the cultural use would

attract approximately two million visitors annually, with a maximum capacity of

750 people being in the tunnels at any hour of a peak day. Because of the

capacity of visitors, the tunnels could accommodate, the building at 38-39

Furnival Street would not currently be able to provide a sufficient floor area for

the required ground floor facilities (reception, lobby, toilets, etc) and for the

provision of a highly accessible ground floor entrance on its own due to the

constricted space. The proposal therefore includes the adjacent building, 40-41

Furnival Street, into the development in order to create larger floorplates and

create the required primary access to the tunnels.

102. The following figure shows the existing ground floor layout of the two buildings

to demonstrate the limitation in floor space at 38-39 Furnival Street and the

additional floor area to be embedded from the inclusion of the adjacent building

into the proposal.

Figure 3. Existing Ground Floor Layout Plans

(40-41 Furnival Street left, 38-39 Furnival Street right)

103. No.40-41 Furnival Street forms a late 90s office building of higher scale than

the other buildings on the street and is currently occupied. It offers 1,229 sqm

(GIA) of office space and ancillary floorspace arranged over the basement,

ground and 6 upper floors.

104. The proposed development seeks to demolish the buildings at both 38-39 and

40-41 Furnival Street and redevelop a building with a combined layout. The

new conjoined building would provide ancillary uses (such as staff

accommodation and gift shop) and form the principal entrance to the proposed

cultural attraction to take place in the existing tunnels. This application would

therefore result in the loss of 1,229sqm (GIA) of existing Class E(c) office

floorspace.

105. London Plan Policy E1 supports the increase in current office stocks especially

within the central London office market. The City of London Local Plan 2015

and the Emerging City Plan 2040 promote the delivery of a world class business

city and the protection and provision of office floorspace. Local Plan policies

CS1 and DM1.1 and Emerging City Plan 2040 policies S4 and OF2 seek to

protect existing office accommodation.

106. Local Plan Strategic Policy CS1 and Policy DM 1.1, require applications for loss

of office accommodation to other uses be refused where the site is suitable for

long-term viable office use and there are strong economic reasons why the loss

would be inappropriate. Inappropriate losses are measured by any the following

reasons:

• prejudicing the primary business function of the City;

• jeopardising the future assembly and delivery of large office development

sites;

• removing existing stock for which there is demand in the office market or

long

• term viable need;

• introducing uses that adversely affect the existing beneficial mix of

commercial uses.

107. The supporting text (paragraph 3.1.8) to Local Plan Policy DM1.1 and the Office

Use SPD indicates that proposals for the change from offices will normally be

refused if the building or site is considered suitable for long-term viable office

use. Paragraph 3.1.8 of Policy DM 1.1 however goes on to state that

“Exceptionally, the loss of individual office developments to other commercial

or infrastructure uses may be acceptable, where the proposed alternative use

meets the wider objectives of the Local Plan”.

108. Local Plan Policy DM1.3 promotes small to medium enterprises in the City and

encourages the continued use of existing small and medium sized units which

meet occupier needs.

109. Local Plan Policy DM1.5 promotes a mix of commercial uses in office

developments that support the city's workers, residents, and enterprises while

also adding to its economy and identity. Supporting text (paragraph 3.1.20) of

the same policy defines complementary uses as retailing, leisure, education

and health facilities and states these should support the prominent office

environment of the City by providing supporting activities and services.

110. Emerging Policies S4 and OF2 of the draft City Plan require the protection of

existing office stock from being lost to other uses where the existing floor space

would be viable in the longer term or where the loss would cause harm to the

primary business function of the City. Paragraph 6.3.9 of the emerging Policy

OF2 states that when a change of use from offices to other complementary

uses which meet the policy priorities of the City Plan is proposed, then a viability

assessment may not be required. The paragraph continues to define

complementary uses as those that meet the needs of City workers, residents

and visitors and help make City buildings much more open and welcoming to

all. The change of use of offices at ground and lower ground levels would also

include the provision of improved vibrancy including active frontages and

permeability. Sustainable development is also a priority to reduce carbon

emissions and retain embodied carbon.

111. The Office Use Supplementary Planning Document (SPD) sets out the

evidence required to support the loss of office floorspace. Paragraph 20 of the

SPD states that when a change of use application provides complementary

uses to the City’s business function, the LPA may accept the development

without the need to demonstrate the viability of the office site.

112. Emerging Policies S6 and CV2 promote opportunities for new cultural and

leisure facilities offering unique experiences in the City’s evening and weekend

economies that support the City’s role as a visitor destination. Policy CV2 also

encourages the use of historic buildings for the provision of such uses that

would contribute to the enjoyment, appreciation and understanding of the City’s

heritage in an inclusive, accessible and welcoming for all way.

113. The submitted evidence report for the proposed loss of office considers that the

commercial building at 40-41 Furnival Street, due to its modest scale and

location, makes very limited contribution towards the City's office stock and the

primary business function of the City and would not have the potential for large

office development in the future. However, officers acknowledge that the

building is considered a viable office as it is currently occupied. Policy DM 1.3

(Small and medium sized business units) in particular encourages the

continued use of existing small and medium size units that meet occupier

needs. Despite the strong policy focus on larger office developments in

strategic locations, having a variety of sizes and scales of offices within the City

and in different areas is important for the business function of the City and its

reputation as a global business centre as well as for attracting a diverse

workforce.

114. The existing office, while occupied, is generally not of high quality or located

within a building of particular architectural or historical merit. Given the dated

and somewhat constricted layout of the existing building officers consider that

there is likely a restriction on useability, limited sustainability measures and

inadequate cycle storage or shower facilities. Following the global pandemic

there is greater demand for cycling facilities and buildings with good air

circulation which would therefore likely decrease the desirability of the building.

It is therefore considered that the office would be a poor competitor to other

buildings in better locations.

115. The proposed cultural and visitor use is considered to fall within the definition

of a complementary use to the City’s business function and proposes to offer a

unique cultural experience in accordance with the Emerging Policies S6 and

CV2. While limited Viability Assessment documentation has been submitted as

part of the proposal, the loss of the modest office is to be weighed against the

exceptional re-use of the adjoining heritage asset, the inherent requirement of

40-41 Furnival Street for access/ancillary space and the wider economic

benefits the cultural use would bring to the City as a whole.

116. The tunnels have been identified as a non-designated heritage asset due to

their historic value. Their retention and repurpose to provide a cultural exhibition

space, that would be dedicated to being appreciated by visitors through a

playful and joyful interactive learning experience, would be in line with Emerging

Policy CV2. It is noted that the heritage benefits and repurposing of existing

infrastructure have been identified in comments received from members of the

public as a significant and unique benefit of the development.

117. The additional proposed floorspace by utilising 40-41 Furnival Street would

achieve accessibility and fire safety standards by providing the necessary

facilities at ground level such as better circulation space, an increased number

of lift shafts, emergency exits and cycle storage as shown in the figure below,

as well as creating ancillary areas at upper levels such as gift shop, staff

accommodation and MEP storage.

Figure 4. Proposed Ground Floor Plan 38-41 Furnival Street – combined

floorspace

118. It is considered that the scheme would help create new jobs and significantly

revitalise the local economy by attracting visitors every year outside working

hours, during evenings and weekends, meeting the strategic objectives of the

City in order to sustain and complement its business function. Approximately

85 new full-time jobs are anticipated to be required to function the permanent

exhibition space in addition to extra staff that would be needed for the special

events space focusing on local recruitments. The proposed bar would operate

separately and would therefore employ its own staff. The application has

received 57 letters of support from the public the majority of which point out the

benefits the development would bring to the local economy in an area that has

suffered deprivation and fights to recover from the pandemic. Among them,

Fleet Street Quarter strongly supports the introduction of a much needed visitor

destination to this area. This would provide a transformative revitalisation of the

High Holborn area and as such has also been supported by the Central District

Alliance. Increased footfall by the development has been heavily supported on

that basis.

119. The supporting text in Local Plan Policy DM1.1 (Protection of office

accommodation) confirms that exceptional losses of individual office

developments to other commercial or infrastructure uses may be acceptable,

where the proposed alternative use meets the wider objectives of the Local

Plan. The high-quality, unique cultural use will contribute towards diversifying

the City’s visitor infrastructure, adding vibrancy and activity for seven days per

week and contribute significantly to the achievement of the City Corporation’s

Destination City ambitions and align with the City Corporation’s wider ambitions

for a post-Covid City. Furthermore, as highlighted above, the proposed use

would bring about a wider economic benefit to the City, providing 85 (FTE) local

jobs, up to 2 million visitors to the City per annum and the restoration of a

heritage asset. In this case therefore, while the proposal would reduce the

amount of potentially viable office space, the proposal is considered to fall

within the ‘exceptional’ category of complimentary uses and as such acceptable

in principle.

120. Whilst the Local Plan 2015 resists the loss of office floorspace, it is considered

the scale of the loss on this site (1,229sqm) would not prejudice the overall

supply of office space in the City, nor prejudice the potential for future site

amalgamation or result in the loss of existing stock for which there is demand

or longer-term viable need.

121. Overall, whilst there would be a loss of existing office floorspace, this would not

have an adverse impact on the overall stock of floorspace in the City or

prejudice the City’s role as an international business and professional centre.

The proposed development would contribute to the support of the City’s

business function offering a unique experience for its workers, residents and

visitors, and add a significant cultural supply to the City’s stock meeting

Destination City’s aspirations. It is therefore identified as complementary use

that meets the wider objectives of the Local Plan in accordance with adopted

Policies DM 1.1, DM 1.3, DM1.5 and emerging Policies OF2 and CV2. The loss

of office floorspace at 40-41 Furnival Street is considered acceptable on that

basis.

Cultural Use (Use Class F1 (b) (c))

122. The proposed development seeks to change the use of the existing Kingsway

Tunnels to a cultural and visitor attraction (exhibition space), including a bar.

The tunnels are not currently publicly accessible and are not in use.

123. The site falls within the CAZ and London Plan Policy SD4 outlines that within

this area the unique concentration and diversity of cultural, arts and tourism

functions should be promoted and enhanced.

124. The London Plan Good Growth objectives GG1 and GG5 are considered

applicable to the provision of community and cultural use (Heritage and Cultural

Exhibition) within development proposals.

125. London Plan Policy E10 states that London’s visitor economy and associated

employment should be strengthened by enhancing and extending its

attractions, inclusive access, legibility, visitor experience and management and

supporting infrastructure, particularly to parts of outer London well-connected

by public transport, taking into account the needs of business as well as leisure

visitors.

126. Policy S1 of the London Plan seeks to ensure that the social infrastructure

needs of London’s diverse communities are met.

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

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

be supported.

128. Local Plan Policy CS11 seeks to maintain and enhance the City’s contribution

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

access a range of arts, heritage and cultural experiences, in accordance with

the City Corporation’s Visitor Strategy, by providing, supporting and further

developing a wide range of cultural facilities. The supporting text for Policy

DM11.1 goes on to state that the international reputation and high quality of this

cultural activity are acknowledged as having a critical part to play in the vibrancy

of the working environment of the City.

129. Emerging Strategic Policy S6 of the draft City Plan 2040 outlines that the City

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

range of creative and cultural spaces and facilities across the City. Destination

City, the City Corporation’s flagship strategy, seeks to ensure that the City is a

global destination for workers, visitors and residents. It seeks to enhance the

Square Mile’s leisure and cultural offer by creating a sustainable, innovative

and inclusive ecosystem of culture that celebrates its rich history and heritage

and makes it more appealing to visitors as well as the City’s working and

resident communities.

130. Emerging Policy CV2 (Provision of Arts Culture and Visitor Facilities) of the

Draft City Plan 2040 encourages the provision of facilities that meet the needs

of visitors in new cultural developments. In particular by encouraging the

provision of arts, culture and leisure facilities in historic buildings and spaces

where this would contribute to the enjoyment, appreciation and understanding

of the City’s heritage in a way that is inclusive, welcoming and accessible for

all.

131. A Cultural Plan has been prepared by Future City and submitted as part of the

application which sets out the cultural vision, the development’s offer, the

delivery strategy and the future steps. The Plan envisages the activation of the

existing tunnels infrastructure to provide cultural exhibition spaces and

opportunities for programming and partnerships.

132. The proposals do not involve construction in the tunnels. The cultural mapping

has been made following the tunnels layouts and based on the historical

significance of each area. As mentioned earlier in the report, the tunnels were

built in phases and were used for different purposes during historic times. The

first phase (1942-1945) includes the construction of the ‘Streets’ that run

parallel to each other accessed by the former Chancery Lane tube station at

31-33 High Holborn. No.38-39 Furnival Street was built to make way for a goods

lift shaft. Originally built to serve as deep-level shelters but actually used for

‘Citadel’ accommodation housing telecommunications rooms where one of the

first Trans-Atlantic calls were made. A plan of ‘Chancery Lane Deep Tunnels’

is shown below demonstrating the various government departments in 1944.

This area is considered to hold the most important historic interest linked to

World War II period.

Figure 5. ‘Chancery Lane Deep Tunnels’ demonstrating the various

government departments in 1944

133. The tunnels were converted in the early 1950s after the Post Office and British

Telecom took their possession, which included the construction of four more

tunnels, known as the ‘Avenues’, on a north-south axis, formed part of the wider

expansion of Britain’s domestic telecommunications network. This area is

considered to be of secondary historic interest.

134. In some parts there are post-war plant and machinery remains associated with

the function and running of the Kingsway Exchange tunnels.

135. The figure below is an extract of the Cultural Plan and shows the defined areas

of the proposed cultural use within the tunnels.

Figure 6. Cultural Plan – key showing areas in the tunnels

136. A History & Heritage experience would reside in the ‘Streets’ marked as the

permanent exhibition space. The site has a historical significance dated to

WWII and subsequent historic times which the proposed scheme seeks to

embrace by repurposing the existing infrastructure and remains. This space

would curate the history of the site through a historic timeline by displaying the

retained and restored telecommunications equipment alongside other findings

and historical assets, engaging visitors in their exploration. The narratives take

place at the construction of the tunnels, in the 1940s, and go on to their

influence on wider historical events in London including WWII and the Cold War

in connection with the role of the tunnels during that timeline and their use as a

telecommunications centre for British Telecom in the 1980s. Part of the Streets

may be used for medium term exhibitions on associated themes such as James

Bond, a theme deriving from Ian Fleming’s reference to the tunnels in his first

book of the infamous UK secret agent.

137. The temporary/flexible Cultural Exhibition space would take place in the

‘Avenues’ and provide a ‘black box’ space, as mentioned in the Cultural Plan,

which would offer an adaptable space for various cultural programmes.

Technological support equipment, such as curved digital screens and

interactive systems, could be installed to support future potential programmes.

138. The floorspace allocated for cultural uses is a total 3,713 sqm. The permanent

Heritage Exhibition would reside 53% of that area leaving 47% to be covered

by the flexible Cultural Exhibition.

139. The main entrance to both exhibition spaces would be at ground level through

a new building at 38-41 Furnival Street. The ground floor serves as a check-in

point and waiting area until the visitors are taken to the tunnels through a round

lift shaft.

140. The following diagram shows the proposed indicative visitor route in the

tunnels, starting from the lift shaft access point and following the heritage trail

towards the ‘South’ and the ‘North’ ‘Streets’ and back to the access point.

Similarly, a shorter indicative trail is marked for the temporary exhibition area in

the three ‘Avenues’.

Figure 7. Diagram showing Visitor Heritage Trail & Exhibitions

circulation routes

141. Almost the entirety of the development serves the cultural uses, including the

upper floors of Furnival Street buildings which provide ancillary space for the

cultural use. The first and second floors would be used for ancillary retail to

house a gift shop. Level three would house MEP equipment serving the tunnels

and level four would be used for staff accommodation offering ancillary office

space, toilet facilities, lockers and outdoor amenity space.

142. A licensed bar would repurpose the original bar built by British Telecom in the

1980s retaining its historic elements. It is suggested to form part of the cultural

experience within the tunnels, however, it would function independently from

the permanent and temporary exhibition spaces and would be accessed via

Fulwood Place, the secondary entrance located in the London Borough of

Camden.

143. The proposed development seeks to provide a visitor and cultural attraction

(Use Class F1(b)(c)) and bar (Sui Generis) within the existing vacant

subterranean Kingsway Tunnels. The level of historical significance the tunnels

hold is so unique that is considered unlikely to find another site of this nature

that would have the potential to make a cultural offer equal to the one of the

proposed development. The proposed provision of a culture and leisure facility

within the various historic buildings and spaces would contribute to the

enjoyment, appreciation and understanding of the City’s heritage. It would

maintain and enhance the City’s contribution to London’s world-class cultural

status and would contribute significantly to the City’s ambitions for Destination

City and post-Covid recovery. The proposed facilities would not only contribute

to ensuring the City becomes a key leisure destination for visitors but would

also maintain and enhance its position as a global business centre, by providing

cultural/leisure experiences for people living and working in and around the

Square Mile. The proposed permanent Heritage Experience would directly

reference the historic tapestry of the City and the flexible exhibition spaces

would provide a unique and distinctive space for cultural events within the

Square Mile. Finally, the proposed uses would contribute to the balance and

mix of uses in the immediate locality, which is comprised of commercial,

educational, residential and office uses.

144. The Cultural Plan and Socio-Economic Assessment suggest that the proposed

development aims to attract up to two million visitors annually, boosting national

and international tourism, with an expectation to generate over 100 jobs and

increase local expenditure. There is a series of benefits brought forward

through the scheme that focus on inclusion and equal opportunities. These

include free school visits, opportunities for local jobs and apprentices, training

opportunities, providing spaces designed for a greater group of people, and co-

curation / co-creation programmes to engage the local community in shaping

the exhibition areas. The development scheme makes use of an existing

infrastructure that would otherwise stay untapped. It does that by creating a

space that focuses on their legacy and embraces their history in a unique way

with a commitment to invest millions of pounds to deliver that vision.

145. It should be noted that during the application’s public consultation, 57 letters of

support have been received, strongly supporting the provision of a touristic

attraction with the characteristics of the proposed scheme in an area that has

been battling to recover from the pandemic. Notwithstanding that, none of the

overall 24 letters of objection raised an objection to the retention and restoration

of the existing historic tunnels.

146. A Section 106 obligation would be required to secure the provision of the

proposed cultural spaces and public benefits brought forward, including a

Cultural Implementation Strategy and Operational Management Plan, and

securing a Cultural Operator or future Partners focusing on inclusive

procurement programmes. Officers consider these obligations to be necessary

for the delivery of the proposed cultural use.

147. The proposed cultural spaces would contribute to the cultural and community

offer in this part of the City. The scheme would align with the City’s ambitions

and direction of travel set out in the recent Destination City which seeks to

ensure that the City is a compelling, seven day a week destination. The

proposed development is therefore considered to be compliant with London

Plan Policies SD4, GG1, GG5, E10, HC5, Local Plan 2015 policies CS11,

DM11.1 and Emerging City Plan 2040 policies S6 and CV2.

Conclusion of proposed uses

148. For the reason stated above, it is considered that the proposed development

would contribute to the support of the City’s business function offering a unique

experience for its workers, residents and visitors, and add a significant cultural

supply to the City’s stock meeting Destination City’s aspirations. There are key

heritage and social benefits brought forward in the scheme and is considered

to constitute a positive development that meets the aims of policies in the Local

Plan and London Plan and meets key strategic objectives and emerging

policies of the Draft City Plan 2040. The proposed development is therefore

considered to be compliant with London Plan Policies SD4, GG1, GG5, E10,

HC5, Local Plan 2015 policies CS11, DM11.1 and Emerging City Plan 2040

policies S6 and CV2.

Design and Heritage

Policy Context

149. The relevant local policies for consideration are DM3.2, CS10, DM10.1,

DM10.3, DM10.4, DM10.8, CS11, CS12, DM12.1 and DM12.2 of the Local Plan

policies and S8, DE2 of S11 of the emerging City Plan, and London Plan

policies D3, D5, D8, HC1. HC5, HC6, GG2 and GG5.

Existing Site and Context

150. No.38-41 Furnival Street is located at the northern end of Furnival Street and

within the Chancery Lane Conservation Area. The existing site is composed of

two distinct buildings, No.40-41 is a modern office building and No.38-39 is an

existing entrance to the Kingsway Tunnels and has been identified as a non-

designated heritage asset due to its historic and rarity value.

151. Furnival Street is a narrow street which runs north-south connecting Cursitor

Street and Holborn. The townscape of the locality is of a modest scale, Furnival

Street is generally constructed of four and five-storey buildings with varied

roofscapes. The scale and massing of 39-41 Furnival Street sit comfortably into

the existing streetscape however although 38-39 Furnival Street is slightly

smaller in scale than the surrounding buildings. The architecture and

appearance of Furnival Street is a narrow enclosed street and dominated by

the use of brick and uniform gridded façades and a fine urban grain. No.38-39

is a positive and unusual contrast to the surrounding buildings, its simple

industrial brick façade hinting to the wider tunnel network below ground. The

architecture of No.40-41 dating from the 1990s is less successful due to the

dominating glazed bow frontage which breaks the uniformity of the streetscape.

152. The existing ground floor frontages have little street presence. At No.40-41 the

frontage is formed by an office lobby which has a lack of façade articulation and

limited street activation. No.38-39 is dominated by black-painted solid doors.

Overall, the buildings underperform for a streetscape which is characterised by

numerous openings and high levels of articulation.

Height/Bulk and Massing of No.38-41 Furnival Street

153. The disposition of the finial massing and bulk has followed a design-led

approach considering local townscape views, daylight assessment and

relationship with neighbouring buildings and access requirements to the

underground network. The massing and façade design has also been designed

around the delivery of optimal microclimatic conditions, including daylight,

sunlight and overshadowing to the building and its neighbours. With respect to

massing, height and façade treatment, the development would demolish the

entirety of No.38-39 and No.40-41 Furnival Street, and the proposed massing

and height of the new structures would largely recreate the existing building

proportions. The proposal would retain the appearance of two buildings,

maintaining the urban grain of the East side of Furnival Street. The changes in

height would be imperceptible and only experienced in oblique views.

154. The proposal would be formed of three levels of basement covering the extent

of the site. The proposed massing of No.38-39 would use the full extent of the

site and would slightly increase in height to accommodate ground plus three

storeys with a rooftop amenity, increasing the overall height by 3.4m. The

balustrading for the rooftop amenity would be set in from the main building

façade reducing its visual impact in the oblique views along Furnival Street, the

top height of the balustrading would be +36.10m AOD. The proposed massing

of No.40-41 would be formed of four storeys above ground plus a setback plant

enclosure at roof level, reaching +41.75m AOD. The massing would use the full

extent of the site footprint however it would be set back at the ground floor to

allow for a covered canopy over the entrance. Widening the public realm around

the entrance would reduce the impact of the increased footfall associated with

the new visitor attraction. The massing at the rear of No.38-41 has been

designed to ensure its visual impact on the neighbouring building has been

minimised by sloping the massing in the middle of the proposal from level 03

and above.

155. The proposal would positively address the street by introducing curved corners

to the body of the building reducing the visual appearance of the currently

unsuccessful blank flank wall which is visible in local townscape views looking

north and south down Furnival Street. The proposed massing would improve

these townscape views by reducing the furthest extent of the massing into the

street by 300mm and pulling the building line back at the ground floor to align

with No.14-18 Holborn.

Architecture and Materiality of No.38-41 Furnival Street

156. The primary frontage of No.40-41 would be a bold addition to the townscape.

The architectural treatment would express the new function of the building while

maintaining the traditional proportions of the street through its expression of

base, middle and top. While the façade of No.38-39 would reimagine the

existing brick façade celebrating the unique history of the site.

157. The proposal allows for a connected single internal floorplate to be achieved

without the disconnected inflexibility of joining the existing buildings. The two

blocks would read as distinct but connected buildings, tied together by a

consistent ground floor frontage and industrial architectural language and

materiality.

158. The development would transform the existing ground floor experience to

Furnival Street introducing a defined, active base of a human scale expressed

as a single height with a recessed covered entrance associated with the main

entrance. The site is constrained with limited frontage and through a design-led

approach the proposal has provided a high level of activation alongside

providing the required servicing entrance and fire escapes. The activation is

created through increased levels of glazing and the primary use of the ground

floor as the entrance to the tunnels. The servicing doors would be integrated

into the façade minimising their impact on the appearance of the building in line

with Local Plan policy DM10.1 and emerging City Plan 2040 policy DE2.

159. The primary entrance would be distinctive, and publicly located parallel to the

street within the 1500mm setback. The soffit treatment, of textured reflective

stainless steel would run from outside into the internal reception creating a

welcoming and visually interesting primary entrance. The entrance including

the soffit treatment would be designed to ensure that the highest standards of

accessibility and inclusivity are achieved in line with Local Plan policy DM10.8

and emerging City Plan 2040 policy DE2. The detailed design would be secured

via condition.

160. Materiality has been a central consideration. The building would have a high-

quality industrial appearance, with the rebuilding of the brick façade at No.38-

39 and the use of glass blocks at No.40-41. The materiality has been developed

to celebrate the history of the site while also providing a high level of natural

light into the building, creating a transition point for visitors between the

subterranean tunnels and the outside. The proposed materiality including

colour, design details and intricacies would be secured through conditions

including samples and bays studies.

161. The use of basalt cladding across the base of No.38-41 would provide a

consistent language across the two buildings and ensure that a high-quality

finish is achieved while ensuring that there is sufficient robustness for a primary

entrance with sufficient footfall.

162. The upper storeys of No.38-39 Furnival Street would celebrate the existing

building located on the site maintaining the unique industrial language by

reinstating the existing brick façade and incorporating the existing concrete

ventilation panel. The brick façade would be framed with black louvred panels

which would be setback from the brick elevation by 400mm creating a clear

hierarchy to the façade. No.38-39 originally had a metal crane, which has been

lost a would be replicated and reinstated.

163. The upper floors of No.40-41 would be characterised by the bold, simple and

elegant glass block four-storey façade, a modern interpretation of the industrial

language found at the existing No.38-39 Furnival Street. The glass block façade

was developed following an extensive pre-application process which looked to

balance the need to provide a high level of ventilation to the third-floor plant

space alongside providing adequate light levels to the ancillary office floor on

level 04. The bold façade would provide visual interest and express the public

uses without being overwhelming. The surrounding townscape is of a varied

character and the independence of the architectural approach and materiality

would add to the surrounding character.

164. The top floor of the No.38-39 would be the rooftop amenity for the tunnel’s

supporting workforce. The balustrading would be set back from the façade line

reducing the visual impact on local townscape views. The terrace has been

designed in line with the City of London Corporation Preventing Suicides in High

Rise Buildings and Structures planning advice note. The balustrading of the

terraces would be a minimum of 1.4m high and have a planted buffer zone

located in front of the balustrading line, creating a natural deterrent. Further

detail regarding suicide prevention would be secured via condition.

165. The outdoor amenity and urban greening of the terrace would provide visual

and physical amenity for the tunnel workforce supporting their mental health

and wellbeing in line with Local Plan policy DM10.3 and emerging City Plan

2040 policy DE2.

166. The glass block façade of No.40-41 Furnival would accommodate integrated

removable façade panels to allow for plant replacement in line with Local Plan

policy DM10.1 and emerging City Plan 2040 policy DE2. The junction detailing

and materiality would be secured by condition.

167. The roof top plant equipment and lift overruns would be screened by the plant

screen which is set back from the façade line reducing its visual impact on local

townscape views. The proposed plant and building services equipment would

be fully screened from view and integrated into the design of the building in line

with Local Plan policy DM 10.1, greening would be optimised where possible in

line with Local Plan Policy DM10.2 and emerging City Plan 2040 policy DE2.

Further details are required and would be secured via condition including the

5th elevation.

168. Appropriate lighting, in accordance with Local Plan Policy DM 10.1, would

deliver a sensitive and co-ordinated lighting strategy integrated into the overall

design, minimising light pollution, respecting the historic context, responding to

public safety and enhancing the unique character of the City by night.

Irrespective of the approved drawings, a detailed Lighting Strategy would be

subject to conditions to ensure final detail, including form, quantum, scale,

uniformity, colour temperature and intensity are delivered in a sensitive manner

in accordance with guidance in the City Lighting Strategy. The proposed public

realm lighting strategy would provide low-level illumination to architectural

features, to enhance the pedestrian experience, improve safety and protect the

existing surrounding residential amenity.

169. Cycle parking facilities for the Tunnel workforce would be accessed via an

entrance on Furnival Street. The short-stay cycle parking would be provided in

public realm. The active edges would improve the pedestrian experience and

cycle facilities would encourage active travel walking and cycling. The

proposals are acceptable and allow for active travel and comply with Local Plan

policy DM10.1 and emerging City Plan 2040 DE2.

170. Irrespective of the approved drawings, full details of the ground floor frontages,

design and materiality of the public realm improvements, and wayfinding

strategy are reserved for condition to ensure these are well-detailed and are

useable. The development has had regard for Local Plan Policy DM 3.2 and

the Mayors Public London Charter promoting a safe, inclusive and welcoming

environment.

171. A high-quality signage strategy and way finding for the proposal would be

required and would be secured via condition.

Conclusion of Architecture and Massing of No.38-41 Furnival Street

172. The proposals would successfully integrate into the modest scale of Furnival

Street and would significantly enhance the streetscape by providing increased

active frontage. The distinctive sense of separate buildings, materials, the

celebration of industrial heritage and intended quality would introduce a well-

considered, refined, neighbourly architectural set piece. The bold architectural

expression would reflect the unique cultural use of the buildings and the

subterrane tunnel network. The development is sensitive to townscape contexts

at macro and local scales. The proposal would optimise the use of land, whilst

significantly improving the buildings’ interface with their surroundings.

173. The development would create a high-quality culture-led commercial

development utilising the existing heritage of the site. The proposals align with

Local Plan Policies CS10, CS11 and CS12, Emerging City Plan 2040 Policy

DE2 and London Plan Polices D3, D5, HC5 and HC6. It is considered that the

scheme would represent ‘Good Growth’ by design, in accordance with the

London Plan Good Growth objectives GG2 specifically GG2E: understand what

is valued about existing places and use this as a catalyst for growth, renewal,

and place-making, strengthening London’s distinct and varied character and

GG5 specifically GG5F: promote and support London’s rich heritage and

cultural assets, and its role as a 24-hour city. The proposals would also align

with the mandate of Destination City by supporting London as a 24-hour city

and creating a new cultural offering in this corner of the City of London

174. An informative for architect retention is proposed.

175. Overall, the proposals accord with the City’s broader visions to deliver

outstanding places, as part of ‘Destination City’, ‘City Recharged’ (2020),

‘Future City’ (2021) and ‘Culture and Commerce’ (2021).

176. The proposals are in overall general conformity with Local Plan Strategic

Policies CS10 (Design), London Plan Policies D3/D8 and emerging City Plan

2040 Strategic Policy S8 (Design).

Heritage Impacts

Direct Impacts Chancery Lane Conservation Area

Significance:

177. The Chancery Lane Conservation Area and its buildings contain considerable

historic character and appearance to convey the area’s historical ethos through

their variety and quality.

178. The characteristics which contribute to the special interest of the Chancery

Lane Conservation Area can be summarised as follows:

• An exceptional span of building ages and styles, resulting in a townscape of

arresting contrasts;

• Significant historic associations with the legal profession, with origins as a

centre for medieval legal administration;

• The collegiate surroundings of Staple Inn and Barnard’s Inn, which

incorporate rare secular medieval survivals;

• A historic association with educational establishments that has persisted to

the present time (e.g. the Inns of Court, Birkbeck College, King’s College

London);

• The site of the Knights Templars’ first precinct and church in London (at

Southampton Buildings);

• A well-preserved and easily legible historic street network;

• Monumental 19th century Victorian public buildings in a range of styles;

• One important early act of conservation (Staple Inn north range) and several

buildings of varying periods associated with a single company’s patronage

(Prudential Assurance Co.);

• Well-considered 21st century insertions into a historic context.

179. No.38-39 is located adjacent to No.35 and No.36-37 which both offer examples

of 20

century executions of traditional forms. It is seen to have a positive

contribution to the conservation area and is noted within the CA Character

Summary and Management Strategy SPD as offering a strikingly industrial

aesthetic to the street, contrasting with the refined architecture of No.10

opposite. The key features which contribute to the industrial aesthetic as the

plain brick elevation, iron crane and large ventilation grille.

180. The character of No.40-41 is out of keeping with the prevailing architectural

aesthetic of Furnival Street due to its large bow front and is not deemed to be

a positive contributor to the conservation area.

Direct Impact:

181. It is noted that a number of objections have been raised regarding the impacted

of the proposal on the character of the Chancery Lane Conservation Area

however this is in contradiction with officers Appraisal and further discussion

regarding the impact of the proposals is set out below.

182. No objection from Historic England or Conservation Area Advisory Committee

(CAAC) have been raised regarding the impact on the Conservation Area.

183. No.38-39 has been identified as having a positive contribution to the

conservation area due to its industrial past and appearance and historic

associations as citadel accommodation. Due to the narrow grain of the street,

it is acknowledged that it is primarily the front façade of No.38-39 which

provides the positive contribution to the conservation area. The proposed works

at No.38-39 would comply with Local Plan policy DM12.2 and emerging City

Plan 2040 policy HE1 as the positive contributors of the existing building would

be reinstated within the proposed works, specifically the brick façade, concrete

grille and reconstruction of the metal crane.

184. No.40-41 Furnival Street would be replaced by a high-quality glass block façade

which would follow the existing datums set by No.14-18 Holborn. The

architectural language would create a modern industrial aesthetic at No.40-41,

emphasising the unknown heritage asset at No.38-39 and would create a

positive addition to the streetscape. Adding to the existing key characteristic of

the conservation through further addition of contrast and well-considered 21st

century insertions in line with Local Plan Policy DM12.2.

185. The view down Furnival Street from Holborn is currently framed by the high-

quality façade of No.10 Furnival Street and the blank red brick flank wall of

No.40 Furnival Street. The proposed works would make a positive contribution

to this view due to the activation of the flank elevation which would be achieved

through the introduction of curved corners and the continuity of the materiality

around corners.

186. The site appears in one local townscape view which has been highlighted in the

Chancery Lane CA Character Summary & Management Strategy SPD as

having a strong contribution to the character of the conservation area, the view

is taken from the junction of Cursitor Street looking north along Furnival Street.

The existing view is characterised by buff brick buildings to the west and a

mixture of red brick and stone to the east, terminating the street is the Grade II*

Prudential Assurance Building. The view would remain largely unchanged due

to the site being located at a significant distance, however, due to the change

in the façade line at No.40-41 Furnival Street the view would be opened up to

allow further appreciation of Prudential Assurance Building.

187. Where the proposal would be visible from higher level windows, officers are

satisfied that the designs would be of high quality, due to its materiality and

greening, providing a high level of architectural and visual interest.

188. On balance, there is sufficient quality within the architecture of the proposal, to

consider the impact on local townscape is acceptable, given that proposals are

of high quality and suitable massing which would be well articulated, and would

respond to its local context forming part of an interesting, varied, streetscape

along Furnival Street. The proposal would result in total demolition of No.38-41

Furnival Street however this would be mitigated by the reinstatement of the

brick façade, concrete grill and metal crane at No.38-39, which would

successfully promote the industrial heritage of the site.

Direct Impacts - Non-Designated Heritage Asset

189. Non-designated heritage assets are buildings, monuments, sites, places,

areas, or landscapes identified by plan-making bodies as having a degree of

heritage significance meriting consideration in planning decisions, but which do

not meet the criteria for designated heritage assets. The guidance in Historic

England’s Advice Note 7: Local Heritage Listing has been used to assess

whether the buildings on the site have the potential for non-designated heritage

asset status. The Kingsway Exchange Tunnels were identified to have such

status as a result of that scoping exercise.

Kingsway Exchange Tunnels

Significance:

190. Asset Type and Rarity: Only eight deep-level tunnels were built as part of the

air shelter programme and the majority of these are located in predominantly

residential areas, except for Chancery Lane and Goodge Street which are

located in predominantly commercial and institutional areas of central London.

The entrance located at No.38-39 Furnival Street is a rare example of industrial

architecture in the City of London, this is represented in the simple brick façade

with concrete ventilation panels and the metal crane which has been lost.

191. Age: The Kingsway Exchange Tunnels were completed in 1942 alongside the

entrance at Fulwood Place and the entrance at No.38-39 Furnival Street was

completed later in 1952. The age of the building does not relate to established

local characteristics or building traditions and does not contribute to the interest

of the Kingsway Tunnels.

192. Architectural and Artistic Interest: The tunnels network was constructed in a

similar way to the underground train network and is of a standard construction

methods. The purpose-built entrance at No.38-39 Furnival Street has a

utilitarian façade which is indicative of its function while its materiality helps

contextualise it into the surrounding streetscape. The intrinsic design and

aesthetic value of the heritage asset do not relate to the local vernacular and

the materials and construction where standard for the time period. The

Kingsway Tunnels do not have any intrinsic architectural or artistic interest.

193. Group Value: The Kingsway Tunnels does not have any clear design

relationship with the surrounding development, with the majority of the asset

hidden underground. The above ground structure at No.38-39 Furnival Street

is part of the 20

century piecemeal contemporary transformation of Holborn

Kingsway Tunnels does not have any group value with the surrounding

development.

194. Archaeological Interest: The building does not provide evidence of past human

activity in the locality and below ground archaeology is considered in detail in

the next section of the report.

195. Historic Interest: The Kingsway Exchange Tunnels were completed in 1942 and

originated as the Chancery Lane deep-level shelter one of eight deep-level air

raid shelters constructed during the Second World War to provide shelter to

Londoners during aerial bombing attacks. The structure and arrangement of the

Chancery Lane deep-level shelter was standard compared to the other seven

constructed. It comprises two principal tunnels, which run in parallel and are

connected by cross passages. The Chancery Lane deep-level shelter was

never used for civilian shelter and was instead converted to ‘Citadel’

accommodation in 1944. At this time the tunnels were adapted to accommodate

a reserve government headquarters in case of invasion or equivalent

emergency. In 1949 the General Post Office took over the tunnels for use as a

telephone exchange and works began at the beginning of the 1950s, in

complete secrecy under emergency powers, to extend the tunnels through the

construction of four large-diameter north-south tunnels, known as the avenues,

these were built to house the automatic switching equipment. It was at this time

that the building and goods lift at 38-39 Furnival Street was constructed. Its

historical uses, although no longer the building’s current use, adds to the

historic significance of the tunnels. The subterranean network of tunnels still

retains many features associated with their use as a citadel accommodation

and subsequent telephone exchange including a canteen, bar, sleeping

chambers and mechanical equipment. The site was also the location of the

UK’s termination point for TAT-1, the first transatlantic telephone cable in 1956.

Which acted as the ‘hotline’ between Washington and Moscow during the

Cuban Missile Crisis. The country's first radio paging terminal was also installed

on this site in the 1970s. The Kingsway Tunnels have significant historic value.

196. Landmark Status: There are no identifiable communal or especially striking

aesthetic values which make the Kingsway Tunnels stand out in the local scene

as much of the asset is formed of subterrane tunnels with limited above ground

presence. The architecture of No.38-39 Furnival was purposely designed to be

unobtrusive and recessive, so it is not considered to possess landmark status.

197. The Kingsway Exchange Tunnels have been identified as a non-designated

heritage asset, and the significance of the Kingsway Exchange Tunnels

primarily arises from its rarity and historic interest as a deep-level air raid

shelter, citadel accommodation and telephone exchange. The above-ground

entrance elements are minimal parts of this much larger complex and are not

representative of the extensive subterranean space and are of limited interest.

The rarity and historic interest are primarily associated with the subterranean

tunnel network.

Impact:

198. The proposal, as described previously, would result in the loss of some historic

fabric, and changes to the above-ground structures at 30-33 High Holborn and

total demolition of No.38-39 Furnival Street to be replaced by a reconstructed

brick façade with additional massing and an increase in overall height.

199. The proposals would result in a demolition of historic fabric to No.38-39 Furnival

Street, with the complete demolition of the above-ground structure and the

widening of the goods lift. The new proposal would dismantle the existing brick

façade and concrete vent and reintegrate them into the new façade. The

original crane which has been lost would be reinstated. The proposal would

create a modern reinterpretation of the existing building and the industrial

identity of the building would be maintained and emphasised by the new

building at No.40-41 Furnival Street. The works would comply with best practice

guidelines regarding cleaning and deconstruction and a complete methodology

would be secured via condition.

200. The works to the subterranean tunnel network would result in a minor loss and

alteration to the historic fabric associated with the refurbishment works. The

works associated with tunnels structures would be minimal and primarily

associated with the remove of the asbestos and works to the access shafts

which is required to ensure safe and inclusive access down into the tunnels.

The form and structure of the tunnels would be maintained, and key features of

the tunnels would be retained including the reinstatement of the deepest bar in

UK and creating a permanent exhibition with the surviving telecom’s equipment,

including the trunk exchange, generators and main distribution frame. The

proposed works would allow for the tunnel network to be opened up to the public

and allow for this currently unknown heritage asset to be enjoyed by a wide

public audience.

201. The proposed works to the Kingsway tunnels have been considered in line with

paragraph 209 of the NPPF regarding the harm or loss of a non-designated

heritage asset. The demolition of No.38-39 Furnival Street and reconstruction

of the brick façade would result in loss of part of the non-designated heritage

asset but on balance this would not diminish the overall significance of the

heritage asset due to limited level of demolition in regard to the entire network

of tunnels, and the continued expression of the tunnels above ground through

the use of simple industrial architecture. Overall, officers consider that the

proposed designs for the Kingsway Tunnels would improve the accessibility

and visibility of this currently unknown heritage asset to a wide public audience

without distracting from its historical and rarity value in line with London Plan

Policy HC1, Local Plan Policy CS12 and Emerging City Plan 2040 Policy S11.

202. In line with paragraph 210 of the NPPF, a condition is recommended to be

secured via Section 106, requiring a Cultural Operator to be secured prior to

any demolition works. Officers consider this as a necessary condition to ensure

the partial loss of the non-designated heritage asset would occur only when the

operation of the proposed cultural development would be secured.

Indirect Impacts:

No.25 Southampton Buildings - Grade II*

Significance:

203. Library and Offices of 1890-1912 by the Office of Works’ principal architect, Sir

John Taylor. The present complex also incorporates three bays of the elevation

of an earlier structure, Staple Inn Chambers, which was designed and built in

1842-43 for the Taxing Masters in Chancery by the London-based architects

Wigg and Pownall. Architecturally the buildings are of considerable interest: the

complex is formed of six distinct blocks with different architectural treatments.

The principal architectural interest of the building lies in the surviving interior

spaces, such as the atrium Reading Room with two gallery floors with

decorative ironwork and Corinthian columns. Further interest is derived from

the building facades which display handsome Victorian and Edwardian

architectural detailing. The Furnival Street and Southampton Buildings façades

are particularly elaborate in their architectural detailing and make a positive

contribution to the historic commercial character of Holborn. Significant historic

interest is also derived from its function as the reading room and offices for the

Patent Office, a government body established in 1852 to grant patents,

trademarks and design rights.

Contribution of Setting:

204. The buildings are located within a dense network of narrow streets and squares

with frontages to Furnival Street, Took’s Court, Southampton Buildings and the

gardens associated with the listed Staple Inn Building. The surrounding area is

characterised by large institutional and commercial premises, such as the Inn

of Court and the setting contributes to the understanding of its historical interest

as a Patent Office and Library. In the 19th century the commercial character of

the area developed with the construction of large-scale office buildings with

impressive street frontages. This is illustrated by the former Patent Office, the

Public Record Office to the south on Chancery Lane (also by Sir Henry Tanner)

and the Prudential Assurance offices to the north on High Holborn. There has

been piecemeal redevelopment throughout Furnival Street and the surrounding

area that has eroded the historic character of the area; however, these are

generally respectful in scale and function.

Impact:

205. No.38-41 Furnival Street is located to the west of the former Patent Office on

the opposing side of Furnival Street, the proposals would amount to change in

a neutral element of its setting. The proposals would be seen together in the

kinetic experience of Furnival Street however both would only be glimpsed in

oblique views. The changes to the façade line of No 40-41 would pull the

massing away from the listed building. Coupled with the setting back of the

upper level of No.40-41, the overall effect would be a distinctive and deferential

new volume that would not appear to dominate the listed building or challenge

it in these views. Accordingly, the proposals would preserve the setting and

significance of the listed building and the ability to appreciate it.

Prudential Assurance Building- Grade II*

Significance:

206. The office building was constructed between 1885 and 1901 to designs by

Alfred Waterhouse. In 1930-32, the building was altered and extended by EM

Joseph. The building is Gothic Revival in style and constructed in a distinct

combination of granite, red brick and red terracotta. The building occupies an

entire urban block within Waterhouse Square, with its principal façade to High

Holborn. The building has a complex floor plan with an interconnected series of

courtyards within the block. The Prudential offices occupy the former site of

Furnival’s Inn, one of Holborn’s Inns of Court, demolished in 1897.

207. The office building has a historical interest as the headquarters of the Prudential

Assurance, Investment and Loan Association, founded in 1848. The building

was extended over several years and designed to reflect the prestige of the

company. The building has further associations with architect Alfred

Waterhouse, who was responsible for well-known works such as the Natural

History Museum and Eaton Hall. The architectural interest of the building

derives from its imposing street presence on High Holborn and its high level of

Gothic detailing. The building is a fine example of purpose-built commercial

office architecture, designed to reflect the values of the company it housed. The

building has strong national associations with other Prudential Assurance

offices, demonstrating a national company identity.

Contribution of setting:

208. The setting of the Prudential Office building contributes positively to its

significance in its visual and spatial relationship with other large commercial

and institutional sites on and around High Holborn. The Prudential Office

building holds a prominent position on Holborn and the primary façade can be

appreciated in its entirety. There are fragments of the historic streetscape that

once characterised this commercial centre on the south side of High Holborn,

which contribute to an understanding of the development of Holborn in the late

19th century. To the east and west of the listed building, there is modern

commercial development of a contrasting style and materiality, which detract

from the architectural and historic interest of the building.

Impact:

209. There is minimal intervisibility between the listed building and No.38-41 Furnival

Street. The proposals would be seen in views of the listed building looking north

along Furnival Street, this would be a kinetic experience and the proposal would

only be glimpsed in oblique views. The changes to the façade line of No.40-41

would pull the massing back and open up the view towards the listed building.

Coupled with the setting back of the upper level of No.40-41 would be a

distinctive and deferential new volume that would not appear to dominate the

listed building or challenge it in these views. The site is a peripheral element in

the wider setting of the building and the proposals would preserve the setting

and significance of the listed building and the ability to appreciate it.

No.32 & 33 Furnival Street – Grade II

Significance:

210. A pair of early 18

century townhouses of three to four storeys over basement.

The buildings are typically Georgian in style and proportion, with architrave

windows, string courses, parapet roofline and door-hoods. The buildings have

architectural interest as a rare example of 18th century domestic development

in central London. The buildings have historic interest as an illustration of the

history of Holborn which developed as a residential suburb to the city before it

declined in popularity in the 19th century and became predominantly

institutional and commercial in character. The townhouses derive group value

from one another through their historic and visual association.

Contribution of setting:

211. The setting of the townhouses contributes positively to their interest, located in

the identifiable historic street pattern of Furnival Street and the surrounding

area, and the visual relationship with No. 10 on the opposite side of Furnival

Street. Furnival Street has undergone piecemeal redevelopment, meaning that

the neighbouring buildings to the listed townhouses are modern constructions.

These vary in architectural quality but overall respect the narrow plot size of the

historic development.

Impact:

212. No.38-41 Furnival Street is separated from the listed buildings by intervening

development. They share a wider visual relationship in the kinetic experience

of views looking north or south along Furnival Street however both would only

be glimpsed in oblique views. Accordingly, the proposals would preserve the

setting and significance of the listed building and the ability to appreciate it.

Indirect Impacts Chancery Lane Conservation Area

Significance:

213. The significance of the Conservation Area lies in its historic association with the

legal profession and educational establishments that have persisted to the

present time, Inns of Court, Birkbeck College, King’s College London. The

architectural character of the conservation area covers an exceptional span of

ages and styles resulting in a townscape of arresting contrast. The

Conservation Area is bound by busy arterial roads, Holborn and Chancery Lane

but vastly made up of well-preserved narrow network historic streets.

Setting:

214. The conservation area is surrounded by a varied and diverse character: to the

East, large scale modern commercial buildings, to the South the diverse

character of commercial buildings associated with the Fleet Street

Conservation; to the West is the Bloomsburg Conservation Area characterised

by low rise buildings around formal landscape squares; to the North is the

Prudential Assurance Building located in the Hatton Garden Conservation

Area.

Impact:

215. The indirect impacts on the Chancery Lane Conservation Area derive from the

above ground works associated at Fulwood Place within the London Borough

of Camden. There would be limited intervisibility with the Chancery Lane

Conservation Area and the works are deemed to have no impact on the

Conservation Area.

Wider Heritage Impacts

216. The definition of setting is the extent to which an asset is ‘experienced,’ which

is not geographically set and can change over time, relating to more than just

a direct visual influence. Given the dense central London location, the site is

potentially within the setting of an enormous amount of heritage assets, and it

would be disproportionate to assess them all. As part of a scoping exercise, this

assessment is in accordance with paragraph 200 of the NPPF and is deemed

proportionate and no more than is sufficient to understand the potential impact

of the proposal on its significance. In accordance with paragraph 201 a number

of potentially affected assets were scoped, accounting for their significance and

contribution of setting to that significance. Additional assets assessed include:

• No.4, 5 and 6 Staple Inn (Grade I)

• 337 and 338, High Holborn (Grade II*)

• No. 9 and 10 Staple Inn (Grade II)

• Staple Inn Hall (Grade II)

• No. 7 and 8 Staple Inn (Grade II)

• The Institute of Actuaries (Grade II)

• Staple Inn North and South Buildings (Grade II)

• Mercer’s School Hall and Building Adjoining (Grade II*)

• Barnard’s Inn Hall (Schedule Monument)

• Hatton Garden Conservation Area (Camden)

• Bloomsbury Conservation Area (Camden)

Conclusion of Heritage Impacts

217. The proposals, by way of impact on setting and character, would preserve the

heritage significance and setting of all aforementioned heritage assets. The

proposals comply with policies CS12 and DM12.2 of the Local Plan 2015 and

S11 and HE1 of the emerging City Plan 2040.

218. The loss of historic fabric associated with the Kingsway Tunnels as a non-

designated heritage would be mitigated through the improvement to the

accessibility and visibility of this currently unknown heritage asset to a wide

public audience. The industrial language of No.38-39 Furnival Street would be

maintained through the reconstruction of the brick façade and the reinstatement

of the metal crane. As such, the proposals are considered to accord with Local

Plan Policies CS12, DM12.1 and DM12.2, emerging City Plan Policies S11 and

HE1, London Plan Policy HC1, having accounted for and paying special regard

to section 72 of the Town and Country Planning (Listed Buildings and

Conservation Areas) Act 1990 (as amended) and the relevant NPPF policies.

Archaeology

219. Policy DM12.4 of the Local Plan 2015 and policy HE2 of the draft City Plan

2036 outline the requirements with regards archaeology, that the City will

preserve, protect, safeguard and enhance archaeological monuments, remains

and their settings, seeking inclusive access to, public display and interpretation

where appropriate.

220. An Archaeological Desk-Based Assessment has been submitted with the

application.

221. The development site lies in an area of archaeological interest (Archaeological

Priority Area) identified in the City Local Plan. The City of London is considered

an archaeologically sensitive area in its entirety. In accordance with the City of

London Local Plan 2015, all of the City is considered to have archaeological

potential, except where there is evidence that archaeological remains have

been lost due to deep basement construction or other groundworks.

222. The desk-based assessment highlights that there was an archaeological

excavation by the Museum of London’s Department of Urban Archaeology in

1988 prior to the erection of the existing building at 40-41 Furnival Street. This

revealed medieval gravel quarries backfilled with brickearth, a series of 13th-

15th Century rubbish pits and a chalk-lined cesspit. The remains of the 17th

Century L-shaped building were excavated on the southern half of the site

which might have removed any evidence of the earlier inn. It is therefore likely

that archaeological remains have been removed from 40-41 Furnival Street.

The current building has a basement level with a floor slab at approximately

3.70m deep and it is considered that any archaeological survival would be very

low.

223. At 38-39 Furnival Street, bombing damages occurred during WWII and the

previous building was demolished. The current building hosts a vent shaft and

a lift in its basement that provides access to the tunnels. Given the old

basement housing the Kingsway Tunnels’ vent shaft and access shaft lay on

the site, archaeological survival is likely to be very low. The Kingsway Tunnels

have survived almost intact.

224. The scheme proposal includes the demolition of 38-39 and 40-41 Furnival

Street and their redevelopment, including the construction of a new four-level

basement across the footprint of the new buildings. The existing round shaft at

38-39 Furnival Street would be retained within the new basement and

excavation works would aim to enlarge the areas around it to provide space for

evacuation stairs.

225. There would be no construction works for the tunnels themselves, however

refurbishment works would be necessary to bring the tunnels into use. It is

acknowledged that these works could affect some of the earlier historic features

of the tunnels dating in the 1940s such as the air-raid shelter and later bunker

and computer centre.

226. The Greater London Archaeological Advisory Service (GLAAS) advised that

further archaeological work should be undertaken for 38-39 Furnival Street

before any excavation takes place as some archaeological potential remains.

In relation to the tunnels, GLAAS identifies the high heritage interest they hold

and recommends that historic building recording is carried out for them prior to

the redevelopment works. The historic building recording should utilise the

digital scans that have already been carried out for the site. The proposed

development works are identified as possible to cause harm to archaeological

remains and field evaluations should be carried out to determine the

appropriate mitigation measures. GLAAS, therefore, recommends two-stage

pre-commencement archaeological conditions requiring a Written Scheme of

Investigation (WSI) and a Historic Building Recording to be carried out prior to

any demolition works. This would comprise firstly, evaluation to clarify the

nature and extent of surviving remains, followed, if necessary, by a full

investigation.

227. The proposals are acceptable in archaeological terms subject to conditions to

cover a WSI and historic building recording. The application therefore complies

with Local Plan Policy DM12.4 and draft City Plan Policy HE2.

Public Access and Inclusivity

228. Developments should be designed and managed to provide for the access

needs of all communities, including the particular needs of disabled people as

required by policies CS10, DM10.1, DM10.5 and DM10.8 of the Local Plan,

policies S1 and S8 of the emerging City Plan 2040 and policy D5 of the London

Plan. Plan 2040 and policy D5 of the London Plan. In particular, policy DM10.8

requires to achieve an environment that meets the highest standards of

accessibility and inclusive design in all development (both new and

refurbished), open spaces and streets.

229. Local Plan policy DM 10.8 requires “to achieve an environment that meets the

highest standards of accessibility and inclusive design in all developments (both

new and refurbished)”. A service provider also has an anticipatory duty under

the Act.

230. A Design and Access Statement has been submitted in conjunction with

supplementary letter of clarification prepared by David Bonnett Associates

(DBA) in response to officers requests.

231. It is also noted that the proposed development has been reviewed by City of

London Access Group (CoLAG) during pre-application stage.

232. The proposed development has been carefully designed within the constraints

of the existing buildings to ensure that the access needs of all users have been

considered.

233. The provision of places to store a mobility scooter is welcome in principle and

should include fire prevention measures and accessible charging points.

Further details of this would be included within an Access Management Plan.

Arrival at the Site

234. Consideration has been given to the points of arrival at the site and the main

entrance to the cultural use amended following officers comments. Details of

the points of arrival and entrances to the site would be secured by an Access

Management Plan.

235. Arrival at the site has been considered for a number of travel options. The

walking distances from key public transport nodes exceed the recommended

50m without a rest. It is therefore welcome that resting points with accessible

seating are proposed wherever possible at maximum intervals of 50m along the

approaches to the buildings from key points of arrivals, to be secured under a

Section 278 Agreement. It is also welcome that an additional blue badge space

is proposed on Furnival Street near the site’s entrance. The exact location and

timed restrictions would be subject to further consultation carried out under a

Traffic Regulation Order. It is noted that Blue Badge holders are limited to 4

hours parking in City of London accessible parking bays.

236. The applicant has provided a framework to provide new high quality public

realm which would significantly improve the pedestrian environment and

capacity, the details of which would be guaranteed within a S278 Agreement.

The highways authority is exploring the further works under a healthy streets

scheme in conjunction with the above on Furnival Street and connecting roads,

that will look to provide the required accessible parking space, provide suitable

pavement to provide access to all, offer suitable resting areas where possible.

237. Continuing provision of the existing Blue Badge space in the area during

construction is important provided it is safe for use and it is recommended that

details are reserved of how this continuous provision will be secured through

the Deconstruction and Construction Logistic Plan.

238. Staff arriving on large outdoor mobility scooters would have one dedicated

parking space in the ground floor cycle store. An independent and dignified

inclusive transfer strategy to access level four office accommodation would be

required to be agreed under the Access Management Plan.

Cycle Provision

239. The long stay cycle entrance for the staff of the tunnels would be provided onto

Furnival Street and would be automated. The Access Advisor has advised that

controls should meet best practice guidance as set out in BS 8300 (2) 8.2.3 to

be accessible to a range of users. The submitted plans show that a space for a

larger cycle would be provided.

240. It is noted that 5% of cycle spaces should be suitable for larger cycles in order

to meet London Plan 2021 Policy T5B and London Cycling Design Standards

8.2.1 guidance. Wheelchair-accessible sanitary and changing facilities are also

necessary. On the submitted plans these appear to be provided within the

Furnival Street building in close proximity to the office accommodation.

However, access to associated staff changing facilities would be limited during

hours of operation. Further detail of operational management is recommended

to be reserved by condition to ensure that associated impacts are limited.

Entrance

241. The Access Statement details the entrances to 38-41 Furnival Street and 31-

33 High Holborn and confirms that they will all be step free with a clear opening

width of at least 1000mm. The primary visitor entrances at both Furnival Street

and Fulwood Place have been confirmed to be an automated swing doors.

Further detail is proposed to be secured via condition to ensure the design of

the manifestation, thresholds, mat wells and floor finishes designed to inclusive

design best practice guidance.

242. Reception facilities should be consistent with AD M(2): 3.6 and BS 8300 8.6.2

Routes from the entrance/lobbies and should be logical, clearly defined and

unobstructed, with adequate and sufficient circulation space. Reception area

desks should be positioned away from the entrance to minimise noise, with

lowered counter sections, appropriate hearing enhancement systems and the

surface of the reception area should be slip resistant. Circulation space around

the front entrance desk should ensure clear movement for wheelchair users,

people with buggies and mobility scooter users. Details are proposed to be

provided through condition.

Vertical Movement

243. London Plan D5, (B)5 states ‘in all developments where lifts are installed, as a

minimum, at least one lift per core (or more subject to capacity assessments)

should be a suitably sized fire evacuation lift suitable to be used to evacuate

people who require level access from the building’. Supporting text (paragraph

6.2.1) further states that there should be an evacuation lift in addition to fire-

fighting lifts. Proposals and the access statement confirm that all lifts will be

more than 1100x1400mm with appropriately sized landings and back-up lifts

are identified across the site in case of failure.

244. The lifts which provide access to the office accommodation from Furnival Street

are not sufficient for users of larger mobility vehicles and alternative provision

should be identified through the Access Management Plan. It is recommended

that details of lifts are reserved by condition.

245. The lifts at Fulwood Place which provide access to the tunnels and are integral

to the escape strategy from the tunnels do not meet the recommended size set

out by BS 8300-2:2018 (Table 4) for users of larger mobility vehicles and

alternative provision should be identified through the Access Management

Plan. It is recommended that details of lifts are reserved by condition.

Horizontal Movement

246. Corridor widths and door openings are confirmed as consistent with AD M(2),

including sufficient door widths and passing places for wheelchairs and will be

subject to detailed design development.

Terraces and Garden Space

247. The areas of landscape have the potential to offer places for rest and recovery,

consistent with guidance in PAS 6463: Design for the Mind. The detailed design

for the amenity terrace should meet best practice guidance as set out in BS

8300-1:2018 to be accessible to a range of users. It is noted that the details of

hard and soft landscaping will be secured by condition.

Sanitary Facilities

248. It is confirmed that unisex accessible toilets will be provided on all floors, with

a range of handed units across the development. Separate male and female,

as well as gender neutral cubicles, ambulant disabled cubicles, baby changing

facilities, and a Changing Places facility are provided across the development.

Further details of the toilet facilities layouts would be required by condition and

their access arrangement through S106 obligation under the AMP.

249. A Changing Places toilet was agreed during development of the proposals, and

which will support the public functions of the tunnels and help make it more

accessible to more people. There are few Changing Places facilities within the

City at present and, although not available on a 24 hour basis, this is a key

element of making the scheme more inclusive. Management and operation

should be covered in the AMP and would be secured via Section 106 obligation.

Internal recovery and restoration areas

250. Recovery and restoration areas have been deemed important for the proposed

development given the long distances to cover in a subterranean environment

and potential for high sensory stimulation, including from exhibitions. The

exhibition space targets to attract a broader audience including children,

elderly, families, people with restricted mobility, a place that would be

accessible to everyone. It is therefore critical to ensure that areas of rest and

isolation are provided in strategic locations within the tunnels for restoration and

recovery.

251. The letter of clarification by DBA proposes accessible seating to be provided at

50m maximum intervals within the exhibition spaces and a quiet room to be

placed in the Avenues, where the temporary exhibition space would be

provided. Recovery areas are proposed at approximately 60m intervals with

exact locations and design to be reserved by condition. Recovery areas would

feature accessible seating and tables, drinking points, visually and acoustically

calming spaces. Further details could be reserved in the Access Management

Plan as an obligation.

Signage and Wayfinding

252. Signage and wayfinding will be important for navigating the site and should be

designed with reference to guidance in PAS 6463: Design for the Mind and

following the principle of ‘two senses’. Details of a Wayfinding Strategy will be

secured by a condition.

Inclusive Procurement and Co-curation

253. An obligation for Inclusive Procurement has been made under the Section 106

including but not limited to opportunities of co-creation / co-curation,

partnerships with artists from underrepresented groups, as well as

opportunities for volunteering, training and mentoring for underrepresented

groups of people.

Public Access and Inclusivity Conclusion

254. The proposal has been designed to ensure that the site is accessible for the

greatest range of people. In order for the proposed cultural use to fulfil its goal

of being a top-tier tourist destination, high accessibility standards and inclusive

environments and practices are essential. Great consideration has been given

as to how to get beyond the limitations posed by the existing building and

tunnels infrastructure in order to secure the optimal solution for everyone.

Subject to further design details and an Access Management Plan, it is

considered that the proposal accords with the access related policies outlined

above.

255. Overall, and subject to the imposition of conditions, the proposal would accord

with the access policies outlined above.

Culture and Education Strategy

256. Policy S1 in the London Plan states that development proposals that provide

high quality, inclusive social infrastructure that addresses a local or strategic

need and supports service delivery strategies should be supported.

257. Local Plan policies CS11 and DM11.2 and draft City Plan 2040 Strategic Policy

S6 encourage new cultural experiences and art works. A Cultural Plan has been

submitted in accordance with emerging Policy CV2 of draft City Plan 2040.

258. A Cultural Plan has been prepared by Future City which sets out the vision and

strategy for the use of the existing tunnels as cultural and visitor attraction. The

proposed cultural destination has been characterised as the ‘London’s

Underground Connector’ in the Cultural Plan, as it strategically sits between the

London Borough of Camden and City of London, two local authorities offering

prominent cultural landmarks and central attractions linked to London’s rich

history from the Roman period, to the presence of St Paul’s and Tower Bridge,

and various livery halls and historic walks. The site would be an opportunity to

add a layer of the 20

century history to London's legacy.

259. The culture and education strategy has been developed around four key

principles: Cultural Intelligence; History and Heritage; Active Participation; and

Sustainable Futures. It is envisaged to use high-end technologies with

programming partners to create transformative experiences in the tunnels

providing a unique opportunity for visitors to interact with a range of media

through a digital stimulus. The history of the site plays a key role in creating a

context of physical heritage assets and programming along the cultural

exhibition areas. In line with the Destination City vision and the consultation

feedback through engagement with stakeholders inclusive and accessible

spaces would be introduced in the tunnels for everyone to enjoy, with part of

the cultural programming focusing on raising awareness about environmental

issues.

260. As mentioned previously, the tunnels would comprise three spaces: The

temporary Cultural Exhibition Space (in the ‘Avenues’); the permanent Heritage

Exhibition Space (in the ‘Streets’); and the Bar. The latter falls outside the

Corporation’s boundary.

261. The applicant's plan is to assemble a dedicated Cultural Delivery Team, for the

delivery of the exhibition programmes outlined in the submitted Cultural Plan,

in relation to the temporary exhibition space. A bespoke team would be

responsible for the operation of the venue. It is envisaged to partner with

London Festivals and Cultural Institutions to enable a variety of cultural

exhibitions and events. It is estimated to secure up to 12 events per year. The

access, operation and coordination of these events would be secured by an

obligation for a Public Access and Events Management Plan in the Section 106.

262. The Cultural Plan identifies the ‘History & Heritage Space’ (permanent

exhibition space) as a ‘continuous excitement’ with recurring programming

responding to the historic significance of the tunnels. It envisions partnerships

with historical and heritage institutions within London and the UK. The Imperial

War Museum, the British Museum and the Museum of London are mentioned

as potential large-scale programming partners, but it is also envisioned to

partner with smaller-scale organisations.

263. A final Cultural Operator is not secured at this stage, however the applicant has

been in meaningful long discussions with providers who have expressed

interest. Suggestions have been made to house the Military Intelligence

Museum in the tunnels. A Cultural Implementation Strategy as a Section 106

obligation would be secured restricting demolition works until an Operator is

secured.

264. The Cultural Plan refers to an initiative of creating a figurative Lab, referred as

the T-Lab, a partnership project that would bring together university, tech-

institutions, creative communities as key partners with further collaborations

with local and London-wide communities, to support generating and providing

content in both exhibition spaces. Opportunities for co-curation and co-creation

of cultural spaces with the help of local communities are considered key factor

to achieve inclusive developments. An Inclusive Procurement and Cultural

Implementation Strategy would be secured by an obligation in the Section 106

agreement which would require further details on inclusive partnerships

including the involvement of underrepresented artists and groups in the

formation of special exhibitions.

265. The proposed exhibition space is anticipated to attract up to two million visitors

per year which would boost national and international tourism. The submitted

Socio-Economic assessment suggests that these visitors could spend between

£60m - £85m in the local area each year. It is estimated that the development

would generate over 100 jobs through direct employment within the cultural use

and an addition of 50 jobs that would arise through the supply chain and worker

expenditure at the London level. The proposed development would generate

approximately £6.1 million of additional Gross Value Added (defined as “the

measure of the value of goods and services produced in an area, industry or

sector of an economy”).

266. The applicant has made a commitment to offer free school visits to the cultural

use. A minimum of two school-trips every week has been found logistically

achievable. Free entry is also considered for up to 20 members of the military

per weekday while discounts would be available for universal and pension

credit holders, emergency workers and carers, teachers, students, young

people and local residents.

267. It is targeted to attract audiences which can differ between the different cultural

offers within the tunnels. Indications of the audience segments include cultural

tourists, incidental tourists, young creatives, families, older learners, education

groups (including schools, colleges, universities, further education, etc), special

interest groups (clubs, societies, etc), local residents and workers.

268. The social benefits of the proposed cultural use include the following features

and commitments made by the applicant as stated in the Socio-Economic

Assessment:

• Offer entry discounts for universal and pension credit holders, emergency

workers and carers, teachers, students, young people and local residents

and free school trips and members of the military to the proposed cultural

exhibition space;

• Maximising opportunities for local jobs and apprentices in collaboration with

London Borough of Camden and City of London, including placements for

local school age children and/or local adults residents;

• Work with local community centres to keep local residents informed on the

development progress and job and training opportunities;

• Accessibility and Inclusivity – the cultural spaces would feature enhanced

access for people with disabilities (both visitors and employees) and ensure

spaces would be designed to be enjoyable and safe for everyone;

• Inclusive procurement and partnerships with inclusive cultural providers;

opportunities for co-created/co-curated exhibitions (community participation

is shaping the design of new cultural events/spaces/galleries); partnerships

with artists of underrepresented groups; volunteering and training

programmes for vulnerable groups of people and for schools;

• Repurposing existing historic tunnels – the proposed development aims to

provide access to the existing infrastructure that has been non-operational

since the 1980s by investing £140m in restoration and preservation. The

applicant commits to an £80m investment for installing the immersive

technology that will help bring the story of the tunnels to life.

269. The provision of the proposed cultural spaces and the benefits that are brought

forward would be captured and secured under a Section 106 agreement for a

Cultural Implementation Strategy and Operational Management Plan.

270. The proposed cultural spaces would provide a destination cultural and

community space which would contribute towards the Corporations Destination

City initiative of creating fun, inclusive and innovative spaces and places that

attract people to the City.

271. The proposed cultural spaces are considered to be an enhancement to the

City’s cultural provision and provide public benefits such as free school-trips at

least twice a week and delivering a highly accessible and inclusive venue.

272. As such, officers consider that the proposal would be in accordance with Policy

CS11 to maintain and enhance the City’s contribution to London’s world-class

cultural status and to enable the City’s communities to access a range of arts,

heritage and cultural experiences, in accordance with the City Corporation’s

Visitor Strategy, Policy DM 11.2 Public Art To enhance the City’s public realm

and distinctive identity.

Transport and Highways

273. The site has the highest level of public transport provision with a public transport

accessibility level (PTAL) of 6B. The application site is also in close walking

distance of London Underground (LU) stations, namely Chancery Lane Station

(c.130 metres), Farringdon (c.650 metres) and Holborn (c.700 metres).

Chancery Lane provides a direct connection to the Central Line and is

reachable within 2 minutes on foot. Farringdon provides access to the Circle

Line, Hammersmith and City Line, Metropolitan Line and the Elizabeth Line.

Holborn (one stop from Chancery Lane) provides onward connection to the

Piccadilly Line and Central line.

274. Farringdon Station is an 8-minute walk away (approximately 650m to the

northeast of the Site). In addition to providing access to the Circle,

Hammersmith & City, Metropolitan, and Elizabeth Line, Farringdon Station also

has access to National Rail services, via Thameslink. The station is served by

regular trains to St Albans, Cambridge, Brighton, Horsham, and Bedford,

amongst others.

275. City Thameslink is a 10-minute walk away approximately (800m south of the

Site). It is served by trains operated by Thameslink on the Thameslink Route

which is a 24-hour main-line route, running from Bedford, Luton, St Albans City,

Peterborough and Cambridge via Central London to Sutton, Orpington,

Sevenoaks, Rainham, Horsham, Brighton and East Grinstead.

276. The closest bus stop to the Fulwood Place Site access is the Chancery Lane

Station bus stop, 125m to the east. The access at 38-41 Furnival Street is

closest to the bus stop at Holborn Circus, 120m to the north-east of the access

point. Chancery Lane Station bus stops are located between the two access

points in Fulwood Place and 38-41 Furnival Street. The stops are served by 5

services, the number 8, 59, 133, N8, N25, and N242.

Trip Generation

277. The applicant has submitted a Transport Assessment (TA) to support the

application, which includes details on trip generation and modal splits. The trip

generation has been calculated by reviewing the theoretical capacity of a busy

design day for visitors coming to The London Tunnels. The design day has

been designed to accommodate the predicted trip generation for the 20 busiest

days of the years (bank holidays etc) based on a density of 6.53sqm per person

in the tunnels, equating to a maximum of 1,020 visitors on site with 750pp/hr in

the tunnels. A normal day (weekday) has been calculated at 10sqm per person

which equates to 490pp/hr in the tunnels and 760pp/hr across the Site as a

whole.

278. Based on the maximum capacity of 1,020 visitor capacity, extrapolating this

over to a maximum daily, weekly, monthly and annual capacity is shown below

in Figure 8.

Figure 8. Maximum visitor capacity assessment

279. Within the initial submission of the Transport Assessment the applicant

compared the likely modal split of the site to the Postal Museum in Islington.

Amended documents have since been submitted with the more likely

compatible site of the Museum of London as a comparison which is considered

to be more similar in nature and likely to generate a similar modal split for the

proposed development.

280. Officers are satisfied that based on this latest submission the outlined impact

of the development can be assessed based on the current assumptions

included within the Transport Assessment Addendum.

Figure 9. The modal split for the proposal

281. The overall numbers travelling to and from the site each day are likely to be

significant and therefore require mitigation. While there is also a potential

additional impact from the staff trip generation, with only 85 staff based at this

site at any one-time, officers have focused the impact of the assessment on the

public highway on the number of visitors.

282. In addition to this the additional visitors attending the special events proposed

for a typical operational purposes are required to be taken into account within

the assessment.

283. Focusing on the main visitor trips, based on the above modal split, there are

four key areas of consideration:

• The pedestrian impact in the area. With a predicted 2025 additional

pedestrians travelling to/from the area, additional visitors coming via

public transport and coach would need to be assessed as they would

also likely all need to utilise pedestrian links to and from the site. This

would inevitably have an impact on pedestrian comfort levels in the area.

• Public transport capacity. With the significant number predicted to use

the train and underground travelling to and from the site, initial impact

analysis assessments have been provided to demonstrate that local

public transport infrastructure can cope with the additional uplift in trips.

• Taxi mitigation. With a predicted 135 people likely to use taxis to travel

to and from the site, on an assumption of two to three capacity per taxi,

this would generate an additional 45-68 taxis per day travelling to and

from Furnival St.

• Coach mitigation. Coach trips to and from the site would be discouraged.

284. In summary, this application would produce a significant impact on the public

highway. That being said, officers are confident that through the below outline

mitigation measures, conditions and obligations the application is considered

acceptable in transport terms.

Events Management

285. In additional to the outlined 'day to day’ trip generation the application seeks to

use the venue for other out-of-hours uses as a potential events venue. This

impact would need to be carefully managed with consideration being given

specifically to any impact on local residents from noise or vehicle movements.

286. Any events would likely need to be considered on a case-by-case basis,

particularly if these events would require special deliveries, any special

allowance of vehicles to and from the site, possible queuing or dwelling outside

the site. Operation and opening times would also be required to be managed

to minimise the impact of these events and ensure that any impact on the public

highway can be mitigated.

287. Therefore, in order to manage these events appropriately, an Event

Management Plan is proposed to be secured via the attached Section 106 legal

agreement which would include the requirement of event management plans to

be submitted to the highway authority prior to each event. It is noted however

that should the Highway Authority feel that the impact on the public highway is

unacceptable then the Authority reserve the right to refuse permission for the

event proceed.

Pedestrian Impact and Public Realm

288. Upon review the submitted proposals would likely generate a high number of

visitors traveling to or from the site each day, with an expected 2,025 pedestrian

trips per day. The overall impact on the public highway and specifically on the

pedestrian comfort levels has been a significant focus in assessing this

application.

289. A site visit was conducted by the applicant to measure the footway widths within

an agreed study area to measure the critical paths. Critical Paths are defined

as the effective width of the footway where pedestrians can walk. The critical

paths additionally took into account street furniture and any frequent pedestrian

queues at bus stops or other areas.

290. This corresponded with a pedestrian count for the area (June 2023), with which

the pedestrian comfort levels can be assessed with. The applicant has applied

the expected uplift in pedestrian numbers should planning permission be

granted to this assessment along with predicted uplift in footfall by 2041 to

predict any potential alterations to the pedestrian comfort levels.

291. Pedestrian Comfort Levels range from A-E, with A being the most comfortable

for free-flowing pedestrian movement. The City of London is committed to

providing no lower than B+ standard of all public spaces both of private public

realm and on public highway.

292. In general, the impact of comfort levels is acceptable, as this is mainly helped

by the many options for pedestrian routes and public transport access across

the area. However, given the constraints of the site there is likely to be an

impact on Furnival Street for which the main entrance to the site is proposed.

293. Furnival Street is a narrow street that is north bound for general traffic only with

a contra flow cycle lane. It currently suffers from very narrow footways which

would need amendments should planning permission be granted. Initial

concerns from officers about queuing from the main entrance of the site onto

Furnival Street have been satisfied with the submission of a supporting

assessment, showing the permeation of pedestrians into the building. The

submitted document is considered to be sufficient to meet the above needs and

would ensure no external queuing on the surrounding public highway.

294. In order to address the pedestrian comfort levels of Furnival Street it is likely

that mitigation would be required to allow the street to cope with the increased

demand. These measures could take the form a raised table along the whole

of Furnival Street from the northern point of the site.

295. However, Furnival street will still need to be left open to vehicles, including

emergency vehicles, for required access to the site, along with maintaining two-

way access for cyclists.

296. The proposal aims to mitigate its impacts by including various public realm

improvement works along the Furnival Street, in conjunction with the City of

London’s Healthy Street aspirations for the area. The general aim of the Healthy

Street plan for Furnival Street is to redesign the street and manage access to

make streets more accessible, engaging and providing safe places for people

to walk, cycle and spend time. The proposal has considered how the application

would intertwine with the City’s scheme and the measures proposed above are

considered to be compliant with the CoL’s Healthy Street aspirations. The

extent of the works to be secured under a Section 278 agreement.

297. In conclusion the proposals impact on the local and wider streets is acceptable,

subject to the outlined changes which will require the applicant to enter into a

Section 278 agreement.

Building Line

Figure 10. Change in Building Line

298. The applicant has proposed to bring the building line on the north side of the

site on Furnival Street back to accommodate the visitors, as outlined from the

red delineation line on Fig 3. This will enable the permeation of visitors into the

site. The section would remain as private given the location underneath and the

protruding first floor.

Taxi movements and drop off

299. The development is expected to generate 15 taxi trips per hour, which would

equate to approximately 8 vehicle movements (based on 2 people per taxi). It

is proposed that all taxi’s would drop off and collect from Holborn, as per

existing highway arrangement.

300. Furnival street is currently used as a cut through for taxis and therefore,

realistically, is likely to be the key area for loading. While the Travel Plan

proposes to minimise vehicle trips on Furnival Street during the development

opening hours this will also need to be backed up by alterations to transport

infrastructure.

301. In order to mitigate the impact from taxis and to prevent vehicles from picking

up and dropping off directly outside of the site, the City’s Healthy Street Scheme

will consider restricting vehicle movements. The scheme could potentially

introduce timed closures or traffic mitigation measures however this is subject

to consultations with the neighbouring properties. The Section 278 therefore,

agrees a scope of work which would include immediate measures, such as

pavement widening, and future collaborative mitigation.

Coaches loading and dwell time

302. The development is expected to generate up to 135 people travelling to and

from the site by coach. With coach capacities varying between 40 to 60

passengers, this would generate between 3-4 coaches arriving to the site each

day.

303. Officers have worked with the applicant who is in agreement that coaches

should be discouraged from traveling to the site and at the point of initial

booking would be advised to seek alternative modes of travel to the site and to

utilise schemes such as the School Party Travel run by Transport for London.

304. A number of locations have been proposed to date for possible loading and

dwelling area for coaches away from the application site. Coaches that must

travel to the site will therefore be advised they are not to dwell or wait for

passengers in the local vicinity of the site.

Servicing

305. The proposed development would be car free, which is considered acceptable.

All vehicle trips generated by the development would likely be associated with

taxis and delivery & servicing. It is estimated that around eight deliveries are

expected to be generated per day.

306. Due to the narrowness and the restricted access of the site on Furnivall Street,

the main delivery point would be from Holborn, specifically outside 8-9 Holborn,

which is set away from residential properties. Access from that section of

highway is currently restricted by a mandatory cycle lane which is in operation

between the times of 7:00 AM and 7:00 PM Monday to Friday. The proposed

solution has been considered by CoL Environmental Health officers who did not

raise any objection, but seek to ensure best practice and ways of minimising

noise to the local residents through the management plans to be secured for

the site in the legal agreement.

307. The applicant therefore has agreed to all deliveries taking place out of hours,

with the main delivery point on Holborn, between the hours of 7:00 PM and

10:00 PM Monday to Friday. In order to secure this agreement, the Service

Management Plan would be secured as an obligation.

308. It is noted that the above arrangements would serve the main cultural use of

the site. Any servicing and deliveries in relation to the proposed bar would be

agreed with Camden officers and would not occur within the City.

100

309. Some limited deliveries, such as refuse collection could be allowed to take

place on Furnival Street for health and safety reasons. The full details of the

scheme are subject to further design work and consultation.

Disabled Motor Vehicle Parking

310. Policy T6.5 of the London Plan and Policy 16.5 of the Local Plan requires

proposals to provide disabled parking for users of the site. However, due to the

constrictive size of the site at surface level, combined with the structurally

restrictive existing supports that link in with access of the lower tunnels,

provision of the disabled parking on site cannot be achieved.

311. In order to provide parking for disabled users, the scheme under the Section

278 agreement on Furnival street, will seek to provide disabled parking in or

close by, in conjunction with the Healthy Streets scheme. As part of this

agreement it shall be outlined that one of the key considerations for the

proposed Highways scheme is to provide disabled car parking near the site.

Travel Plan

312. In order to mitigate the impact on this development a Full Travel Plan is required

to be put in place, which is required to cover the active travel promotions as

well as monitoring for staff and visitors. Travel Plans are an effective tool for

managing visitors, volunteers and employees at a site by helping to promote

sustainable transport and raising awareness of their benefits. It is particularly

important to note that actions discouraging coach use to and from the site

should be integral to targets and actions within this Travel Plan. The

discouragement of coaches has been outlined in the Transport Assessment

Addendum and this states that coach trips would be discouraged wherever

possible.

313. A Travel Plan (TP) is proposed to be secured as a Section 106 planning

obligation in order to meet London Plan policy T4 and Local Plan Policy 16.1.

The travel plan would need to be approved by the CoL prior to occupation and

this would include a requirement for a Travel Plan Co-ordinator to be appointed

no less than 3 months before occupation. The TP should include the action plan

with smart objectives, aiming to encourage the use of the sustainable modes of

transport.

314. Transport for London encourages developers to use the TRICS database for

trip generation predictions. Under the proposed legal agreement the applicant

will also be required to undertake a TRICS after study and provide TfL and the

City of London with the results on completion of the development. TfL would

then be able to update the TRICS database with the trip generation results for

101

the various use categories associated with this development. The necessary

after surveys and results are proposed to be secured by Section 106 agreement

as part of the Travel Plan review and monitoring process.

Cycle Parking

315. London Plan Policy T5 (Cycling) requires cycle parking be provided at least in

accordance with the minimum requirements set out within the London Plan.

Policy T5 (Cycling) requires cycle parking to be designed and laid out in

accordance with the guidance contained in the London Cycling Design

Standards and that developments should cater for larger cycles, including

adapted cycles for disabled people.

316. The level of cycle parking proposed as part of the development for long stay

parking meets minimum London Plan requirement for the cultural use with 12

long stay cycle parking spaces are proposed as being provided. At ground level

is proposed 3 Sheffield stand providing 3 general spaces and 1 fully accessible

space. At basement level which is accessible via a large lift at the secondary

entrance is proposed the remaining 8 spaces with the provision of two-tier

Joster Stand. Provision of additional 2 spaces is also required to cover for the

requirements of the bar at the same basement location. Details of the cycle

stores have been secured by condition.

317. The accessible Sheffield stand is welcomed and meets the London Plan

requirement for 5% of long stay parking to be accessible to disabled bicycle

users. It is also considered that the other long stay cycle parking meets cycle

design guidance standards and is acceptable. Officers encourage the provision

of an accessible cycle bay at the basement storage and require the inclusion of

a range of cycle space types split across the two bike stores by way of condition.

Furthermore, the proposed application also seeks to provide one accessible

shower at the staff accommodation at fourth level and another one at basement

level where the rest of the bikes are to be stored. In addition, provision of lockers

for staff is made in the office area and the basement cycle store. The supporting

facilities are considered acceptable for the 14 long stay cycle spaces.

318. Short stay cycle parking requirements for similar uses as outlined in the London

Plan is 1 space per 100sqm. If this requirement is applied to the total size of the

development, there would be a requirement to provide 125 short stay cycle

parking spaces.

319. Due to the constraints of the development site, the constricted floor layout

required for queueing and access to the tunnels and the large number of cycle

spaces required it is not possible to provide spaces within the development

itself. Nevertheless, it is proposed that the Section 106 legal agreement would

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secure the provision of cycle parking spaces on the public highway, including

improvements to the cycle infrastructure in the vicinity of this development.

Camden Officers have agreed to provide 20% of the total requirement on their

public highway. Therefore, subject to this provision the application is considered

acceptable on this basis.

Management and Construction Impacts on the Public Highway in the local area

320. The proposal would involve a significant amount of demolition and construction

works. This would generate a large number of construction vehicle movements

during the overall construction period. Demolition and construction at ground

level as well as access to works below the surface would require cross

boundary access between two authorities, the London borough of Camden and

the City of London corporation. It is also important to note that works would be

conducted under Transport for London's strategic road network on high

Holborn, as well as close to London Underground assets. All of the above

mentioned stakeholders would be required to agree construction logistic plans

prior to the commencement of works.

321. The proposed works would likely have a significant impact on the operation of

the public highway if not managed effectively. Officers primary concern is public

safety but would also need to ensure that construction traffic does not create

(or add to existing) traffic congestion or impact on the road safety or amenity of

other highway users. The proposal is also likely to lead to a variety of amenity

issues for local people (e.g. noise, vibration, air quality) during the construction

stage.

322. London Underground while not objecting has asked to impose a condition for

approval to safeguard their assets from ground movement impacts during

demolition and construction works.

323. A preliminary Construction Logistic Plan (CLP) has been submitted in support

of the planning application and this provides useful information to outline the

proposed works and methodology.

324. It has been proposed that the majority of the demolition and construction works

would be carried out from Furnival Street within the CoL boundary, with an

additional secondary access from Fulwood place in the London borough of

Camden. Furnival street is located within a gyratory network, that contains

narrow roads with tight corners and will have limitations on vehicle access

through the area. It should be noted that the final admission of the construction

logistic plans would need to provide details and significant consideration on how

access would be managed.

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325. A more detailed CLP and DLP would be secured by via condition with a

requirement to be prepared once a Principal Contractor has been appointed,

which would need to be in line with TfLs Construction Logistics Plan Guidance.

326. The City of London needs to ensure that the development can be implemented

without being significantly detrimental to the amenity or the safe and efficient

operation of the highway network in the local area. Therefore, a CLP and a DLP

is proposed to be secured as via condition to ensure the construction and

demolition of the site is in accordance with The London Plan Policy T7 and

DM16.1 of the CoL Local Plan. This would provide a mechanism to

manage/mitigate the impacts which the proposed development would have on

the local area. The CLP would need to be approved by the CoL prior to works

commencing on site.

Waste Management

327. Local Plan policies CS17 and DM17.1 require sustainable choices for waste

and for waste facilities to be integrated into building design. Draft City Plan

Policies S16 and CE1 require developments to consider circular economy

principles.

328. A Waste Management Plan has been submitted as part of this application which

sets out the servicing and waste collection strategy. The proposed development

would be serviced on site with all deliveries and refuse collection activities being

carried out at ground floor level, accessible via Furnival Street. These

arrangements serve all activities taking place within the building at Furnival

Street and underground. The bar would be served via Fulwood Place, in LB of

Camden.

329. The City’s Cleansing team were consulted and raised some initial concerns of

health and safety regarding the internal transfer of bins form the basement level

1 to the ground level. An updated Waste Management Plan has since been

prepared to address these concerns and was submitted to CoL for review. The

Cleansing team has reviewed the responses and confirmed that the proposed

waste storage and collections facilities comply with CoL’s requirements and no

objections were raised.

330. The waste storage is considered to comply with Local Plan policies CS17 and

DM17.1 and draft City Plan policies S16 and CE1. An obligation for the

Servicing and Delivery arrangements of this development would be secured in

the Section 106.

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Transport Conclusion

331. The proposals are acceptable in transport terms, subject to the necessary

conditions and obligations as discussed above.

332. Nos. 38-39 and 40-41 Furnival Street represent a constrained site within a

tightly knitted, urban section of the City of London. Furnival Street itself is also

restricted in terms of its size, design and current vehicular and pedestrian

usage. The proposed development would significantly increase the use of both

the public realm and the highway that is located immediately adjacent to the

site. However, the submitted documentation details appropriate mitigation and

measures that would reduce the impact on the surrounding highway network

while also promoting active and sustainable transport.

333. The following S106 planning obligations and conditions would therefore need

to be secured:

• The applicant has agreed to enter into a S278 agreement, which would

intertwine with the City of London’s Healthy Street plan for the area.

These plans would be delivered in conjunction with the City’s aspiration

for the area and mitigate the impact of the proposed development by

delivering a substantial uplift in the quality of the surrounding highway

network. The submitted drawing, titled ‘Vision zero/Healthy Streets Plan’

ref: 70106185-TP-SK-18 rev: P02, includes a shaded area in green,

showing the extent of S278 works, and agreed with the applicant. The

works are subject to further design and consultation.

• Any design would also need to address the City of London's key

transport objectives for the area, which is to:

i. provide a healthy streets scheme with consideration to providing

a shared surface, increased footpath, additional street furniture,

additional blue badge parking and further public realm

improvements

ii. improve sustainable transport to and across the area

iii. provide additional greening

iv. maintain the contra flow cycle lane

v. maintaining access for emergency vehicles

• Contributions towards cycle infrastructure.

• Travel Plan (TP) s106 agreement shall state that the TP for all users of

the development shall be approved prior to occupation of the site.

• Delivery and Servicing Management Plan (DSMP). The Section 106

agreement shall state that the DSMP shall be approved prior to the first

occupation of the site and the approved plan shall be followed.

• A condition to secure a Construction Logistic Plan (CLP). The condition

shall state that the CLP shall be approved prior to any works starting on

site and the approved plan shall be followed thereafter. It should also

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restrict HGV movement to and from the site to with in the hours of 9:30

to 16:30 Monday to Friday, 8 till 13:00 Saturdays and fully restrict

movement on Sundays and Bank Holidays unless agreed with the CoL

in advance.

• S106 obligation - requiring the submission of an Event Management

Plan (EMP) to no less than 12 weeks prior to each event commencing.

The Highway Authority (HA) will then have at least 21 days to request

alterations or object to any event.

• A condition requiring the details of the long stay cycle parking spaces

for the development. The spaces to be designed to London Cycle Design

Standards, implemented prior to occupation, maintained and retained as

part of this development thereafter.

Daylight, Sunlight and Overshadowing

334. Policy D6(d) of the London Plan states that the design of development should

provide sufficient daylight and sunlight to surrounding housing that is

appropriate for its context, whilst avoiding overheating, minimising

overshadowing, and maximising the usability of amenity space.

335. Local Plan Policy DM10.7 ‘Daylight and Sunlight’ seeks to resist development

which would reduce noticeably the daylight and sunlight available to nearby

dwellings and open spaces to unacceptable levels, taking account of the

Building Research Establishment (BRE) guidelines.

336. Draft City Plan 2040 Policy DE7 states that development proposals will be

required to demonstrate that the daylight and sunlight available to nearby

dwellings and open spaces is appropriate for its context and provides

acceptable living standards taking account of the Building Research

Establishment’s guidelines.

337. Paragraph 3.10.41 of the Local Plan indicates that BRE methods will be applied

consistent with BRE advice that ideal daylight and sunlight conditions may not

be practicable in densely developed city centre locations. Paragraph 3.10.41 of

the Local Plan and Policy HS3 of the Draft City Plan states when considering

on the amenity of existing residents, the Corporation will take into account the

cumulative effect of development proposals.

338. The BRE guidelines “Site layout planning for daylight and sunlight - A guide to

good practice” (2022) present the following methodologies for measuring the

impact of development on the daylight and sunlight received by nearby existing

dwellings and any existing non-domestic buildings where the occupants have

a reasonable expectation of natural light:

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• Daylight: Impacts to daylight are measured using the Vertical Sky

Component (VSC) method: a measure of the amount of sky visible from

a centre point of a window; and the No Sky Line (NSL) method, which

measures the distribution of daylight within a room. The BRE advises

that this measurement should be used to assess daylight within living

rooms, dining rooms and kitchens; bedrooms should also be analysed

although they are considered less important. The BRE Guide states that

diffuse daylighting of an existing building may be adversely affected if

either the VSC measure or the daylight distribution (NSL) measure is not

satisfied.

• Sunlight: Impacts to sunlight are measured using Annual Probable

Sunlight Hours (APSH) for all main living rooms in dwellings if they have

a window facing within 90 degrees of due south. The guidelines consider

kitchens and bedrooms to be less important, but that care should be

taken to not block too much sun from these rooms.

Interpreting results

339. In undertaking assessments, a judgement can be made as to the level of impact

on affected windows and rooms. Where there is proportionately a less than 20%

change (in VSC, NSL or APSH) the effect is judged as to not be noticeable.

Between 20-30% it is judged to be minor adverse, 30-40% moderate adverse

and over 40% major adverse. All these figures will be impacted by factors such

as existing levels of daylight and sunlight and on-site conditions. It is for the

Local Planning Authority to decide whether any losses result in a reduction in

amenity which would or would not be acceptable.

Overshadowing

340. Overshadowing of amenity spaces is measured using sunlight hours on the

ground (SHOG). The BRE guidelines recommends that the availability of

sunlight should be checked for open spaces including residential gardens and

public amenity spaces.

Assessment

341. An assessment of the impact of the development on daylight and sunlight to

surrounding residential buildings and public amenity spaces has been

undertaken in accordance with the Building Research Establishment (BRE)

Guidelines using daylight (VSC, NSL) and sunlight (APSH) assessment

methodologies and considered having regard to policy D6 of the London Plan,

policy DM 10.7 of the Local Plan and policy DE7 of the draft City Plan 2040.

Policy D6D of the London Plan 2021 states that the design of development

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should provide sufficient daylight and sunlight to new and surrounding housing

that is appropriate for its context whilst avoiding overheating, minimising

overshadowing and maximising the usability of outdoor amenity space. The

BRE guidelines can be used to assess whether daylight or sunlight levels may

be adversely affected. Local Plan policy DM10.7 states that development which

would reduce noticeably the daylight and sunlight to nearby dwellings and open

spaces to unacceptable levels taking account of BRE guidelines, should be

resisted. The draft City Plan 2040 requires development proposals to

demonstrate that daylight and sunlight available to nearby dwellings and open

spaces is appropriate for its context and provides acceptable living standards

taking account of its context.

342. The report has identified the following sensitive receptors:

• 1 to 6 Dyers Buildings (residential);

• 34-37 Furnival Street (residential);

• 10 Furnival Street (office/commercial); and

• 10-12 and 14-18 Holborn (office/commercial).

343. The report states that due to window locations and views across the Site, only

1 to 3 Dyers Building have been considered relevant for assessment for daylight

and sunlight. However, several of the properties within 4 to 6 Dyers Buildings

have windows facing directly towards the development site, which have not

been included for assessment. Officers requested to undertake assessment of

these properties. In response, a VSC assessment was undertaken by GIA on

the windows of 4-6 Dyers Buildings facing the site.

344. The assessment also excludes the residential premises within Sterling House,

12 Dyers Buildings which have windows facing the site, which have not been

identified as sensitive receptors. However, given the height and scale of the

proposal and the separation distance of this property from the site these

windows are not considered relevant for assessment.

345. The residential premises immediately to the south of the proposed development

site, at 34-35 and 36-37 Furnival Street, have not been assessed because their

windows are not orientated within 45 degrees of the uplift of the proposed

development in line with the advice set out within the BRE (2022) Guidelines.

346. The criteria set out in Building Research Establishment (BRE) Guidelines: Site

Layout Planning for Daylight and Sunlight (2022) are used as guidance in

forming a judgement on whether the design of the proposed development

provides for sufficient daylight and sunlight to surrounding housing and is

appropriate for its context (London Plan policy D6D), and when considering

whether the daylight and sunlight available to nearby dwellings is reduced

noticeably to unacceptable levels (Local Plan policy DM 10.7) and in

considering whether daylight and sunlight is appropriate for its context and

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provides acceptable living standards (draft City Plan policy DE7) it is

appropriate to have regard to the assessment carried out in accordance with

the BRE guidelines.

347. Two commercial receptors have been identified as listed above. However, the

impact on their daylight and sunlight has not been assessed. Local Plan

Strategic Policy CS10 seeks to ensure that buildings are appropriate to the

character of the City and the setting and amenities of surrounding buildings and

spaces. The BRE daylight guidelines are intended for use for rooms adjoining

dwellings where daylight is required and may also be applied to non-domestic

buildings where the occupants have a reasonable expectation of daylight; this

would normally include schools, hospitals, hotels and hostels, small workshops

and some offices. The BRE sunlight guidelines are intended for dwellings and

for non-domestic buildings where there is a particular requirement for sunlight.

The proposed increase in height to 38-39 Furnival Street would be likely to have

a minor impact on daylight to Chancery Exchange, 10 Furnival St. (opposite), it

is however worth noting that the proposed development would still be lower in

height (by over 3 metres) (than the building opposite at 10 Furnival St.). In this

case officers do not consider that the offices surrounding the application site

fall into the category contemplated by the BRE where occupiers have a

reasonable expectation of daylight, and officers do not consider that the

surrounding offices have a particular requirement for sunlight. The dense urban

environment of the City, is such that the juxtaposition of commercial buildings

is a characteristic that often results in limited daylight and sunlight levels to

those premises. Commercial buildings in such locations require artificial lighting

and are not reliant on natural daylight and sunlight to allow them to function as

intended, indeed many buildings incorporate basement level floorspace or

internal layouts at ground floor and above without the benefit of direct daylight

and sunlight. As such the daylight and sunlight impact is not subject to the same

policy test requirements as residential premises.

348. There are no nearby gardens or amenity areas directly to the north of the

development that would require a sunlight / overshadowing assessment.

Daylight and Sunlight

349. Daylight has been assessed for both Vertical Sky Component (VSC) and No

Sky Line (NSL), these are complementary assessments for daylight: VSC is the

measure of daylight hitting a window, NSL assesses the proportion of a room

in which the sky can be seen from the working plane. Daylighting will be

adversely affected if either the VSC of the NSL guidelines are not met.

350. The BRE criteria state that a window may be adversely affected if the VSC

measured at the centre of a window is less than 27% and less than 0.8 times

its former value (i.e. experiences a 20% or more reduction.) In terms of NSL, a

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room may be adversely affected if the daylight distribution (NSL) is reduced

beyond 0.8 times its existing area (20% or more reduction).

351. Both the London Plan 2021 and the draft City Plan 2040 require daylight and

sunlight to residential buildings to be appropriate to their context, and this will

need to be considered alongside reductions in daylight and sunlight assessed

under the BRE methodology.

352. The applicant has submitted a Sunlight and Daylight Assessment and a

Daylight and Sunlight Addendum letter.

1 to 3 Dyers Buildings

Daylight

353. 1 to 3 Dyers Buildings is a five-storey residential development located

immediately to the east of the application site. Given the close proximity of this

development to the application site, which are effectively separated by a light

well, the existing daylight levels are low, particularly at basement, ground, first

and second floor levels. The daylight and sunlight report has assessed 59

windows serving 18 rooms within this development for daylight.

Windows: Vertical Sky Component

354. Of the 59 windows assessed, 35 would meet the BRE guidelines for skylight

visibility (VSC). Of the 24 windows which fall below the guidance for VSC, eight

experience proportional VSC reductions between 20% to 30% (minor adverse

impact), nine between 30%-40% (moderate) and seven in excess of 40%

(major).

355. Of the 24 windows that fall below the BRE recommendations, 18 serve known

living rooms. Four remaining windows serve rooms for which the use is

unknown but are assumed to be habitable. A further two rooms serve bedrooms

which are considered to have a lower requirement for natural light.

356. It is noted that the VSC levels to the windows on the basement, ground, first

and second floors are exceptionally low in the existing scenario (the majority of

windows experience a VSC of below 10% with some as low as 0-0.3%). These

windows are therefore more susceptible to greater proportionate reductions in

skylight visibility. So, whilst these windows see reductions in VSC over that

which is recommend by the BRE guidelines, the absolute reductions in VSC

are generally quite small (i.e. between 0-4.3%). Of the 24 windows that fall

below guidance, nine see an absolute VSC reduction of less than 1%. A further

eight windows see no more than a 3% absolute change for VSC, and the

remaining eight windows see no greater than a 5% absolute change in VSC.

The report points out that absolute reductions of 3% have been referenced in

past appeals as “virtually imperceptible”, and absolute reductions of 5% have

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been described as “barely noticeable”. As such, while there is identified

breaches of the BRE Guidance, the existing level of VSC is exceptionally low

that any minimal change would result in the windows falling below the guidance.

The reductions proposed however are modest in reduction, would fall under the

imperceptible category and as such are assessed as acceptable.

Rooms: Daylight Distribution

357. Of the 18 rooms assessed, 13 would meet the BRE guidelines for daylight

distribution (NSL). Of the five rooms that fall below the guidelines, two would

experience a percentage alteration of between 30%-40% (moderate adverse

impact), and three would experience a percentage alteration in excess of 40%

(major adverse impact).

358. Two of the five rooms (F00, R2 and R3) assessed for daylight distribution (NSL)

that fall below the guidelines serve bedrooms, which have a lower requirement

for daylight. These rooms would experience proportionate reductions in daylight

distribution of 32.1% and 67.7%.

359. The remaining three rooms are a ground floor living room (F00, R4), and LKDs

on the first and second floors (F01/R2 and F02/R2). The living room on the

ground floor would experience a reduction in daylight distribution from 15.4%

to 8.5% of the room having a view of the sky. The LKD on the first floor sees a

reduction in daylight distribution/sky visibility (NSL) from 30.6% to 13.5% and

the LKD on the second floor sees a reduction in sky visibility from 51.1% to

35.3%. Although the daylight distribution analysis is based on assumed layouts

and the results carry uncertainty and the actual impacts may be different in the

existing rooms, it is considered that the impact would be acceptable given that

the impact in minor adverse to a limited number of rooms.

Sunlight

360. 35 windows have been identified as eligible for assessment for sunlight. The

report demonstrates that all the windows assessed would meet the BRE

Guidelines for sunlight (APSH) with the proposed development in place.

4-6 Dyers Buildings

361. A VSC assessment was undertaken in GIA’s Phoenix application on the

windows of 4-6 Dyers Buildings facing the Site. This showed no alterations

beyond 20%, therefore all windows would be BRE compliant and no further

technical assessments were deemed necessary. Furthermore, given the

proposed massing of the building and separation distances to the residential

property the impact in terms of daylight and sunlight is considered to be

acceptable in this instance.

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10 Furnival Street (Chancery Exchange) and 10-12 &14-18 Holborn

362. It is not considered that the commercial buildings at 10 Furnival Street, 10-12

and 14-18 Holborn are of a nature that requires exceptional daylight and

sunlight levels mainly due to its location in a dense urban environment and the

type of accommodation which is expected to be largely used during office hours

and being relied upon artificial lighting throughout the day. As such the daylight

and sunlight impact is not subject to the same policy test requirements as

residential premises. The dense urban environment of the City, is such that the

juxtaposition of commercial buildings is a characteristic that often results in

limited daylight and sunlight levels to those premises. On that basis, the

assessment has not considered the surrounding commercial buildings, which

officers found an acceptable approach.

Conclusion

363. The assessment results included in the daylight and sunlight assessment report

submitted with the application demonstrate a moderate to hight level of BRE

compliance. Where there are technical breaches of the BRE guidelines, they

can be partly attributed to the low existing levels of daylight received by the

neighbouring residential properties assessed, which would be sensitive to

proportionately higher percentage reductions as a result of the low existing

levels of daylight.

364. Overall the daylight and sunlight available will be sufficient and appropriate to

the context, and acceptable living standards would be maintained. As such, the

overall impact (including the degree and extent of harm) is not considered to be

such that it would conflict with, London Plan policy D6, Local Plan Policy

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

Light Pollution

365. Local Plan Policy DM15.7 and draft City Plan 2040 Policy DE8 require that

development should incorporate measures to reduce light spillage particularly

where it would impact adversely on neighbouring occupiers, the wider public

realm and biodiversity.

366. It is considered that only the front (west) facade of previous 40-41 Furnival

Street building would be designed with glass bricks creating a level of

translucency which would create light spill from internal lighting towards the

occupiers facing the west side of the building which is relevant to the

commercial building at 10 Furnival Street. There would be no translucent

elevations opposite the residential buildings and therefore light pollution has not

been considered a material factor in the submitted Daylight and Sunlight

Assessment.

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367. To ensure that appropriate lighting levels are achieved externally and internally

including at roof terrace level, and to mitigate impacts of public realm and

nearby residential properties, a condition for the submission of relevant details

of a Lighting Strategy and Technical Lighting Design would be required to be

submitted for approval. This will have to be submitted prior to the occupation of

the building and the details shall accord with the requirements as set out in the

Lighting SPD, including but not limiting to details of all external, semi-external

and public-facing parts of the building and of internal lighting levels and how

this has been designed to reduce glare and light trespass.

Air Quality

368. Local Plan 2015 policy CS15 seeks to ensure that developments positively

address air quality. Policy DE1 of the draft City Plan 2040 states that London

Plan carbon emissions and air quality requirements should be met on sites and

policy HL2 requires all development to be at least Air Quality Neutral,

developers will be expected to install non-combustion energy technology where

available, construction and deconstruction must minimise air quality impacts

and all combustion flues should terminate above the roof height of the tallest

part of the development. The requirements to positively address air quality and

be air quality neutral are supported by policy SI1 of the London Plan.

369. The application includes an Air Quality Assessment which addresses the likely

impact of the proposed development on air quality as a result of the construction

and the operational phases of the development.

370. The proposed development will be car free and heating will be through air

source heat pumps which is welcomed. The development meets both the

transport and building emissions benchmarks for the Air Quality Neutral

Assessment. The proposal includes a visitor attraction in underground tunnels

where levels of indoor air pollution should be minimised.

371. The City’s Air Quality Officer has reviewed the proposal and has raised no

objections subject to conditions and informatives in respect of generators

combustion flues, Non-Road Mobile Machinery Register, and the Indoor Air

Quality.

372. In light of the above and subject to conditions, the proposed development would

accord with Local plan policy CS15, policies HL2 and DE1 of the draft City Plan

2040 and SI1 of the London Plan which all seek to improve air quality.

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Impact on amenity (Noise, Disturbance and Overlooking)

373. London Plan Policy D13 requires the proposed development to mitigate noise-

generating uses and Policy D14 aims to avoid significant adverse noise impacts

on health and quality of life. Local Plan Policies DM3.5 and DM15.7, seek to

ensure that operational noise does not adversely affect neighbours and that

any noise from plant should be at least 10dBa below background noise levels.

Policies S1 and HL3 of the Draft City Plan 2040 requires that noise does not

adversely affect nearby land uses, supporting a healthy and inclusive City.

374. Local Plan Policy DM21.3 and Emerging Policies HS3 and DE4 seek to protect

the amenity of residential properties from uses which would cause undue noise,

disturbance and requires new development near existing dwellings to

demonstrate adequate mitigation measures to address the impact.

Development proposals are expected to be designed to avoid overlooking to

adjacent residential accommodation in line with Policies DM10.3 and DM21.3

of the Local Plan and Policies HS3 and DE4 of the Draft City Plan 2040.

375. An Acoustic Assessment has been submitted which provides an outline

assessment of the impact of noise and vibration from the mechanical plant on

the surrounding area. In addition, operational use noise and construction

impacts have been considered.

376. The nearest noise sensitive receptors that have been identified in the

assessment are the residential properties to the south and east of the site, 36-

37 Furnival Street and 1-6 Dyer’s Buildings, and the commercial occupiers to

the west, 10 Furnival Street and 9 Holborn and to the north at 14-18 Holborn.

Noise surveys have been conducted to obtain the background noise levels of

these properties from two measurement positions. Tabulated results are

provided within the submitted Acoustic report.

377. Plant equipment serving the building and the tunnels would be housed within

38-41 Furnival Street building. The new building would house the primary

entrance to the cultural exhibition space, ancillary office accommodation and

retail spaces at upper levels, basement plant rooms, an air handling unit (AHU)

plant room and a roof plant room situated at the northern roof level which forms

the highest part of the proposed building. The proposed plant would be subject

to a condition that require noise levels to be compliant with the City’s standard

of at least 10 dBa below background noise level as well as a condition to

minimise transmission of structure borne sound or vibration to any other part of

the building.

378. The impacts of the demolition and construction work on the surrounding area

would be controlled by conditions requiring the submission of schemes of works

to protect neighbouring occupiers. Noise and vibration mitigation, including

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control over working hours and types of equipment to be used would be

included in a construction management plan to be secured by condition, and

freight movements would be controlled through the Construction Logistics Plan,

secured by condition. These would need to demonstrate compliance with the

City’s Code of Practice for Deconstruction and Construction Sites and the

Mayor of London’s Construction Logistics Plan Guidance.

379. The impact of the proposed development in terms of noise associated with the

operational stage of the cultural use (i.e. the actual underground use) has been

considered to be negligible based on the fact that the main visitor space is

provided underground and therefore away from nearby noise receptors. Since

the earth has enough bulk to keep noise from escaping, noise breakout from

the cultural exhibition spaces through the ground is therefore not regarded as

a problem. It is however acknowledged that the proposed development has the

potential to increase activity at street level with visitors arriving to the venue and

exiting through from the upper levels of the gift shop back to the street level.

Officers acknowledge that increased footfall in the area would likely increase

the noise generated and disturbing to nearby properties. For that reason, the

submitted Transport Assessment has produced a robust worst-case scenario

based on predictions for the busiest day on site. It is estimated that a standard

visitor will spend a total of 1 hour and 20 minutes on the site. Model outputs

have tested the operation of the ground floor site entrance on Furnival Street to

understand if there will be any external queueing that would have adverse

impacts to the amenity of neighbouring occupiers. The dynamic model takes

into consideration different parameters proposed to mitigate impact on the

highway such as the proposed footway widening in front of the principal

entrance that has been designed to maximise any pedestrian queues within the

curtilage of the site and the proposed operational and management plan of the

venue (including the capacity of the visitor lifts, security check points and

processing time for ticketing). The results demonstrate that queuing would not

be expected into Furnival Street at the tested scenario. Notwithstanding that, a

worse-case scenario of 20% uplift in visitor numbers has been tested with all

other parameters taken into account and results still showed no external

queuing on the street.

380. In addition, it has been logically assumed that visitors arriving and leaving the

site would most like be coming from Holborn where public means of transport

and cycle/motorbike parking facilities are available alongside other commercial

uses such as F&Bs which people can visit before or after their booked visit to

the site. It is therefore considered that visitors arriving and leaving the cultural

exhibition space would not create significant queues at street level or use the

part of Furnival Street that extends southern to the site which would have likely

cause some disturbance to nearby occupants.

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381. The existing buildings on Furnival Street are either vacant or serve a modest

scale office. The proposed change of use to a cultural facility, by its very nature,

would likely increase the pedestrian and vehicular movement within the

immediate vicinity. This would be particularly pertinent for the residents of 36-

37 Furnival Street and 1-6 Dyer’s Buildings. While the highway modelling

described above confirms limited use of the street for significant queues,

officers are cognisant there would likely be an increase in general noise and

disturbance to the surrounding properties from increased activity. This is

however the case with all similar cultural use applications that are intending to

draw visitors to the site and officers consider that the noise increase would not

vastly differ from that already found within the immediate locality (for example

on Holborn or other surrounding uses). Care has been taken to prevent

significantly detrimental impacts occurring to neighbours, through constrained

servicing times and event management conditions, however the potential

increase in general human activity is considered to be acceptable and

proportional to this highly urbanised, constrained setting.

382. The application also includes a Security Strategy that outlines the security

measures to be implemented on site that would support the smooth operation

of the development. The site would benefit from a comprehensive management

team, including on-site staff such as receptionist and security staff who would

be present throughout the site’s operational hours. The building would benefit

from Video Surveillance Systems (VSS) monitored by on-site staff at a Security

Control Room (SCR) to aid in the management of the building and surrounding

spaces. As such, officers consider that adequate management of the

development would likely ensure no adverse impacts are cause due to

increased pedestrian movements around the site or increased number of users

of the building. Details of an Operational Management Plan would be secured

in the Section 106.

383. The proposal involves the operation of two separate cultural exhibition spaces

within the tunnels. The Heritage Exhibition space forming the permanent visitor

attraction would operate on a daily basis, and the Cultural Exhibition space

which would be available for temporary exhibitions along the year and would

operate with programmed events. The Cultural Plan estimates approximately

12 events taking place intermittently over a year. Further details on event

programming and minimising the impact of events on amenity in terms of

dispersal of visitors at night time and noise and disturbance would be required

as part of the Public Access and Event Management Strategy that would be

secured in the Section 106.

384. The proposed roof terrace at level four, would be used by the working staff and

no members of the public would be allowed to access it. The terrace would

measure 40sqm area with a 1.4m high boundary and embedded plant floor

along its perimeter to provide privacy. The residential properties to the east and

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south side of the terrace would be further protected from overlooking by the

proposed frosted glass screen of 1.4m height and excessive greening against

the eastern boundary of the terrace. Notwithstanding that, it is noted that the

terrace is set back from the eastern side as the east elevation has been

designed with an inclination to this portion of the building. This design provides

greater distance from the adjacent residential properties and reduces the level

of potential overlooking drastically. An external staircase is proposed to the

southeast corner of the terrace to be used only as a fire escape. An alarmed

gate would be in position to ensure that these stairs are only used in an

emergency. The Environmental Health team has recommended a condition to

restrict the use of the proposed roof terrace between the hours of 20:00 on one

day and 08:00 on the following day and not at any time on Sundays or Bank

Holidays, other than in the case of emergency in order to safeguard the amenity

of the nearby occupants. Officers consider the proposed privacy measures

sufficient to safeguard the privacy of the surrounding dwellings and recommend

a condition for the approval of details in relation to the proposed screening and

planting of the roof terrace.

385. It should be noted that the proposed bar and the programmed school trips to

the Heritage Exhibition space would access the site solely through the

secondary entrance at High Holborn only, which is located within London

Borough of Camden. Therefore, the relevant Local Planning Authority would be

responsible to control noise and disturbance to safeguard the amenity of

neighbouring properties around the secondary entrance.

386. Due to there being nearby sensitive receptors it is also considered necessary

to restrict overnight servicing, therefore a condition will be included to ensure

no servicing of the development shall take place between 23:00 and 07:00

Monday to Saturday and between 23:00 on Saturday and 07:00 on the following

Monday and on Bank Holidays.

387. Subject to the imposition of conditions, in particular those relating to noise from

plant and schemes of works to protect against the impacts of demolition and

construction and event management, it is considered that the application is in

accordance with London Plan Policies D13 and D14, Local Plan Policies

DM3.5, DM10.3 DM15.7 and DM21.3, and Emerging Policies S1, HL3, HS3

and DE4 of the draft City Plan 2040.

Health Impact Assessment

388. Policy HL9 of the draft City Plan 2040 requires major developments to submit

a Healthy City Plan Checklist to assess potential health impacts resulting from

proposed developments.

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389. The applicants have submitted a Rapid Health Impact Assessment (HIA) using

evidence and assessments of impact within documents submitted with the

planning application. The London HUDU Planning for Health Rapid HIA Tool

Fourth Edition (October 2019) recommends the assessment of potential health

impacts under 11 different broad health determinants. The HUDU checklist has

been satisfactorily completed and there are not expected to be any adverse

health impacts resulting from the proposed development.

390. The Assessment concludes that the development would have an overall

positive impact on health. Positive impacts include:

• Improvements to the public realm along Furnival Street to be secured under

Section 278;

• A Heathy Street approach would be adopted;

• Reuse an existing infrastructure and create accessible arrangements for

everyone to have the opportunity to enjoy;

• Provision of a cultural space including heritage exhibition space;

• A car-free development with cycle parking proposed on and off site;

• Inclusivity and Accessibility at the heart of the Cultural Plan;

• Design out crime practices;

• Access to local employment and training opportunities as well as inclusive

local procurement to be secured under Section 106;

• An outdoor amenity space is provided for the staff, greenery is incorporated

wherever possible and active travel is promoted.

391. The HIA does not identify any negative impacts. However, officers considered

that some impacts would arise during the construction and operational phases

such as dust, noise, vibration and odours, and air pollution caused by traffic.

These impacts would be mitigated by the requirements of relevant conditions

and Section 106 obligations. For example, by implementing a Delivery and

Servicing Plan that ensures sustainable modes and operation of freight; a

Construction Environmental Management Plan and Construction Logistics

Plan; securing local employment and training opportunities; and other air quality

and environmental health mitigations addressed elsewhere in the report.

392. The HIA assessment adequately addresses potential health impacts and

therefore the development complies with draft City Plan HL9.

Sustainability

Circular Economy

393. London Plan Policy SI7 (‘Reducing waste and supporting the circular economy’)

sets out a series of circular economy principles that major development

proposals are expected to follow. The Local Plan Policies CS15 and DM 17.2

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and the emerging City Plan 2040 Policy S16 set out the City’s support for

circular economy principles.

394. The London Plan Policy GG5 states that “Creating a low carbon circular

economy, in which the greatest possible value is extracted from resources

before they become waste, is not only socially and environmentally responsible,

but will save money and limit the likelihood of environmental threats affecting

London’s future”

395. ‘Circular economy’ is defined within the London Plan’s glossary as, “An

economic model in which resources are kept in use at the highest level possible

for as long as possible in order to maximise value and reduce waste, moving

away from the traditional linear economic model of ‘make, use, dispose’”.

Development Proposal

396. The full extent of the tunnel network is proposed to be retained and refurbished

(>90% of material retained). No.s 38-39 and 40-41 Furnival Street are proposed

for demolition due to the practicalities of construction and challenges of plant

arrangement. Further details are included under Carbon Options Appraisal

below.

397. Fulwood Place (31-33 High Holborn, Camden) would require limited structural

works at basement and ground level only to facilitate visitor access and the

MEP strategy. The building will also be refurbished likely including minor

upgrades to the façade (e.g. glazing replacement and draughtproofing).

Carbon Options Appraisal

398. In line with the CoL Carbon Options Guidance, the application includes a study

of opportunities to retain and refurbish the buildings at no. 38-39 and 40-41

Furnival Street including a carbon assessment. The Carbon Option appraisal

was subject to review by a third-party expert. The reviewer has confirmed that

the optioneering has been carried out in compliance with the Carbon Options

Guidance.

399. The demolition of No. 38-39 (ventilation building) is consistent across all three

options. Due to access requirements (escape stairs, elevator upgrade,

installing plant equipment) and the practicality of construction any retention was

deemed unfeasible. Redevelopment of No. 38-39 would include: new three-

level basement constructed, shaft enlarged down to tunnel entrance and

superstructure rebuilt with one additional floor. Dependent on their condition,

existing bricks and concrete louvres from 38-39 will be reused to rebuild the

replacement.

400. No. 40-41 with its 7-storey concrete frame offers some retrofit potential. Three

options were explored for 40-41 Furnival Street only:

119

Option 1: Major refurbishment

401. All substructure and majority of superstructure retained. Openings created in

level 5 slab to accommodate MEP. One additional floor added. Retained slabs,

columns and possibly foundations strengthened to accommodate openings and

increased loading.

Full Replacement and upgrade of existing façade system.

Option 2: Major refurbishment with vertical extension

402. Substructure and ground to 3rd floors retained. Retained slabs, columns and

possibly foundations strengthened to accommodate increased loading.

Demolition of top 3 levels of superstructure. Replacement structure has no

additional floors but greater height and more efficient space for MEP plant.

Full Replacement and upgrade of existing façade system.

403. Option 3: Full demolition and redevelopment (Development proposal) –

Demolition and rebuild, including new three-storey basement. One-storey

increase in height to no. 40-41.

Figure 11. Optioneering

404. The subterranean nature of the tunnels and proposed cultural use with significant

visitor numbers requires a significant size and quantity of plant equipment for

ventilation and cooling. The existing floor to floor heights of no. 40-41 causes

challenges with accommodating the plant. Some of the plant also requires access

to fresh air and cannot be placed underground. Options 1 and 2 work within these

constraints to propose feasible options which retain existing structure. As the

120

extent of demolition increases, improvements to system efficiencies are expected

due to larger, more flexible plant area at street level.

405. The appraisal of the three scenarios is underpinned by a quantitative assessment

of whole life-cycle carbon emissions of each option. Quantitative results from the

options appraisal for 40-41 Furnival Street only are set out in the table below.

406. The operational energy figure accounts for the Tunnels and Furnival Street

energy use and is based on Category A fit-out which includes regulated

emissions (heating, cooling, lighting) and fixed services (e.g. lifts) but does not

include any tenant equipment such as audio-visual equipment.

407. The majority of energy consumption takes place in the tunnels; however the

plant is predominantly located above ground in the Furnival Street buildings

(with minor variation between options). The operational energy rate per m2 is

divided by the area (GIA, m

) of Furnival Street only in order to align with the

embodied carbon figures which also apply to Furnival Street only.

Table 7. Quantitative results from the options appraisal for 40-41 Furnival Street

Furnival Street Options

Option 1

Major

refurbishment

Option 2

Major refurb

with extension

Option 3

Redevelopment

(Optioneering stage)

1. Gross Internal area (GIA) m²

1979

2125

2589

2. Increase in GIA (over

existing)

10%

35%

60%

3. Substructure % retained by

mass

100%

4. Superstructure % retained by

area

(frame, upper floors, roof,

stairs, ramps)

55%

35%

5. Upfront Embodied Carbon

(A1-A5) (kgCO₂e/m² GIA)

exc. sequestration

666

616

818

6. In-use & End of Life

Embodied Carbon (B-C)

(kgCO₂e/m² GIA) excl. B6 &

464

461

453

7. Life-cycle Embodied Carbon

(A1-A5, B1-B5, C1-C4)

(kgCO₂e/m² GIA)

1,130

1,077

1,271

8. Fuel source

Electricity

9. Operational Energy Use (B6)

of the Tunnels + Furnival St.

(divided by GIAm

of Furnival

St. only) (kWh/m²/yr GIA)

424

395

324

10. Estimated Whole Building

Operational Carbon for

883

822

675

121

building lifetime (B6)

(kgCO₂e/m² GIA)

11. Total WLC Intensity (incl.

B6 & pre-demolition)

(kgCO₂e/m² GIA) Module B7

is not considered

2,026

1,918

1,977

12. Upfront embodied carbon

(A1-A5) (tCO₂e)

1,318

1,309

2,118

13. In-use embodied carbon (B-

C, excl. B6 & B7) (tCO₂e)

918

980

1,173

14. Operational carbon for

building lifetime (B6) Tunnels

+ Furnival St. (tCO₂e)

1,747

1,748

1,746

15. Total WLC (incl. B6 and pre-

demolition) (tCO₂e) Module

B7 is not considered

4,009

4,077

5,117

Figure 12. Estimated Cumulative Carbon Emissions Intensity

500

1,000

1,500

2,000

2,500

0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60

Years (2024-2084)

Estimated Cumulative Carbon Emissions Intensity (kgCO₂e/m² GIA/year)

Major refurbishment Major refurbishment with extension New build

Upfront Embodied

Carbon (PC)

incl.A1-A5 &

demolition

122

Figure 13. Estimated Total WLC

408. The study found marginal differences between the two refurbishment options.

Option 2 is able to achieve better operational performance and reduced upfront

emissions compared to Option 1 due to a more efficient spatial arrangement

and structural grid and the significant strengthening work Option 1 would

require to accommodate the MEP equipment.

409. Total upfront emissions increase by ~1,000,000 kgCO2e from Option 2 to

Option 3. For Option 3, 8% of the total WLC emissions (393,528 kgCO2e )are

attributed to the new substructure works (inc. 3 basement levels).

410. Option 2 and 3 include capacity for additional sustainability benefits such as a

blue roof which allows water retention and an amenity terrace with greening for

the staff.

411. The new build option was chosen as the preferred option based on overall

benefits including “constructability, maintenance and space utilisation.” Fitting

the required plant within the existing structure of 40-41 Furnival St. is

complicated, in part due to restricted floor heights, and would require

strengthening works which have an associated carbon impact. As new build

area increases operational performance is also predicted to improve as plant

specification/layout can be optimised. The new build option offers the greatest

increase in floor area which allows the most flexibility in spatial design terms

and improved facilities including:

a) Improved accessibility and public realm

1,000

2,000

3,000

4,000

5,000

6,000

Major refurbishment Major refurbishment with extension New build

tCO₂e

Estimated Total WLC (tCO₂e)

Estimated existing building demolition A1 - A5 B - C (excl. B6 & B7) B6

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b) Larger area of amenity terrace for staff and additional greening

c) Increased plant space which;

• simplifies provision of future heat network connection

• improves smoke management and stair pressurisation increasing

potential visitor capacity.

Development Proposal

412. The Circular Economy Statement (CES) submitted describes the strategic

approach to the incorporation of circularity principles and actions according to

the GLA Circular Economy Guidance.

413. Approximately 90% of the existing site (by area), including the entire tunnel

network will be retained. 31-33 High Holborn (Camden) will be largely retained.

The Tunnels are being refurbished and adapted to offer an adaptable and

flexible space for future occupants.

414. Outline proposals for incorporating circular economy principles:

• All internal partitions (other than fire lobbies) can be dismounted and

altered for future adaptation

• Materials used will be high quality and high durability to ensure long

service life and minimise the impact of replacement with new Tunnels /

shaft linings designed for a 120-year design life.

• Various building elements, including lifts, glass balustrades, façades, and

steel frames, have been designed for disassembly and recycling

• Services are designed for ease of maintenance and replacement.

Demountable sections have been incorporated into the glass block

façade for plant replacement.

• Generally, all MEP items can be de-commissioned and removed for re-

use or recycling. Ductwork will be installed with flanges and pipework

which will aid in the deconstruction

• Steel frames supporting the first-floor gallery, spiral stair and façade at

Furnival Street can be adapted, strengthened, or finally deconstructed

and reused, if necessary in future.

• Where possible, precast reinforced concrete elements (likely to include

walls, infill panels and Tunnels lining structure) will be discussed with the

contractor at the next stage. These can be prefabricated off site reducing

waste and emissions.

415. Figure 2 of the Circular Economy Statement summarises a list of circular

economy commitments/approaches as follows:

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a) The development aspires to achieve the GLA recommended target of

minimum 20% of all new material being reused/recycled content by value.

b) Specific materials targets for investigation at developed design stage:

• 20% of new materials used should contain reused/recycled content

by value (as per GLA recommended target)

• 25% GGBS in concrete

• 20% recycled content in steel

• 60% recycled content in plasterboard

• 97% recycled content in rebar

• 35% recycled content in aluminium

• Materials from suppliers who participate is responsible sourcing

c) schemes such as the BRE BES 6001:2008 Responsible Sourcing

Standard will be prioritised.

d) Exploring prefabricated and modular design options throughout the

detailed design phase to minimise construction waste; specifically, precast

reinforced concrete (RC) elements, including walls, infill panels, and the

Tunnels lining structure.

416. A pre-demolition and retrofit audit was undertaken to assess which materials

can be re-used or recycled in order to retain maximum value and advise on

material recovery strategies.

417. Total demolition waste forecast is 36,257 Tonnes of with an estimated

recovery rate (reuse/recycling) of circa 95%. Concrete that will be crushed

accounts for 90% of total waste by weight. Plant equipment, furniture and

Bakelite have been designated for possible reuse with all other items

proposed for recycling at a raw material level. Further details will be provided

at detailed design stage.

418. The ‘material recovery options’ table indicates how materials will be

segregated and which will be sent to specialist recyclers for further

processing. The development will submit a Waste Management Plan and

advise the contractor of the targets to be achieved.

419. A number of specific elements have been earmarked for reuse, depending on

their condition:

• cast iron shaft rings repurposed as lift shaft cladding

• shaft linings will be reused as architectural elements lining the new stair

and lift shaft.

• Brickwork and concrete louvres to rebuild 39 Furnival St.

125

420. Updates to the detailed Circular Economy Statement are required by condition,

prior to commencement (excluding demolition), and post completion, in line with

the Mayor’s guidance on Circular Economy Assessments. The statement is to

include details of elements recovered for reuse on/off site and the demountable

internal partitions.

BREEAM

421. Emerging City Plan 2040 Policy DE1: Sustainability Standards requires

proposals for major development to achieve a minimum BREEAM rating of

“Excellent” (70% of credits) and aim for “Outstanding” (80% of credits) against

the current, relevant BREEAM criteria at the time of application, obtaining

maximum credits for the City’s priorities (energy, water, pollution, and materials)

as well as the climate resilience credit in the Waste category.

422. Given the specific nature of the development and following discussion with CoL

officers and BREEAM the assessment type selected is: BREEAM Non-

Domestic Refurbishment and Fit Out 2014 Bespoke.

423. The development is targeting a high-scoring ‘Very Good’ rating, which does not

meet City Plan policy of minimum ‘Excellent’. The pre-assessment results show

a target score of 67% and a potential score of 81% (Outstanding) if all the

additional credits identified were achieved. This demonstrates good scope to

achieve an ‘Excellent’ rating as a minimum. Options for additional credits are to

be incorporated into the project cost plan to assess the costs required to

achieve an ‘Excellent’ rating.

424. Pre-assessment results show the development to be on track to achieve high

credits in the Water category and moderate credits in the Energy, Materials and

Pollution categories.

425. A post construction BREEAM assessment is required by condition.

Whole Life-Cycle carbon emissions

Policy and guidance

426. London Plan Policy SI 2 (Minimising greenhouse gas emissions) requires

applicants for development proposals referable to the Mayor (and encourages

the same for all major development proposals) to submit a Whole Life-Cycle

Carbon assessment (WLCA). The assessment captures a building’s

operational carbon emissions (from regulated and unregulated energy use), as

well as embodied carbon emissions, (i.e. those associated with raw material

extraction, manufacture and transport of building materials and construction)

and emissions associated with maintenance, repair, and replacement as well

as dismantling, demolition and eventual material disposal. The Circular

Economy strategy is therefore closely interlinked, addressing reuse and

126

recycling of existing buildings and materials, as well as the longevity, flexibility,

and adaptability of the design proposal.

427. Core Strategic Policy CS15 of the City’s Local Plan requires “all redevelopment

proposals to demonstrate the highest feasible and viable sustainability

standards in the design, construction, operation and “end of life” phases of

development.”

The application proposal:

428. Approximately 75% of the proposed development by floor area (GIA) is made

up of retained existing entities (all tunnels, shafts and 31-33 Holborn buildings),

whilst the other 25% (Furnival St) is new build.

429. The proposed change of use would transform the Tunnels into a cultural venue

with the exhibition divided broadly into two key components – a permanent

historical section occupying the ‘Streets’ tunnels and a flexible digital

component located in the ‘Avenues’. Within the flexible avenues spaces

innovative digital led experiences will be developed, sometimes combined with

physical installations. These experiences will be short to medium term

exhibitions and one-off events. Detailed exhibition content would be developed

during the refurbishment period. The DAS describes the proposal as follows:

The seamless integration of state-of-the-art audio-visual technology will form a

key element in the delivery of a successful immersive and interactive visitor

experience, with a combination of LED screens, projectors and advanced

sound system technology built to create best in class immersive experiences.

Figure 14. Indicative projectors in the tunnels

127

430. The WLCA lays out three potential fit-out scenarios based on differing extents

of audio-visual (AV) equipment (indicative final fit-out designs) which result in a

very wide range for both embodied and operational carbon emissions. The

extent of AV will depend on the museum operator and programme of temporary

(short or medium term) exhibitions and special events, changing throughout the

year. The WLCA and Energy Statement have been based on the medium use

scenario.

Table. 8. Implications of different Scenarios

Scenario

Summary

Implications

Low

Base building/CAT A design

(inc. heating, cooling,

ventilation, lighting and fixed

energy loads such as lifts)

operating with anticipated

occupancy and opening hours

but only limited audio-visual

(AV) equipment installed.

Includes audio-visual and other

equipment for the Heritage Museum

in the Streets, and the Bar, and

limited use of projectors in the

Avenues.

Many of the cultural use scenarios

fall in this category.

Medium

Base building plus a mix of low

energy AV systems including

some LED screens and high-

fidelity projectors.

Based on anticipated occupancy

and opening hours. Improved

HVAC efficiencies due to

equipment running at part load

and the use of cooling from

ambient air temperatures.

Balanced use of projector

technology and LED. Includes

higher LED loads including music

events or immersion visual

experience, set out in the Cultural

Plan, but does not include the full

extent of AV provision allowed for

the highest case.

This is a conservative position that

allows much cultural flexibility.

High

Based on anticipated occupancy

and opening hours. Base

building plus, a higher amount of

AV equipment with a high

proportion of LED screens.

The Highest case relates to the

possible installation of a fully

immersive LED solution installed in

up to 50% of the surface area of the

Avenues.

This level of energy use may

happen for some cultural

installations but is not expected to

be applied for long periods of time.

The table below provides a breakdown of screen area and number of projectors by

area for each scenario.

128

Low scenario

Medium scenario

High scenario

Screen

area

(m2)

No. of

projectors

Screen

area (m2)

No. of

projectors

Screen

area (m2)

No. of

projectors

Entrance Hall

102

204

Avenues

1104

2208

126

Streets

788

1575

Total

1994

108

3987

182

The table below shows a comparison of upfront and total WLC carbon figures by

scenario and with GLA Retail Benchmarks.

431. Total embodied WLC emissions per m2 for Medium and High scenarios are

substantially higher than the GLA Retail Benchmarks. It is noted that retail

benchmarks are not representative of this unique development but are

considered the most relevant by the applicant and agreed by the 3rd party

reviewer of the WLCA.

432. The detailed WLC and energy assessments are based on the medium scenario.

The final fit-out is currently uncertain but will be developed throughout the

detailed design stages and finalised once museum operators are on board. A

detailed whole life-cycle carbon assessment confirming the proposed fit-out

plan including quantities of audio-visual equipment and predicted frequency of

events or special exhibitions as well as the associated carbon impacts is

required by pre-commencement (exc. demolition) condition.

129

Table 9. Life-cycle carbon emissions by module based on the medium scenario.

Estimated

Whole Life

Carbon

Emissions (over

60-year

lifespan)

Upfront

Embodied

Carbon

(A1-A5 excl.

sequestered

carbon)

Total embodied

Carbon

(A-C excl. B6-

B7; incl.

sequestered

carbon)

Module

B1-B5

Whole

Building

Operational

carbon

(B6-B7)

Total Whole

Life Carbon

(inc. B6)

Development

Total (kg CO2e)

7,911,775

17,554,764

9,087,567

11,582,588

29,137,352

Total per m2

(kg CO2e/m2

GIA)

745

1,652

855

1,090

2,742

433. Total WLC emissions (embodied and operational) are estimated at 29,137,352

kgCO2e.

434. Embodied carbon emissions total 17,554,764 kgCO2e with MEP equipment

accounting for approximately 70% (~15% is typical for an office scheme

according to research by LETI). Two-thirds of those embodied emissions from

MEP are attributed to maintenance and replacement.

435. The sustainability consultants included an estimated embodied carbon

comparison with the Museum of London and Liverpool Everyman Theatre to

provide context with buildings of a more similar programme to the proposed

development. A comparison of operational emissions was not provided.

Table 10. Estimated embodied carbon comparisons

London Tunnels

Medium

Scenario

Museum of

London

Liverpool

Everyman

Theatre

Year

2029

2026

2013

Size (m2 GIA)

10,625

49,996

4,690

Visitors/year

2,000,000

(target)

2,000,000

(target)

120,000 (actual)

Embodied carbon

(A-C) total (kgCO2e)

17,555,000

29,997,000

4,845,000

Embodied carbon per

m2 over 60-year period

(kgCO2e)

1,652

600

1,033

Embodied carbon

per visitor over 60-year

period (kgCO2e)

146

250

670

436. The Tunnels has the highest embodied carbon ‘intensity’ (rate per m2) of the

venues assessed. The underground nature and elongated form of the tunnel

130

network naturally requires extensive ventilation/cooling and long servicing runs

in order to be made into a viable tourist attraction. The comparison table shows

that if these venues attract (close to) their target (or actual) visitor numbers then

over a 60-year period the Tunnels attraction would have a lower embodied

carbon cost per capita than these other indicative cultural venues. The

embodied carbon cost (per capita) for the tunnels becomes less than the

Museum of London after around 35 years.

Furnival Street New structure

437. A variety of structural systems were considered during design phase table

and evaluated against project brief, architectural design intent, programme,

sustainability, and cost. Relative carbon intensity was assessed at high-level

based on previous experience. The primary system chosen is a concrete

frame with post-tensioned concrete slabs. Steel and CLT options were

discounted before carbon and detailed structural design was undertaken as

they cannot achieve the architectural intent for structural floor zone and

spans. The choice is justified by the intention to allow greatest flexibility in

floor space and plant equipment layout.

438. The strategy to minimise embodied carbon includes the following measures:

• Hybrid elements of structure with a variety of structural framing and floor

plate types has been proposed to optimise efficiency based on

parameters such as loading requirements

• Prioritisation of prefabricated elements, likely to include walls, infill panels

and tunnel lining structure, to minimise material use and thereby reduce

construction waste and carbon emissions

• Floor load allowance to be refined following clarification of MEP plant in

next stage. To avoid overspecification of predicted loads;

• Post-tensioned system reduces slab thickness and requirement for beams

• Refrigerant specified for cooling system has very low global warming

potential of <1 – a negligible effect on global warming

439. The design and specifications will ensure that environmentally sensitive (non-

toxic) building materials are used throughout. Specifically, the design and

specification of materials used internally will be based on the use of products

that contain low levels of or no Volatile Organic Compounds (VOCs). This is

important for health and wellbeing as well as carbon reduction.

440. Design optimisations will be explored at detailed design stage to reduce carbon

emissions including:

• Further reduction of superstructure PT slab thickness

• Non-metallic ductwork

• Alternative chilled ceilings

131

• Potential to source reused steel sections

• Reclaimed raised access flooring.

Operational energy strategy and carbon emissions

Policy and Guidance

441. London Plan Policy SI 2 Minimising greenhouse gas emissions sets out how

major developments should be net-zero carbon by “reducing greenhouse gas

emissions in operation and minimising both annual and peak energy demand

in accordance with the following energy hierarchy:

• be lean: use less energy and manage demand during operation

• be clean: exploit local energy resources (such as secondary heat) and

supply energy efficiently and cleanly

• be green: maximise opportunities for renewable energy by producing,

storing and using renewable energy on-site

• be seen: monitor, verify and report on energy performance”

442. Policy SI2 also states that “Major development proposals should calculate

and minimise carbon emissions from any other part of the development,

including plant or equipment, that are not covered by Building

Regulations, i.e. unregulated emissions.” [emphasis added]

443. Development Clause 9.9.2 expands on the priority of the energy hierarchy

which is to “minimise energy demand, and then address how energy will be

supplied and renewable technologies incorporated. An important aspect of

managing demand will be to reduce peak energy loadings.” [emphasis

added].

444. London Plan Policy SI4 Managing Heat Risk states that Development should

minimise adverse impacts on the urban heat island through design, layout,

orientation, materials, and the incorporation of green infrastructure. Through an

energy strategy, development should demonstrate how they will reduce internal

overheating and reliance on air conditioning systems in accordance with the

cooling hierarchy.

Application proposal:

445. For the medium scenario, total operational carbon emissions (B6 & B7) are

calculated at 11,582,588 kgCO2e or 1090kgCO2e/m

- about 40% of total WLC

emissions.

446. The proposed development employs a highly efficient and fully electric HVAC

system of air source heat pumps, cooling towers, and water-cooled chillers with

heat recovery, which help reduce carbon emissions.

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447. Avenues and Streets supplied with minimum fresh air via combined general

ventilation and smoke control ductwork. Duct sizes are minimised to the smoke

requirement to save material and embodied carbon and CO2 control in air

handling units and Avenue zones help minimise energy consumption.

448. The operational energy of the proposed development is affected significantly

by the final fit-out and specific equipment associated with exhibitions/events as

demonstrated in the Low, Medium, and High scenarios set out above.

449. Audio-visual equipment has a very significant impact on energy consumption

for the building. Compared with the base building adding projectors across the

Avenues, Streets and Entrance Hall leads to an increase in annual energy

consumption of 188% from 67 kWh/m2 to 126 kWh/m2. This shift also

increases the cooling demand by over 700%.

450. The adopted GLA energy assessment guidance (2022) requires developments

to calculate Energy Use Intensity (EUI), a measure of total energy consumed

in a building annually including regulated and unregulated energy use, as well

as the space heating demand. For offices, the GLA sets a target EUI of 55

kWh/m2(GIA)/year, and a space heating demand of 15 kWh/m2(GIA)/year

whilst the UKGBC target is 90 kWh/m2/year. As there are no industry targets

for cultural buildings and given the unique nature of the Tunnels, these targets

is for guidance only.

Table comparing estimated annual energy use intensity for the proposal

scenarios with office targets.

Office Targets

Low

scenario

Medium

scenario

High

scenario

GLA

Target

UKGBC

target

2025-30

UKGBC

target

2030-35

Whole building

energy

intensity

kWh/m2GIA

126

191

115

451. The current anticipated competition date for the Tunnels is 2029. Against the

2025-30 target, the EUI for the medium and high scenarios is 10 and 66%

higher respectively. Against the 2030-35 target, the medium and high scenarios

are 40% and 112% higher respectively.

452. The Tunnels have low heating loads due to the insulation/thermal mass

provided by the surrounding soil. Cooling demand for the site is predicted to be

very high due to large visitor numbers and intensive AV equipment in a confined

environment. The maximum predicted cooling load is 1.8MW.

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453. The following strategy has been designed to optimise cooling delivery and

minimise waste heat rejection (impact on the local heat island) but there is a

significant embodied carbon footprint associated with the extent of plant

required:

• Heat recovery has been implemented wherever possible to minimise heat

rejected and improve system efficiencies.

• Heat is rejected by highly efficient cooling towers and water source

chillers, circulating chilled water

• Chilled water panels located throughout the ‘avenue’ and streets’ tunnels

absorb heat locally helping to capture heat from equipment such as

screens and projectors.

• The inclusion of chilled panels enables cooling during unoccupied hours

using only the cooling towers, avoiding energy usage associated with

operating the chillers.

• Rejected heat from the Tunnels will be able to pre-heat air in order to heat

above ground areas of the building and provide hot water.

454. The application proposal has been designed to achieve an overall 41.4%

reduction in regulated emissions compared to the notional existing building

based on GLA energy guidance, meeting the London Plan requirement of 35%

minimum on site.

455. The proposal does not meet the GLA requirement for net zero carbon, so a

carbon offset payment in required. This has been provisionally calculated based

on the medium scenario as £123,951. An updated energy assessment based

on fit-out with a high level of AV equipment should be undertaken prior to

occupation and the offset payment calculated accordingly. The energy

statement should be secured under condition. The payment should be secured

through S106 agreement.

456. A S106 clause will be included requiring reconfirmation of this energy strategy

approach at completion stage and carbon offsetting contribution to account for

any shortfall against London Plan targets, for the completed building. There will

also be a requirement to monitor and report the post construction energy

performance to ensure that actual operational performance is in line with GLA’s

zero carbon target in the London Plan.

Be Lean

457. The first step of the energy hierarchy is to reduce demand through energy

efficiency measures. The majority of the development utilises existing buildings.

Due to the existing heritage of the projects, has not been possible to update the

material in the actual Tunnels however these already benefit from the insulation

provided by the soil surrounding the structure.

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458. At application stage, the proposed energy demand reduction strategy (‘be lean’)

only achieves an operational saving of 0.3%, well below the 15% GLA

requirement for commercial buildings.

459. This is due largely to the nature of the tunnels (subterranean, long, enclosed

spaces), combined with the operational requirements of the proposed change

of use to museum/event space – high visitor numbers and AV equipment

requiring ventilation and cooling.

460. The energy efficiency measures proposed exceed minimum building regulation

requirements and include:

• Highly efficient building fabric at Furnival Street

• Centralised ventilation with heat recovery

• All spaces will include 100% low energy lighting with lighting

controls/sensors

• Smart control systems and building management system to ensure

efficient control and monitoring of MEP services to minimise energy

waste.

Be Clean

461. The applicant team has consulted with the local heat network operator (Citigen).

At present there is no heat network infrastructure planned for the area. In

accordance with GLA guidance a low temperature hot water system has been

specified and the plant room designed to facilitate heat network connection in

future. Evidence of provision for connection to a future heat network is required

by an obligation.

462. Utilising waste heat through connection to a heat network, direct transmission

to a nearby building or otherwise, is key to reducing the environmental impact

of the proposed development. An obligation is to be included which requires the

development to thoroughly explore possible options for beneficial rejection of

waste heat.

Be Green

463. The proposed development employs a fully electric HVAC strategy using highly

efficient air source heat pumps and water-cooled chillers which help reduce

carbon emissions.

464. Potential for roof mounted PV at Furnival Street was assessed but roof area is

limited. The largest area is occupied by plant which requires ventilation so

cannot accept PVs above. The other roof area has been prioritised as a staff

amenity terrace as the only outside space available on the site.

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465. A detailed Whole Life-Cycle carbon assessment incorporating improvements

achieved through the detailed design stage, and a confirmation of the post-

construction results are required by conditions.

Urban Greening and Biodiversity

466. Local Plan Policy DM19.2 promotes Urban Greening and Biodiversity, DM 10.2

(Design of green roofs and walls) and 10.3 (Roof gardens and terraces)

encourages high quality roof gardens and terraces.

467. The existing site has negligible ecological value. The proposal provides

greening at roof level, on the staff terrace and plant room roofs, and a green

wall on the south façade of 40-41 Furnival Street. At level 4, a planting palette

of flower rich perennial planting, including small trees/shrubs and climbers, at

level 5, an intensive roof sown with a wildflower seed mix with plug planting.

These measures will improve public realm quality and achieving a UGF of

0.135.

468. Project constraints make it difficult to achieve the recommended UGF of 0.3;

• Proposed development is predominantly underground

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• Constrained form, in part due to rights of light envelope, provides limited

area to provide more greenery without away from the only outdoor space

available for the staff.

Proposed Roofs

Extensive Green Roof Area

31.2 m²

Intensive Green Roof Area

24 m²

Green wall

13.5 m²

Blue Roof Available

Attenuation Volume

4.9 m³

Rainwater harvesting tank

8 m

Photovoltaic Panels

None

469. Details of the quality and maintenance of the proposed urban greening are

required by conditions (1. Rainwater attenuation and biodiversity, 2. Visual

amenity).

Climate Change Resilience

Water resources

470. The development incorporates best practice technologies to limit its water

consumption to a minimum. Including:

• Water leak detection and automatic shut off valves

• Water efficient / low flow sanitary fittings

• Rainwater harvesting for irrigation/WC flushing

Flood Risk, Water Management and Drainage

471. The GLA’s London Plan 2021 Policy SI 12 gives specific guidance on the

provision of flood resilience which is relevant to this development with Policy SI

13 noting that developments should aim to achieve greenfield runoff rates and

ensure run-off is managed as close to the source as possible.

472. Local Plan 2015 policy CS18 seeks to “reduce the risk of flooding from surface

water throughout the City, by ensuring the development proposals minimise

water use, reduce demands on the combined surface water sewer and

sewerage network”. The use of Sustainable Drainage Systems (SuDS) is

supported by Local Plan policy CS18 and policy CR3 of the draft City Plan 2040.

473. The submitted Flood Risk Assessment identifies the site as lying in Flood Zone

1 (an area of very low flood risk). As such the application site is at low risk of

fluvial and tidal flooding. The risks of groundwater flooding are also considered

to be low, however, given the subterranean nature of the tunnels appropriate

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waterproofing and underfloor drainage and pump systems are proposed to

collect any remaining seepage and redirect it to the public sewer system.

474. The proposed drainage strategy includes capturing rainwater landing on roof

levels and remaining impermeable areas and directing this to the blue roof

system or via downpipes/pipe network to storage systems (tanks) before being

discharged to the existing combined public sewer in Furnival Street. Systems

have been sized to accommodate the 1 in 100-year storm rainfall event with a

40% additional allowance for climate change.

475. The proposed maximum discharge rate from the Proposed Development is 1.5

l/s, which is as close as technically feasible to greenfield run-off rates given the

nature of the development and offers a significant betterment on existing pre-

development run-off rates.

476. The Lead Local Flood Authority and Thames Water have been consulted and

recommended conditions and informatives are to be attached.

477. The proposed Flood Risk and SUDS strategy would accord with policies CS18

of the Local Plan 2015, S15, CR2 and CR3 of the draft City Plan 2040 and

policies SI12 of the London Plan.

478. Although the likelihood of flooding is considered low for the development, the

consequences of flooding in the Tunnels is high so the following are considered:

• Appropriate waterproofing measures should be deployed to manage risk

of groundwater seepage.

• Any routes for surface water ingress to the Tunnels (i.e. via the shafts) are

protected by finished floor levels that rise to a minimum of 150mm above

adjacent street levels;

• Where practicable, all electrical and life safety infrastructure is provided a

minimum of 300mm above finished floor levels, or where not practicable,

equipment is designed to be flood resilient;

479. A Flood Evacuation Plan was submitted over the course of the application

which has been reviewed by CoL Environmental Resilience Officer. The

proposed egress and access routes both internal and external, have been

identified go through unflooded areas in compliance with CoL Flood Emergency

Plans for New Developments Planning Advice Note (June 2020). The site is

low flood risk and the possible flooding mechanism of the tunnel (groundwater

and burst watermains) fall into residual risk (i.e. it is defended against and will

only result if those defences fail). The two routes with distinct exit points helps

to mitigate this risk yet further. Officers would therefore consider this

development to meet the policy in this area (flood egress and access). Further

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details would be required to be provided in the AMP under Section 106, to

ensure safe egress of all groups of people is being considered.

Heat Stress

480. Policy SI 4 of The London Plan (2021) states that major development proposals

should reduce potential overheating, and reliance on air-conditioning systems,

and demonstrate this in accordance with its cooling hierarchy.

481. The most prescient risks to the building of these changes are overheating, and

increased cooling demands & costs. Thermal modelling has been carried out

as part of the design process to ensure the impacts of these heightened

temperatures can be managed and minimised.

482. 100% low energy LED lighting will reduce internal heat gains whilst an efficient

water-cooled system allows mitigation of overheating space. All electric cooling

plant minimises carbon impact of additional cooling requirement.

Urban Heat Island

483. All air handling systems will be equipped with heat recovery systems to reduce

the amount of heat expelled to the external environment.

484. Water Greening on the Furnival Street terrace will contribute to a reduction in

the heat island effect as plants mitigate retention of heat.

Natural Capital and Pest & Diseases

485. Overall, this development includes a range of measures which will improve its

resilience to climate change. Details of these measures will determine how

effectively the building performs in coming decades, with detailed modelling and

planting plans required by conditions including comparison against the UK

Climate Projections UKCP18 to 2080 (tools and data that show how the UK

climate may change in the future, based on potential emissions scenarios).

486. Prior to the commencement of the development (other than demolition) a

Climate Change Resilience Sustainability Statement (CCRSS) shall be

submitted to and approved in writing by the Local Planning Authority, that

demonstrates how the development will be resilient and adaptable to predicted

climate conditions during the lifetime of the development. This condition may

be fulfilled by a satisfactory assessment in support of the BREEAM Wst 05

credit.

Conclusion on Sustainability

487. The City of London Climate Action Strategy supports the delivery of a net zero,

climate resilient City. The agreed actions applicable to the planning process

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relate to the development of a renewable energy strategy in the Square Mile,

to the embedding of carbon analysis, circular economy principles and climate

resilience measures into development proposals and to the promotion of green

spaces and urban greening as natural carbon sinks. The Local Plan policies

require developments to demonstrate highest feasible and viable sustainability

standards in the design, construction, operation, and end of life phases of

development as well as minimising waste, incorporating climate change

adaption measures and urban greening, and promoting biodiversity and overall

wellbeing.

488. Demolition of both buildings on Furnival Street is deemed acceptable, justified

by the practical constraints of the construction process, achieving greater

access to the Tunnel network (for visitors and equipment) and the greater

servicing efficiencies which can achieved through the size/layout of a new build.

489. The whole life-cycle carbon assessment sets out the large, embodied carbon

cost of the refurbishment and fit-out works as well as plant replacement over

life-cycle period of 60 years. High energy and cooling demand are driven by

high visitor numbers and extensive AV equipment proposals. However, a highly

efficient, water-based and localised cooling system with heat recovery has been

designed to manage overheating within the tunnel network and reduce

operational energy.

490. The London Tunnels proposal offers a unique visitors attraction in a strategic

location for a new cultural offering. The scheme would bring an underutilised

piece of historic infrastructure with a storied past into public use, bringing

economic benefits to the area. The change of use of deep level tunnels

designed for emergency shelter and secure telecommunication to a cultural

exhibition and event space offering an immersive audio-visual experience is

technically challenging and requires an extensive amount MEP equipment to

accommodate the high visitor numbers targeted/anticipated.

Security

491. London Plan Policy D11 requires consultation with the City of London Police to

identify the community safety needs and maintain safe and secure

environments. Local Plan Policy CS3 and Emerging Policy S2 highlight the

needs for the City to be secure from crime, disorder and terrorism thereby

increasing public and corporate confidence in the city's role as the world's

leading international financial and business centre.

492. Concerns have been raised by residents regarding the security and safety

impacts of the proposed development.

140

493. A Security report has been prepared and submitted as part of this application.

The Security Strategy focuses on internal attacks in the tunnels and proposes

mitigation measures such as the introduction of a bag scanning and searching

system at check-in of visitors. All visitors would be required to pre-book their

visit, with information provided at the booking regarding the security process

and a list of prohibited items. Locker rooms would be available at ground level,

before entering the exhibition space, where visitors would lock their personal

staff that cannot be carried inside the tunnels. A grouping system would be

adopted to control visitors journey and access to spaces. Video Surveillance

Systems (VSS) will monitor the site through Security Control Room (SCR). It is

not anticipated to have people queuing outside the building and therefore

Hostile Vehicle Mitigation (HVM) has not been proposed for implementation.

494. Visits to the bar would be also pre-booked. The bar is only accessible via

Fulwood Place, the secondary entrance in Camden, where security control

would be in place. Access from the bar to any other areas of the tunnels would

not be available outside of the exhibition spaces operational hours.

495. City Police and Counter-Terrorism Security Advisers have reviewed the

information provided and have made a number of recommendations to prevent

potential attacks on site with advice given for ongoing consultation with them

as the plans for the site develop. Officers consider that the application complies

with London Plan Policy D11, Local Plan Policy CS3 and Emerging Policy S2.

Recommendations for Operational and Events Management Plan have been

made, including crowd management, dispersal, levels and system of control on

site that would help prevent antisocial behaviour, to be secured via Section 106.

Informatives have been also recommended for the continuous involvement of

the City Police and CTSA at the detailed design stage of the scheme.

Suicide Prevention

496. Local Plan policy CS3 requires that security and safety measures are of an

appropriate high-quality design. The City Corporation has recently adopted the

Planning Advice Note “Preventing Suicide from High Rise Buildings and

Structures” (2022) which advises developments to ensure the risk of suicide is

minimized through appropriate design features. These features could include

planting near the edges of balconies and terraces, as well as erecting

balustrades.

497. Policy DE4 of the draft submission City Plan 2040 advises that appropriate

safety measures should be included in high-rise buildings, to prevent people

from jumping or falling.

498. The proposal includes a roof terrace at level four, which would only be

accessible to staff working on-site.

141

499. The Design and Access Statement confirms that the roof terrace has been

designed in line with the adopted Advice Note with the provision of a balustrade

of 1.4m in height to the perimeter of the terrace, exceeding the 1.1m required

by building regulations and in line with the 1.4m suggested by the Planning

Advice Note. Perimeter planters are also proposed to be embedded in the floor

to restrict and deter access to the boundary of the useable terrace.

500. The terrace would not be accessible to any member of the public which

provides a more controlled use of the outdoor space. However, a condition has

been recommended for details of suicide prevention measures to be submitted

and approved by the City prior to the first occupation of the building.

501. The proposal is considered to comply with Local Plan Policy CS3 and draft City

Plan Policy DE4 and the recommendations of the Planning Advice Note. A

condition has been imposed as mentioned above.

Fire Statement

502. Policy D12 of the London Plan seeks to ensure that proposals have been

designed to achieve the highest standards of fire safety, embedding these into

developments at the earliest possible stage. Policy D5 requires development to

incorporate safe and dignified emergency evacuation for all building users with

a minimum of one lift per core to be a suitably sized fire evacuation lift.

503. The application is accompanied by a Fire Statement in accordance with London

Plan Policy D12B for major developments and the fire safety regulations.

504. The application predicts an annual visitation of two million on site. The tunnel

exhibition visitors are estimated to reach maximum 750 people/hour and the

visitor of the underground bar is estimated to be 120 people/hour. The Fire

Statement clarifies that the conventional British Standards guidance would

potentially not be adequate for achieving optimal fire safety levels due to the

unique nature of the proposed development. Instead, an engineering and risk-

based design approach has been suggested, along with the implementation of

a Basis of Design (BoD) document to guarantee adherence to fire safety

regulations.

505. A water-based suppression system is proposed to be installed which would be

activated in the event of a fire to extinguish or control the fire. The presence of

fire/smoke shutters in the tunnels ensures that there are several layers of fire

separation between the occupants and the fire source. This compartmentation

allows the occupants to safely make their way towards the protected lobbies of

the evacuation shafts. The lobbies next to the lift shafts at the two entrance

points would be designated as safe areas equipped with fire-resistant materials

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and would be pressurized to prevent smoke accumulation in case of sprinkler

system failure. These refuge areas can accommodate up to 50% of the tunnel's

occupants for evacuation through lifts or stairs.

506. In line with London Policy D5, evacuation lifts would be available at both

entrances. At Furnival Street the round lifts would serve the east side of the

tunnels and levels 1 and 2, and the lifts at the rear would serve the upper levels

of the Furnival buildings for evacuation to Furnival Street. Fulwood Place works

as an emergency exit to the west side of the tunnels. Vertical evacuation would

be available on this side as well that leading to Fulwood Place and then to High

Holborn.

507. Incorporating smart signage and wayfinding systems linked to the detection

system will help guide occupants to the protected lobbies based on the fire's

location.

508. The CoL District Surveyors have reviewed the application and the Fire

Statement and raised no objections.

509. Given the somewhat unique nature of the proposal and the proposed use,

officers have sought London Fire Brigade’s view of the submitted documents.

The London Fire Brigade (LFB) is not a statutory consultee under the Town and

Country Planning Act 1990, however due to the uniqueness of the site, the

subterranean layout and the long underground distances Offices consider it

pertinent to review measures in detail at an early stage. London Fire Brigade

have therefore indicated various measures that would need to be considered

post planning stage.

510. In general, LFB is content that the methodology outlined in BS 7974:2019 would

be applied and this has been supported. As part of this methodology a

Qualitative Design Review (QDR) process would be undertaken and LFB would

expect to be involved in this process as a key stakeholder. This QDR process

would take place post planning and would therefore fall under Building

Regulations, i.e. post planning. Notwithstanding this however, a number of

areas have been identified for review given concerns from LFB and the

applicant has confirmed that these would be reviewed under any subsequent

next step. These identified matters consist of the extended travel distances for

occupant means of escape and firefighter access/intervention, radio

communications coverage for firefighters and other emergency responders,

Electric Powered Personal Vehicles and the construction phase fire safety.

511. Again, while these issues would be included as part of any QDR process, which

takes place prior to a statutory Building Regulations consultation with LFB, they

are discussed below for completeness.

143

512. With regard to the extended travel distances for occupant means of escape and

firefighter access, given the nature of the existing tunnel infrastructure is such

that travel distances hose laying distances for firefighter access/intervention will

be extended beyond the distances recommended within guidance. LFB

understand that extended hose laying distances are proposed to be addressed

by providing an enhanced dry fire main system, similar to that provided for sub-

surface railway tunnel infrastructure. While there is no objection to this in

principle the technical details of this would need to be reviewed at QDR stage

in conjunction with the LFB. Equally, in terms of the of the radio communications

for firefighters while the applicant has confirmed that the scheme would have a

Distributed Antanae System so that there will be mobile communications

provisions in the tunnels, this would need to be confirmed under the QDR

appropriately.

513. Regarding Electric Powered Personal Vehicles (EPPVs) officers have sought

that the Accessibility Management Plan would secure the use of self-

propelled/transit wheelchairs to limit the use of lithium-ion power units within

the Tunnels. While this would be reviewed under the QDR process the

Accessibility Management Strategy, proposed to be secured under any

attached legal agreement, would secure an initial requirement to limit any

potentially fire issues in the future. This would also be similar to the construction

phase fire safety which would again require further consultation with the LFB at

QDR stage, prior to Building Regulations, noting that a sufficient fire risk

assessment to demonstrate compliance with The Order during construction

would be required from the applicant.

514. With specific respect to LFB’s view around compliance with planning policies

given the depth of the premises from the access level and the fact that

occupants other than persons of restricted mobility may experience difficulty in

evacuating upwards over a height in excess of 30m, LFB recommend that

consideration be given to providing additional evacuation lift capacity and this

should be taken into account when undertaking the evacuation lift capacity

assessment expected under London Plan 2021 Policy D5(B5). Officers have

proposed a requirement in the proposed Access Management Plan to review

the evacuation proposal against London Plan Policy D5 and as such adhering

to the comments received from LFB. This would be secured within the attached

legal agreement and would require submission of details for further review. For

absolutely clarity however, while the QDR process lies outside of the planning

process, officers have sought confirmation from the applicant that the above

matters falling outside the scope of planning would be reviewed at this QDR

stage and this reminder would be included within informatives attached to any

permission.

515. The proposed development would therefore meet the requirements of Policy

D5 and D12 of the London Plan.

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The Public Sector Equality Duty (section 149 of the Equality Act 2010)

516. When considering the proposed development, the Public Sector Equality Duty

(PSED) requires City of London to consider how the determination of the

application will affect people who are protected under the Equality Act 2010,

including having due regard to the effects of the proposed development and

any potential disadvantages suffered by people because of their protected

characteristics.

517. The City, as a public authority must, in the exercise of its functions, have due

regard to the need to:

• Eliminate discrimination, harassment, victimisation and any other conduct

that is prohibited by or under this Act;

• Advance equality of opportunity between persons who share a relevant

protected characteristic and persons who do not share it;

• Foster good relations between persons who share a relevant protected

characteristic and persons who do not share it.

518. The characteristics protected by the Equality Act are age, disability, gender,

reassignment, marital status, pregnancy and maternity, race, religion or beliefs,

sex and sexual orientation.

519. An Equalities Impact Assessment has been carried out in respect of the scheme

by the applicant which did not identify potential for discrimination or adverse

impact to any protected groups.

520. It has been considered that the physical design and layout of the scheme has

been designed to be accessible to all regardless of age, disability, whether you

are pregnant, race, sex, sexual orientation and gender reassignment and

marital status. This would be achieved through measures such as:

• Pedestrian approaches to the entrances that are safe, segregated from

vehicle traffic;

• The provision of step-free access to all parts of the building. Step-free

access for staff use of the roof terrace in Furnival Street;

• Large passenger lifts with capacity to accommodate Type C mobility scooter

access to the retail floors of Furnival Street and the cultural exhibition

spaces in the tunnels;

• Provision of a type C mobility scooter parking space and charging point for

staff at ground level;

• Secured accessible cycle parking for staff at ground floor of Furnival Street;

• Unisex wheelchair-accessible sanitary facilities for visitors upon arrival and

to serve the retail areas in Furnival Street, and within the tunnels, including

provision of a Changing Places toilet;

• Provision of a mix of male, female and unisex toilets including facilities for

ambulant disabled users in Furnival Street and within the tunnels. Dedicated

sanitary facilities in close proximity to the bar;

145

• Welfare facilities for visitors such as wheelchair-accessible baby changing

facilities across the site;

• Provision of quiet spaces, a first aid room and seating within the final fit out

of the tunnels;

• Wheelchair-accessible sanitary and refreshment facilities to serve the staff

areas;

• Evacuation lifts for the safe and dignified evacuation of disabled users;

• Interior design, wayfinding strategy, design of exhibition spaces, lighting,

acoustics and use of assistive technology to be detailed at the appropriate

design stage taking into consideration the good practice guidance of BS

8300:2018 and PAS 6463:2022;

• The provision of resting points on routes longer than 50m from key points of

arrival to the site’s main entrance including accessible seating;

• The commitment to provide and additional blue badge parking on Furnival

Street and the public realm improvement works (to be secured via Section

278 agreement).

521. Final detail of an Access Management Plan and Operational Management Plan

would be secured by condition in order to secure the access requirements of

all users are being met and to cover all aspects of the user experience from the

provision of pre-arrival information in accessible formats, to the management

of exhibition spaces (e.g. offering quiet visiting times) and staff training in

accessibility and inclusion and in evacuation procedures.

522. The applicant has made a commitment to provide social benefits through the

development that would promote equality and inclusion. Examples of such

benefits include:

• Free school visits for schools around London;

• Partnerships with universities, institutions, local communities and

underrepresented artists to co-curate the exhibition spaces

• Training opportunities accessible to all

523. Conditions, informatives and Section 106 and 278 agreements would be

required to cover the accessibility management and operation of the exhibition

space and other matters such as the accessible parking, resting points and

inclusive procurements. An informative would be placed on the permission

reminding future occupiers of their duty under the Equality Act 2010.

524. A suitable programme of highway works and conditions relating to construction

and demolition management and logistics, noise and dust management are

recommended in order to minimise the impact of the scheme on nearby

occupiers and those with Protected Characteristics.

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525. The proposed development has been assessed against policy GG1 of the New

London Plan and would be considered to support and promote the creation of

an inclusive London where all Londoners, regardless of their age, disability,

gender, gender identity, marital status, religion, race, sexual orientation, social

class, or whether they are pregnant or have children, can share in its prosperity,

culture and community, minimising the barriers, challenges and inequalities

they face.

526. For the reasons set out above officers consider that overall the proposal would

have a positive impact on Protected Characteristics. Any potential negative

impacts that could arise through construction and operation would be managed

by the recommended conditions.

Human Rights Act 1998

527. It is unlawful for the City, as a public authority, to act in a way which is

incompatible with a Convention right (being the rights set out in the European

Convention on Human Rights (“ECHR”)).

528. Insofar at the grant of planning permission will result in interference with the

right to private and family life (Article 8 of the ECHR) including by causing harm

to the amenity of those living in nearby residential properties, it is the view of

officers that such interference is necessary in order to secure the benefits of

the scheme and therefore necessary in the interests of the economic well-being

of the country, and proportionate. Although it is recognised that the

development would have some impact on the amenities of the nearby residents

and other adjoining occupiers, including by way of noise and disturbance during

construction, it is not considered that, subject to conditions, the proposal would

result in unacceptable impact on the existing use of nearby residential

properties to an extent that would warrant refusal of the application on those

grounds. It is the view of the officers that the provision of such a unique cultural

and visitor attraction meets Local Plan ambitions and Destination City

aspirations for an evening and weekend economy and in tandem with the wider

socio-economic benefits brought by the proposed development the Minor

Adverse impacts on nearby residential and commercial properties are

outweighed and that such impact is necessary in the interests of the economic

well-being of the country and is proportionate.

529. Insofar as the grant of planning permission will result in interference with

property rights (Article 1 Protocol 1) including by interference arising though

impact on the amenity of adjoining properties, it is the view of officers that such

interference is in the public interest and proportionate.

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CIL and Obligations

530. The proposed development would require planning obligations to be secured in

a Section 106 agreement to mitigate the impact of the development to make it

acceptable in planning terms. The applicant would enter into a separate S106

agreement with the London Borough of Camden.

531. Contributions would be used to improve the City’s environment and facilities.

The proposal would also result in payment of the Community Infrastructure

Levy (CIL) to help fund the provision of infrastructure in the City of London.

532. These contributions would be in accordance with Supplementary Planning

Documents (SPDs) adopted by the Mayor of London and the City.

533. On the 1st of April 2019 the Mayoral CIL 2 (MCIL2) superseded the Mayor of

London’s CIL and associated Section 106 planning obligations charging

schedule. Therefore, the Mayor will be collecting funding for Crossrail 1 and

Crossrail 2 under the provisions of the Community Infrastructure Levy

regulations 2010 (as amended).

534. CIL contributions and City of London Planning obligations are set out below.

535. Evidence was requested from the applicant to demonstrated whether the

tunnels have been lawful use for six months over the last three years. No

evidence has been provided for the LPA to determine this and they are

therefore considered to be vacant for the purpose of calculating CIL.

MCIL2

Liability in accordance with the

Mayor of London’s policies

Contribution

(excl. indexation)

Forwarded to the

Mayor

City’s charge for

administration

and monitoring

MCIL2 payable

£702,793

£674,681

£28,112

City CIL and S106 Planning Obligations

Liability in accordance

with the City of London’s

policies

Contribution

(excl. indexation)

Available for

allocation

Retained for

administration

and monitoring

City CIL

£461,625

£438,544

£23,081

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City Planning Obligations

Affordable Housing

£52,200

£51,678

£522

Local, Training, Skills and

Job Brokerage

£31,320

£31,007

£313

Carbon Reduction Shortfall

(as designed)

Not indexed

£123,975

(based on the

whole site)

£123,975

£0

Section 278 (Evaluation and

Design Fee)

Not indexed

£100,000

£0

S106 Monitoring Charge

£4,086

£0

£4,086

Total liability in

accordance with the City

of London’s policies

£773,206

£745,204

£28,002

City’s Planning Obligations

536. The obligations set out below are required in accordance with the City’s

Planning Obligations SPD 2021. They are necessary to make the application

acceptable in planning terms, directly related to the development and fairly and

reasonably related in scale and kind to the development and meet the tests in

the CIL Regulations and government policy.

Heads of Terms

a) Highway Reparation and other Highways Obligations (Highways Schedule

of Condition Survey, site access, consents, licences etc)

b) Local Procurement Strategy (including inclusive procurement)

c) Employment and Skills Plan (demolition, construction and end use)

d) Delivery and Servicing Plan (including consolidation)

e) Travel Plan (Including Cycle Promotion Plan)

f) Construction Monitoring Cost (£30,935 – First year of development and

£25,760 for subsequent years)

g) Carbon Offsetting (£123,975 - to be reviewed on completion and prior to

occupation of the development)

h) Utility Connection Requirements

i) Section 278 Agreement (CoL). Scope to consider but not be limited to:

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• provide a healthy streets scheme with consideration to providing

a shared surface, increased footpath, additional street furniture,

additional blue badge parking, and further public realm

improvements

• improve sustainable transport to and across the area

• provide additional greening

• maintain the contra flow cycle lane

• maintaining access for emergency vehicles

j) Management Plan (including free or discounted tickets for certain groups)

and Public Access and Events Management Plan (in relation to the

cultural/temporary exhibition space)

k) Cultural Implementation Strategy (to restrict demolition until a Cultural

Operator is secured)

l) Access Management Plan (for the operation of the site)

m) Waste Heat Transfer

n) Improving cycle infrastructure on public highway

537. Some financial contributions could be subject to proportional split with London

Borough of Camden.

538. Officers request to be instructed to continue to negotiate and agree the terms

of the proposed obligations and enter into the S278 agreement.

539. The London Borough of Camden has made provision of the following Heads of

Terms to be included in their S106 agreement in accordance with their Local

Plan/SPD:

a) Car free development

b) Construction Management Plan (CMP) and CMP implementation support

contribution of £30,513 and CMP impact bond of £32,000

c) Travel Plan and associated monitoring and measures contribution of

£11,348

d) Electric vehicle charging infrastructure (fast charger) contribution of

£20,000

e) Delivery and Servicing Plan

f) Highways works contribution of £20,000

g) Off-site cycle parking contribution for cycle parking stands of £4,800

h) Pedestrian, Cycling, and Environmental Improvements contribution of

£150,000

i) Micromobility Improvements contribution of £10,000

j) Restriction on coach bookings and picking up/dropping off of customers by

coach outside site’s entrance at 31-33 High Holborn.

k) Requirement to form a construction working group consisting of

representatives from the local community

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l) Carbon offset payment – estimated £123,951

m) Energy Efficiency and Renewable Energy Plan

n) Sustainability Plan (including BREEAM Excellent)

o) Measures to ensure future connection to a local energy network

p) Construction apprenticeships paid London Living Wage (29 in total) and

support fee of £1,700 per apprentice (£49,300)

q) Local Procurement Strategy (including Camden Local Procurement Code)

r) Employment and Training Plan (including work experience placements,

20% local recruitment target, and engaging with Camden schemes)

s) Operational Management Plan

540. The Heads of Terms secured by the City are mostly in alignment with the above

Heads of Terms sought by Camden, however there are inevitably some

differences due to the respective Local Plans, context of the parts of the

development falling on different sides of the LPAs boundary, and separate

assessments of the proposal. As such, some obligations are sought by one

authority and not the other.

541. The boroughs will be in consultation with each other both during the drafting of

the respective legal agreements and, where appropriate, in the process of

discharging relevant obligations to ensure that where any Heads of Terms

extend across the borough boundaries or are required by only one borough, the

obligations are consistent and enforceable.

542. Consideration may also be given to the boroughs being a party to the other

borough’s legal agreement to acknowledge that, where relevant, the obligations

are enforceable across the whole of the development site.

Monitoring and Administrative Costs

543. A 10-year repayment period would be required whereby any unallocated sums

would be returned to the developer 10 years after practical completion of the

development. Some funds may be set aside for future maintenance purposes.

544. The applicant will pay the City of London’s legal costs and the City Planning

Officer’s administration costs incurred in the negotiation, execution and

monitoring of the legal agreement and strategies.

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Conclusions

545. The proposal has been assessed in accordance with the relevant statutory

duties and having regard to the Development Plan and other relevant policies

and guidance, SPDs and SPGs and relevant advice including the NPPF, the

draft Local Plan, local finance considerations, and considering all other material

considerations.

546. The application site straddles the City of London and London Borough of

Camden. For that reason, duplicate applications have been submitted to both

local authorities. Through the course of the application the two local authorities

worked together to address the matters raised by internal and external

consultees and public representations and conclude on planning

recommendations.

547. The application is intended to be considered by the Planning Committee of

London Borough of Camden on 11

of July 2024 and as such no resolution has

been granted. LB Camden will be determining an identical application which will

assess the considerations relevant to the development located within their

boundaries and against their policies.

548. The proposed development comprises the change of use of the existing deep

level tunnels to a visitor and cultural attraction (Use Class F1 (b) and (c)). The

attraction would offer cultural exhibition areas, to curate the history of Kingsway

Tunnels, used during and after London war times, by restoring and interpreting

their rich history in a historic exhibition space and a flexible gallery space where

modern and innovative content would be shaped by indented partnerships. The

proposal also involves the demolition and reconstruction of 38-39 Furnival

Street and the redevelopment of 40-41 Furnival Street to provide the principal

entrance to the cultural space at the ground level and ancillary spaces at the

upper levels, including a gift shop, staff accommodation and plant rooms to

serve the function of the tunnels. The reconstruction of the site at Furnival

Street would involve excavation for additional basement levels under the two

buildings and widening of the lift shaft at 38-39 Furnival Street for the provision

of the main passenger lifts. A secondary visitor and emergency entrance is

proposed at 31-33 High Holborn via Fulwood Place, located in the London

Borough of Camden. The creation of a deep level bar is proposed at the western

part of the tunnels, in LB Camden, which would be principally accessed via

Fulwood Place and would form an independent unit with its own operational

hours and staff.

549. The application received 57 letters of support from the public that expressed

their strong support for the proposed cultural use and the socio-economic

benefits it would bring to the local and London-wide area. Letters of support

have been received from Central District Alliance and the Fleet Quarter,

identifying the transformative nature of the scheme to an area that very much

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needs this change. It is not standard for an application in the City to receive so

many letters of support.

550. A total of 24 objections to the scheme have been received from the public

raising concerns over the noise and disturbance caused by construction and

the increased footfall and traffic at operational stage that would impact the

amenity of nearby residential and commercial occupants, the harm to the

conservation area and the design of the new building on Furnival Street, impact

of the proposed delivery and servicing arrangements on local residents and

business, the physical incapacity of Furnival Street to accommodate the

proposed development, and daylight and sunlight impacts to the commercial

building at 10 Furnival Street, opposite of the application site. The areas of

consideration are normally raised by the public when an application involves

construction works near residential properties and a land use with the potential

to increase activity on site.

551. A total of 12 statutory consultees have responded with no objections raised for

the grand permission of the proposed development subject to conditions and

informatives being appended.

552. Whilst there would be a loss of 1,229 sqm office floorspace, building at 40-41

Furnival Street, officers conclude that this is necessary for the delivery of the

proposed scheme which is considered to fall within the ‘exceptional’ category

of complimentary uses, as identified in supporting text in Local Plan Policy

DM1.1, and as such it is acceptable in principle.. The existing offices would be

a poor competitor to other buildings in better locations given they are dated and

not of high-quality in terms of their accommodation and building design. The

scheme delivers 10,341 sqm of high-quality unique cultural use with access

provided at the northwest side of the City. The loss of the modest office has

been weighed against the exceptional re-use of the adjoining heritage asset,

the inherent requirement of 40-41 Furnival Street for access/ancillary space and

the wider economic benefits the cultural use would bring to the City as a whole.

Officers consider that the proposal would not have an adverse impact on the

overall stock of floorspace in the City or prejudice the City’s role as an

international business and professional centre. The cultural space will

contribute towards diversifying the City’s visitor infrastructure, adding vibrancy

and activity for seven days per week and contribute significantly to the

achievement of the City Corporation’s Destination City ambitions and align with

the City Corporation’s wider ambitions for a post-Covid City. The loss of office

floorspace at 40-41 Furnival Street is considered acceptable on that basis.

553. The proposal makes effective use of an existing unused infrastructure and

considers a most interesting way of restoring and reusing them with reference

to their rich history which has been left unknown to date. Officers consider this

to be a respectful way to bring the tunnels back to life and educate people on

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their use at historic times. The application provisions a large heritage space to

be developed around the site's historic times with interactive ways of exploring

and learning to create stimulating experiences. It is acknowledged that any

other use would not be able to focus on the heritage and historic aspect of the

site as much as the current proposal does. The provision of a flexible exhibition

space adds to the cultural supply in the City and would create opportunities for

special exhibitions to take place to attract more diversified population.

554. The cultural use is supported on the basis of the City’s wider cultural aspirations

and the public benefits of the scheme. Such benefits include engaging with

schools by securing free school visits and training programmes, generating

employment on the site and through supply chains, tourism and spending

between £60m - £85m in the local area each year which would benefit the

economy and revitalisation of the local businesses, maximising opportunities

for local and inclusive procurements. The proposal gives the opportunity to

access and appreciate the interiors of such historically significant infrastructure

and commits to partnerships with universities and tech-institutions and co-

curation and co-creation programmes to curate the cultural spaces with the help

of local communities.

555. The site is located within the Chancery Lane conservation area. The building at

38-39 Furnival Street has been identified as a non-designated heritage asset

due to its connection to the historic Kingsway Tunnels and its rarity value. The

proposed development involves demolition in a conservation and

reconstruction of the primary facade of the No38-39.

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

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

determining the application. In weighing applications that directly or indirectly

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

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

heritage asset.” Paragraph 210 of the NPPF continuous to state that “Local

planning authorities should not permit the loss of the whole or part of a heritage

asset without taking all reasonable steps to ensure the new development will

proceed after the loss has occurred”. It is considered that the demolition of 38-

39 Furnival Street and reconstruction of the brick facade would result in loss of

part of the non-designated heritage asset but on balance this would not diminish

the overall significance of the heritage asset. Officers have taken into account

that the proposed works would improve the accessibility and visibility of this

currently unknown heritage asset to a wide public audience without distracting

from its historical and rarity value in line with London Plan Policy HC1, Local

Plan Policy CS12 and Emerging City Plan 2040 Policy S11. In line with

paragraph 210 of the NPPF, a Cultural Implementation Strategy would be

secured via Section 106, requiring a Cultural Operator to be secured prior to

any demolition works. Officers consider this as a necessary condition to ensure

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the partial loss of the non-designated heritage asset would occur only when the

operation of the proposed cultural development would be secured.

557. The Greater London Archaeological Advisory Service (GLAAS) have

recommended two-stage pre-commencement archaeological conditions

requiring a Written Scheme of Investigation (WSI) and a Historic Building

Recording to be carried out prior to any demolition works. Subject to conditions

the proposal is acceptable in archaeological terms and accords with Local Plan

Policy DM12.4 and draft City Plan Policy HE2.

558. The architectural approach is to recreate the existing building portions in terms

of massing, height as currently stand at 38-41 Furnival Street. The proposed

facade treatment includes a primary frontage of 40-41 Furnival Street

expressing the new function of the building, while it reimages the existing brick

facade of 38-39 Furnival Street to celebrate the history of the site. The

distinctive sense of separate budlings with different characters would refine a

level of neighbourly architecture while adding a level of visual interest and

character connected to the unique cultural use of the buildings and the

subterrane tunnel network. The development is sensitive to townscape contexts

at macro and local scales. The proposal would optimise the use of land, whilst

significantly improving the buildings’ interface with their surroundings. The

proposals are in overall general conformity with Local Plan Strategic Policies

CS10 (Design), London Plan Policies D3/D8 and emerging City Plan 2040

Strategic Policy S8 (Design).

559. The proposed ground floor layout and design promotes a defined, active base

of human scale expression through increased levels of glazing and interaction

with the ground floor primary use of the cultural use main entrance making a

positive contribution to the street.

560. The proposed cultural use due to its unique experience and capacity would

generate trips towards the site with a high number of visitors travelling to the

area. The site is within the Central Activities Zone and highly sustainable with

very good access to transport infrastructure and able to support active travel.

However, there would be some impact to the pedestrian comfort due to a high

number of future visitors. An appropriate package of S278 works would be

agreed in order to facilitate the development and make the development

acceptable in planning terms. Works would include providing a welcoming

pedestrian environment while coping with the increased footfall in the local

area. Other mitigation measures, conditions and obligations have also been

considered to make the application acceptable such as a future agreement of

an Events Management Plan with highways matters to be agreed on a case-

by-case basis to control servicing, possible queuing, operations, and time

restrictions for deliveries. Vehicle movements would also be increased in the

area. Around eight deliveries are expected to be generated per day by the site.

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Officers have worked closely with the applicant to identify how and when

deliveries can be facilitated. The main delivery point has been amended over

the course of the application due to the narrowness and the restricted access

of the site on Furnivall Street. The main delivery point would be from Holborn

away from residential properties and will be restricted in line with local traffic

orders and environmental health officer recommendations to protect the

amenity of local residents. Matters relating to cycle parking, car parking, taxi

drop off, and coach parking have been satisfactorily addressed.

561. The proposed buildings have been designed to ensure the site is accessible for

the greatest range of people. Step-free access is secured for the entirety of the

development. Visitors would only be able to access the ground level where the

principal entrance would be located, at 38-41 Furnival Street, the tunnels

exhibition spaces and the first and second levels where provision of a gift shop

would be made. The upper levels up to level four and the roof terrace would

only be accessible to staff. The staff accommodation area has been designed

with accessibility standards and offers end-of trip facilities and accessible

changing facilities and toilets. A public Changing Places facility would be

provided in the tunnels alongside a mix of toilets across general public

accessible areas. Details of the management and operation of the above

spaces would be required under conditions and an Access Management Plan

in the Section 106 agreement. Subject to further design details and an AMP, it

is considered that the proposal accords with the access related policies outlined

above. Overall, and subject to the imposition of conditions, the proposal would

accord with the access policies of the Local and London Plan.

562. It is noted that the majority of the objections have been around noise,

disturbance, impacts to residential amenity and traffic. This report has

considered these impacts, including any requisite mitigation which would be

secured by conditions.

563. The Environmental Health team were consulted and recommended a series of

conditions to control the noise levels generated by the operation of the cultural

use, the plant room at roof level and servicing. Negative impacts during

construction would be controlled as far as possible by the implementation of

Schemes of protective works for demolition and construction and a

Construction Logistics Plan and good site practices embodied therein. It is

recognised that there are inevitable, albeit temporary consequences of

development in a tight-knit urban environment. Post construction, compliance

with planning conditions would minimise any adverse impacts. The use of the

staff rooftop terrace would be restricted outside 8am-8pm to safeguard the

amenity of adjoining occupiers. Therefore it is considered the proposed

development complies with local plan policies regarding impact on amenity.

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564. Negative impacts during construction would be controlled as far as possible by

the implementation of Schemes of protective works for demolition and

construction and a Construction Logistics Plan and good site practices

embodied therein. It is recognised that there are inevitable, albeit temporary

consequences of development in a tight-knit urban environment. Post

construction, compliance with planning conditions would minimise any adverse

impacts.

565. The safe and secure decontamination of the site has been secured by

conditions for submission of relevant details to the local authority prior to

commencement of works.

566. In terms of daylight sunlight impacts, the proposed buildings would not deviate

significant from the existing massing. The necessary assessment has been

undertaken demonstrate a moderate to hight level of BRE compliance. it is

considered that the impact of the proposed development is considered to be

acceptable with regards nearby dwellings, in accordance with the requirements

of London Plan policy D6, Local Plan Policy DM10.7 and Policy DE7 of the draft

City Plan 2040. Considering the site’s urban context, acceptable living

standards would be maintained.

567. It is important to acknowledge the significant environmental impact associated

with the proposed development. The City of London Climate Action Strategy

supports the delivery of a net zero, climate resilient City. Local Plan policy

dictates that all development is required; to demonstrate the highest feasible

and viable sustainability standards in the design, construction, operation and

“end of life” phases of development; to minimise emissions and contribute to a

City-wide reduction in emissions: to incorporate climate change adaption

measures and urban greening, and to promote biodiversity and overall

wellbeing. Development should also avoid demolition and reduce construction

emissions through the reuse of existing buildings and by following principles of

the circular economy.

568. The London Tunnels proposal offers a unique visitors attraction which would

bring an under-utilised piece of historic infrastructure into public use, whilst

retaining 90% (by area) of the existing buildings and structures, including the

entire tunnel network bringing with it public and environmental benefits.

569. Demolition of both buildings on Furnival Street is deemed acceptable, justified

by the practical constraints of the construction process, the requirements for

achieving greater access to the Tunnel network (for visitors and equipment) as

well as the improved servicing efficiencies which can achieved through the

size/layout of a new build.

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570. The change of use of deep level tunnels, designed for emergency shelter and

secure telecommunication, to a cultural exhibition and event space offering the

potential for immersive audio-visual experiences is technically challenging and

requires an extensive amount of building services equipment to accommodate

the high visitor numbers targeted/anticipated, and to meet high cooling loads

particularly associated with audio-visual equipment.

571. The building operations and maintenance and replacement works over the

building’s lifespan (primarily attributed to servicing equipment) have a high

carbon intensity (emissions rate per m2). Embodied emissions associated with

MEP equipment alone are estimated to be 40% of WLC embodied emissions

with a further 40% of WLC emissions attributed to operational energy use. A

highly efficient cooling system with heat recovery has been designed to manage

over-heating within the tunnel network but the amount of waste heat expelled

to the atmosphere remains significant without a connection to a local area

network or neighbouring site, neither of which are currently proposed.

572. The total quantity of audio-visual equipment has a very significant impact on

overall energy use and cooling demand which in turn affect both operational

and embodied carbon emissions (due to the increase in quantity of cooling

equipment). Therefore, the special exhibitions and events component of the

proposal (and the type and frequency thereof) has a significant impact on the

sustainability of the development. The impact could be reduced through a

responsible Cultural Implementation Strategy and Management Plan.

573. The proposed development offers an increase in urban greening and

biodiversity, and an improved surface water run-off rate. Although these

contributions are relatively small, they are acceptable in policy terms due to the

limited area of the site which sits above ground.

574. The development proposal is currently targeting a BREEAM rating of ‘Very

Good’ which falls short of the City’s policy requirement of ‘Excellent.’ The pre-

assessment demonstrated good potential to achieve an Excellent rating. Given

this assessment and the wider environmental impact, the development is

therefore expected to make best efforts to achieve a minimum rating of

‘Excellent’. A condition has been recommended to secure requirements are

met.

575. In terms of fire safety, the proposal integrates a series of measures to control

fire and keep people in safety until they egress. A fire evacuation strategy and

fire-fighters emergency access and fire elimination equipment would be

strategically implemented on site. City’s District Surveyor has reviewed the

submitted Fire Statement and raised no objections. Whilst London Fire Brigade

raised questions about how the detailed design of the scheme would be able to

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satisfy some of their concerns, it is considered that the exact design and

methodologies would be only available post planning and during the Qualitative

Design Review (QDR) process. The applicant has committed to consult LFB as

a key stakeholder at that stage. An informative has been recommended as a

reminder.

576. Therefore overall, it is considered that the proposed cultural use would not

prejudice the primary business function of the City; it would contribute to the

City’s aspirations for evening and weekend economy; it would generate local

spend between £60m - £85m each year and create new jobs; promote balance

and mix of uses in the immediate locality; and would not result in unacceptable

adverse impacts on the amenity of neighbouring properties.

577. The proposals are considered to be in accordance with the development plan

when taken as whole.

578. The Local Planning Authority must determine the application in accordance with

the development plan unless other material considerations indicate otherwise.

579. It is the view of officers that as the proposal complies with the Development

Plan when considered as a whole and as other material considerations also

weigh in favour of the scheme, planning permission should be granted as set

out in the recommendation and the schedules attached.

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Appendix A - Background Papers

List if Application Documents:

Application Covering Letter (30/11/2023)

Application Form & Certificates (30/11/2023)

Community Infrastructure Levy Form (18/12/2023)

Site Location Plan 2 (Below Ground & Tunnels Complex) (30/11/2023)

Site Location Plan 3 (Site Boundaries) (15/12/2023)

Site Plan (30/11/2023)

Design and Access Statement (30/11/2023)

Accessibility Assessment (30/11/2023)

Planning Statement (30/11/2023)

Heritage Statement (30/11/2023)

Archaeological Desk Based Assessment (30/11/2023)

Cultural Plan (30/11/2023)

Statement of Community Involvement (30/11/2023)

Socio-Economic Assessment (30/11/2023)

Sunlight & Daylight Assessment (30/11/2023)

Air Quality Assessment (30/11/2023)

BREEAM Pre-Assessment Report (30/11/2023)

Circular Economy Statement (30/11/2023)

Construction Traffic Management Plan (30/11/2023)

Delivery & Servicing Plan (17/05/2024)

Energy Statement & Overheating Assessment (30/11/2023)

Fire Statement (30/11/2023)

Flood Risk Assessment & Outline Drainage Strategy (30/11/2023)

Framework Travel Plan (17/05/2024)

Geotech Basement Impact Assessment (30/11/2023)

Noise and Vibration Impact Assessment (30/11/2023)

Pre-demolition Audit (30/11/2023)

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Security Report (30/11/2023)

Structural Report (30/11/2023)

Sustainability Statement (30/11/2023)

Transport Assessment (17/05/2024)

Waste Management Plan (05/05/2024)

Whole Life-Cycle Carbon Assessment (30/11/2023)

Health Impact Assessment (18/12/2023)

Adaptation to Climate Change Report (13/03/2024)

Loss of Office Policy Note (11/04/2024)

Lighting Strategy Report (12/04/2024)

Equality Impact Assessment (03/05/2024)

Flood Risk Evacuation Strategy (15/05/2024)

Supplementary Air Quality Response (06/03/24)

Daylight Sunlight Response 1 (05/03/2024)

Daylight Sunlight Response 2 (26/03/24)

WSP responses to Sustainability queries (22/04/24, 02/05/24 and 13/05/2024)

Cultural Plan responses, Email (14/05/2024)

Fire Statement Response to LFB letter (14/05/24)

Design Supplementary Clarification 01 – Furnival Street (17/05/2024)

Design Supplementary Clarification 02 – Accessibility (17/05/2024)

Design Supplementary Clarification 03 – 39 Furnival Street Fabric Retention

(17/05/2024).

party reviews

3rd Party Review of Whole Life Carbon Assessment Report by Civic Engineers

(14/03/24)

Internal Consultee Responses

Memo, 29/12/23, Environmental Health Officer

Memo, 24/01/24, District Surveyors Office

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Memo, 24/01/24, Lead Local Flood Authority

Memo, 23/02/24, Environmental Resilience Officer

Email, 18/04/24, Cleansing Team

Memo, 11/03/24, Air Quality Officer

Email, 16/05/24, City of London Police

Email, 17/05/24, COL Police - Counter Terrorism

Email, 22/05/24, Environmental Resilience Officer

Representations

Support

29/01/24, Mr Colin Matthews, Online

29/01/24, Mr Philip Nash, Online

29/01/24, Ms Susan Smith, Online

31/01/24, Mrs Robyn Brook, Online

31/01/24, Mr James Loxton, Online

01/02/24, Mr KENNETH GOLBY, Online

01/02/24, Mr George Harris, Online

01/02/24, Mr Max Tobias, Online

01/02/24, Mr peter conniff, Online

02/02/24, Mr William Morris, Online

06/02/24, Mr Stuart Perl, Online

14/02/24, Mr Andrew Raca, Online

18/02/24, Mr Andrew Raca, Online

20/02/24, Ms Wendy Lyons, Online

20/02/24, Mr Charles Parry, Online

20/02/24, Miss Chelsea Cooper, Online

20/02/24, Mr Thomas Seabourne, Online

23/02/24, Miss Angela Dunning , Online

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26/02/24, Mrs Sue Macdiarmid, Online

26/02/24, Mr Graham Wingham, Online

26/02/24, Ms Angela Epps, Online

26/02/24, Ms Caroline Gallagher , Online

27/02/24, Mr Neil Emberson, Online

27/02/24, Mr DEREK OWEN, Online

27/02/24, Mr Patrick Ralph, Online

27/02/24, Mrs Sandra Murphy, Online

27/02/24, Dr GABRIEL GOLDMAN, Online

27/02/24, Mr PAUL SCOTT, Online

27/02/24, Mr Jp Ralph, Online

27/02/24, Mr Stephen Luderman, Online

27/02/24, Justin Manley-Cooper, Online

27/02/24, Nick Finegold, Online

28/02/24, Mr Adam Fayed, Online

28/02/24, Mr Gregory Jones KC, Online

28/02/24, Mr David Brown, Online

28/02/24, Alex Hayes-Griffin, Online

28/02/24, Mr chris sullivan, Online

28/02/24, Mr Daniel van Vuuren, Online

28/02/24, Mr Luis Esguevillas, Online

28/02/24, Mr win man, Online

29/02/24, Mr David EH Yeoh, Online

29/02/24, Mr Guy Brook, Online

29/02/24, Miss Heidi Bryant, Online

29/02/24, Ms Helen McDowell, Online

01/03/24, Mr Michael Brown, Online

01/03/24, Dr Geoff Ferreira, Online

06/03/24, Mr Adam Pollock, Online

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14/03/24, Mr Lawrence Yew, Online

14/03/24, Mr Maggie Lai, Online

14/03/24, Dr Lai Meng Looi, Online

17/03/24, Mr Alistair Sommerlad, Online

11/04/24, Ms Maria Nieves Garcia Somoza, Online

02/05/24, Mr James Hacking, Online

21/05/24, Central District Alliance

23/05/24, Fleet Street Quarter

Objections

27/12/23, Mrs G Birri, Email, Objection

28/12/23, Ms Lidia Zazzera, Online

30/12/23, Lord John Krebs, Online

03/01/24, Leyi Wang, Email

04/01/24, Mrs Nina Keay, Online

04/01/24, Lisa Zazzera, Email

08/01/24, Walter Scott, Email

08/01/24, Mr James Keay, Online

08/01/24, Mr Brian Cotsen, Online

08/01/24, Brian Cotsen, Email

09/01/24, LEYI WANG, Online

09/01/24, Liz Speirs, Email,

10/01/24, Miss Meihan Dong, Online

10/01/24, Chloe Nash, Email

11/01/24, C Murphy, Online

11/01/24, Anonymous, Email

13/01/24, Mr Jack Watkins , Online

14/01/24, Professor Susan V. Scott, Email

30/01/24, Furnival Management Limited, Email

04/02/24, Miss Lisa Dickenson, Online

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16/02/24 - 16:44, Chancery Exchange, Email

20/04/24, Mr & Mrs Birri, Email

27/04/24, Furnival Management Limited, Email

13/05/24, Coralie Murphy, Online

Neutral

29/01/24 - 15:15, Mr Oscar Li, Online

23/03/24 - 15:39, Mr Stephan Fels, Online

24/04/24 - 12:47, Mr Andrew Green, Online

External consultees

02/01/24, Historic England

04/01/24, Historic England (GLAAS)

09/01/24, Transport For London (Infrastructure Protection)

24/01/24, Westminster City Council

29/02/24, Thames Water

07/03/24, Conservation Area Advisory Committee (CAAC)

13/03/24, Environment Agency

19/04/24, Transport For London (Spatial Planning)

22/04/24, London Fire Brigade

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Appendix B

Relevant Local Plan Policies

CS1 Provide additional offices

To ensure the City of London provides additional office development of the highest

quality to meet demand from long term employment growth and strengthen the

beneficial cluster of activities found in and near the City that contribute to London's

role as the world's leading international financial and business centre.

CS2 Facilitate utilities infrastructure

To co-ordinate and facilitate infrastructure planning and delivery to ensure that the

functioning and growth of the City's business, resident, student and visitor

communities is not limited by provision of utilities and telecommunications

infrastructure.

CS3 Ensure security from crime/terrorism

To ensure that the City is secure from crime, disorder and terrorism, has safety

systems of transport and is designed and managed to satisfactorily accommodate

large numbers of people, thereby increasing public and corporate confidence in the

City's role as the world's leading international financial and business centre.

CS4 Seek planning contributions

To manage the impact of development, seeking appropriate developer contributions.

CS10 Promote high quality environment

To promote a high standard and sustainable design of buildings, streets and spaces,

having regard to their surroundings and the character of the City and creating an

inclusive and attractive environment.

CS11 Encourage art, heritage and culture

To maintain and enhance the City's contribution to London's world-class cultural status

and to enable the City's communities to access a range of arts, heritage and cultural

experiences, in accordance with the City Corporation's Destination Strategy.

CS12 Conserve or enhance heritage assets

To conserve or enhance the significance of the City's heritage assets and their

settings, and provide an attractive environment for the City's communities and visitors.

CS13 Protect/enhance significant views

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To protect and enhance significant City and London views of important buildings,

townscape and skylines, making a substantial contribution to protecting the overall

heritage of the City's landmarks.

CS14 Tall buildings in suitable places

To allow tall buildings of world class architecture and sustainable design in suitable

locations and to ensure that they take full account of the character of their

surroundings, enhance the skyline and provide a high quality public realm at ground

level.

CS15 Creation of sustainable development

To enable City businesses and residents to make sustainable choices in their daily

activities creating a more sustainable City, adapted to the changing climate.

CS16 Improving transport and travel

To build on the City's strategic central London position and good transport

infrastructure to further improve the sustainability and efficiency of travel in, to, from

and through the City.

CS17 Minimising and managing waste

To support City businesses, residents and visitors in making sustainable choices

regarding the minimisation, transport and management of their waste, capitalising on

the City's riverside location for sustainable waste transfer and eliminating reliance on

landfill for municipal solid waste (MSW).

CS18 Minimise flood risk

To ensure that the City remains at low risk from all types of flooding.

CS19 Improve open space and biodiversity

To encourage healthy lifestyles for all the City's communities through improved access

to open space and facilities, increasing the amount and quality of open spaces and

green infrastructure, while enhancing biodiversity.

CS20 Improve retail facilities

To improve the quantity and quality of retailing and the retail environment, promoting

the development of the five Principal Shopping Centres and the linkages between

them.

CS21 Protect and provide housing

To protect existing housing and amenity and provide additional housing in the City,

concentrated in or near identified residential areas, as shown in Figure X, to meet the

City's needs, securing suitable, accessible and affordable housing and supported

housing.

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CS22 Maximise community facilities

To maximise opportunities for the City's residential and working communities to

access suitable health, social and educational facilities and opportunities, while

fostering cohesive communities and healthy lifestyles.

DM1.1 Protection of office accommodation

To refuse the loss of existing (B1) office accommodation to other uses where the

building or its site is considered to be suitable for long-term viable office use and there

are strong economic reasons why the loss would be inappropriate. Losses would be

inappropriate for any of the following reasons: prejudicing the primary business

function of the City;

• jeopardising the future assembly and delivery of large office development sites;

• removing existing stock for which there is demand in the office market or long

term viable need;

• introducing uses that adversely affect the existing beneficial mix of commercial

uses.

DM1.3 Small and medium business units

To promote small and medium sized businesses in the City by encouraging:

a) new accommodation suitable for small and medium sized businesses or

occupiers;

b) office designs which are flexible and adaptable to allow for sub-division to create

small and medium sized business units;

c) continued use of existing small and medium sized units which meet occupier

needs.

DM1.5 Mixed uses in commercial areas

To encourage a mix of commercial uses within office developments which contribute

to the City's economy and character and provide support services for its businesses,

workers and residents.

DM2.1 Infrastructure provision

1) Developers will be required to demonstrate, in conjunction with utility providers,

that there will be adequate utility infrastructure capacity, both on and off the site, to

serve the development during construction and operation. Development should not

lead to capacity or reliability problems in the surrounding area. Capacity projections

must take account of climate change impacts which may influence future infrastructure

demand.

2) Utility infrastructure and connections must be designed into and integrated with the

development wherever possible. As a minimum, developers should identify and plan

for:

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a) electricity supply to serve the construction phase and the intended use for the

site, and identify, in conjunction with electricity providers, Temporary Building

Supply(TBS) for the construction phase and the estimated load capacity of the

building and the substations and routes for supply;

b) reasonable gas and water supply considering the need to conserve natural

resources;

c) heating and cooling demand and the viability of its provision via decentralised

energy (DE) networks. Designs must incorporate access to existing DE networks

where feasible and viable;

d) telecommunications network demand, including wired and wireless

infrastructure, planning for dual entry provision, where possible, through communal

entry chambers and flexibility to address future technological improvements;

e) separate surface water and foul drainage requirements within the proposed

building or site, including provision of Sustainable Drainage Systems (SuDS),

rainwater harvesting and grey-water recycling, minimising discharge to the

combined sewer network.

3) In planning for utility infrastructure developers and utility providers must provide

entry and connection points within the development which relate to the City's

established utility infrastructure networks, utilising pipe subway routes wherever

feasible. Sharing of routes with other nearby developments and the provision of new

pipe subway facilities adjacent to buildings will be encouraged.

4) Infrastructure provision must be completed prior to occupation of the development.

Where potential capacity problems are identified and no improvements are

programmed by the utility company, the City Corporation will require the developer to

facilitate appropriate improvements, which may require the provision of space within

new developments for on-site infrastructure or off-site infrastructure upgrades.

DM3.2 Security measures

To ensure that security measures are included in new developments, applied to

existing buildings and their curtilage, by requiring:

a) building-related security measures, including those related to the servicing of the

building, to be located within the development's boundaries;

b) measures to be integrated with those of adjacent buildings and the public realm;

c) that security is considered at the concept design or early developed design

phases of all development proposals to avoid the need to retro-fit measures that

impact on the public realm;

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d) developers to seek recommendations from the City of London Police

Architectural Liaison Officer at the design stage. New development should meet

Secured by Design principles;

e) the provision of service management plans for all large development,

demonstrating that vehicles seeking access to the building can do so without

waiting on the public highway;

f) an assessment of the environmental impact of security measures, particularly

addressing visual impact and impact on pedestrian flows.

DM3.3 Crowded places

On all major developments, applicants will be required to satisfy principles and

standards that address the issues of crowded places and counter-terrorism, by:

a) conducting a full risk assessment;

b) keeping access points to the development to a minimum;

c) ensuring that public realm and pedestrian permeability associated with a building

or site is not adversely impacted, and that design considers the application of

Hostile Vehicle Mitigation measures at an early stage;

d) ensuring early consultation with the City of London Police on risk mitigation

measures;

e) providing necessary measures that relate to the appropriate level of crowding in

a site, place or wider area.

DM3.4 Traffic management

To require developers to reach agreement with the City Corporation and TfL on the

design and implementation of traffic management and highways security measures,

including addressing the management of service vehicles, by:

a) consulting the City Corporation on all matters relating to servicing;

b) restricting motor vehicle access, where required;

c) implementing public realm enhancement and pedestrianisation schemes, where

appropriate;

d) using traffic calming, where feasible, to limit the opportunity for hostile vehicle

approach.

DM3.5 Night-time entertainment

1) Proposals for new night-time entertainment and related uses and the extension of

existing premises will only be permitted where it can be demonstrated that, either

individually or cumulatively, there is no unacceptable impact on:

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a) the amenity of residents and other noise-sensitive uses;

b) environmental amenity, taking account of the potential for noise, disturbance

and odours arising from the operation of the premises, customers arriving at and

leaving the premises and the servicing of the premises.

2) Applicants will be required to submit Management Statements detailing how these

issues will be addressed during the operation of the premises.

DM10.1 New development

To require all developments, including alterations and extensions to existing buildings,

to be of a high standard of design and to avoid harm to the townscape and public

realm, by ensuring that:

a) the bulk and massing of schemes are appropriate in relation to their

surroundings and have due regard to the general scale, height, building lines,

character, historic interest and significance, urban grain and materials of the

locality and relate well to the character of streets, squares, lanes, alleys and

passageways;

b) all development is of a high standard of design and architectural detail with

elevations that have an appropriate depth and quality of modelling;

c) appropriate, high quality and durable materials are used;

d) the design and materials avoid unacceptable wind impacts at street level or

intrusive solar glare impacts on the surrounding townscape and public realm;

e) development has attractive and visually interesting street level elevations,

providing active frontages wherever possible to maintain or enhance the vitality of

the City's streets;

f) the design of the roof is visually integrated into the overall design of the building

when seen from both street level views and higher level viewpoints;

g) plant and building services equipment are fully screened from view and

integrated in to the design of the building. Installations that would adversely affect

the character, appearance or amenities of the buildings or area will be resisted;

h) servicing entrances are designed to minimise their effects on the appearance of

the building and street scene and are fully integrated into the building's design;

i) there is provision of appropriate hard and soft landscaping, including appropriate

boundary treatments;

j) the external illumination of buildings is carefully designed to ensure visual

sensitivity, minimal energy use and light pollution, and the discreet integration of

light fittings into the building design;

k) there is provision of amenity space, where appropriate;

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l) there is the highest standard of accessible and inclusive design.

DM10.2 Design of green roofs and walls

1) To encourage the installation of green roofs on all appropriate developments. On

each building the maximum practicable coverage of green roof should be achieved.

Extensive green roofs are preferred and their design should aim to maximise the roof's

environmental benefits, including biodiversity, run-off attenuation and building

insulation.

2) To encourage the installation of green walls in appropriate locations, and to ensure

that they are satisfactorily maintained.

DM10.3 Roof gardens and terraces

1) To encourage high quality roof gardens and terraces where they do not:

a) immediately overlook residential premises;

b) adversely affect rooflines or roof profiles;

c) result in the loss of historic or locally distinctive roof forms, features or coverings;

d) impact on identified views.

2) Public access will be sought where feasible in new development.

DM10.4 Environmental enhancement

The City Corporation will work in partnership with developers, Transport for London

and other organisations to design and implement schemes for the enhancement of

highways, the public realm and other spaces. Enhancement schemes should be of a

high standard of design, sustainability, surface treatment and landscaping, having

regard to:

a) the predominant use of the space, surrounding buildings and adjacent spaces;

b) connections between spaces and the provision of pleasant walking routes;

c) the use of natural materials, avoiding an excessive range and harmonising with

the surroundings of the scheme and materials used throughout the City;

d) the inclusion of trees and soft landscaping and the promotion of biodiversity,

where feasible linking up existing green spaces and routes to provide green

corridors;

e) the City's heritage, retaining and identifying features that contribute positively to

the character and appearance of the City;

f) sustainable drainage, where feasible, co-ordinating the design with adjacent

buildings in order to implement rainwater recycling;

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g) the need to provide accessible and inclusive design, ensuring that streets and

walkways remain uncluttered;

h) the need for pedestrian priority and enhanced permeability, minimising the

conflict between pedestrians and cyclists;

i) the need to resist the loss of routes and spaces that enhance the City's function,

character and historic interest;

j) the use of high quality street furniture to enhance and delineate the public realm;

k) lighting which should be sensitively co-ordinated with the design of the scheme.

DM10.7 Daylight and sunlight

1) To resist development which would reduce noticeably the daylight and sunlight

available to nearby dwellings and open spaces to unacceptable levels, taking account

of the Building Research Establishment's guidelines.

2) The design of new developments should allow for the lighting needs of intended

occupiers and provide acceptable levels of daylight and sunlight.

DM10.8 Access and inclusive design

To achieve an environment that meets the highest standards of accessibility and

inclusive design in all developments (both new and refurbished), open spaces and

streets, ensuring that the City of London is:

a) inclusive and safe for of all who wish to use it, regardless of disability, age,

gender, ethnicity, faith or economic circumstance;

b) convenient and welcoming with no disabling barriers, ensuring that everyone

can experience independence without undue effort, separation or special

treatment;

c) responsive to the needs of all users who visit, work or live in the City, whilst

recognising that one solution might not work for all.

DM11.1 Protection of Visitor, Arts and Cultural Facilities

1) To resist the loss of existing visitor, arts and cultural facilities unless:

a) replacement facilities are provided on-site or within the vicinity which meet the

needs of the City's communities; or

b) they can be delivered from other facilities without leading to or increasing any

shortfall in provision, and it has been demonstrated that there is no demand for

another similar use on the site; or

c) it has been demonstrated that there is no realistic prospect of the premises being

used for a similar purpose in the foreseeable future.

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2) Proposals resulting in the loss of visitor, arts and cultural facilities must be

accompanied by evidence of the lack of need for those facilities. Loss of facilities will

only be permitted where it has been demonstrated that the existing floorspace has

been actively marketed as a visitor, arts or cultural facility at reasonable terms.

DM11.2 Public Art

To enhance the City's public realm and distinctive identity by:

a) protecting existing works of art and other objects of cultural significance and

encouraging the provision of additional works in appropriate locations;

b) ensuring that financial provision is made for the future maintenance of new

public art;

c) requiring the appropriate reinstatement or re-siting of art works and other objects

of cultural significance when buildings are redeveloped.

DM12.1 Change affecting heritage assets

1. To sustain and enhance heritage assets, their settings and significance.

2. Development proposals, including proposals for telecommunications infrastructure,

that have an effect upon heritage assets, including their settings, should be

accompanied by supporting information to assess and evaluate the significance of

heritage assets and the degree of impact caused by the development.

3. The loss of routes and spaces that contribute to the character and historic interest

of the City will be resisted.

4. Development will be required to respect the significance, character, scale and

amenities of surrounding heritage assets and spaces and their settings.

5. Proposals for sustainable development, including the incorporation of climate

change adaptation measures, must be sensitive to heritage assets.

DM12.2 Development in conservation areas

1. Development in conservation areas will only be permitted if it preserves and

enhances the character or appearance of the conservation area.

2. The loss of heritage assets that make a positive contribution to the character or

appearance of a conservation area will be resisted.

3. Where permission is granted for the demolition of a building in a conservation area,

conditions will be imposed preventing demolition commencing prior to the approval of

detailed plans of any replacement building, and ensuring that the developer has

secured the implementation of the construction of the replacement building.

DM12.3 Listed buildings

1. To resist the demolition of listed buildings.

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2. To grant consent for the alteration or change of use of a listed building only where

this would not detract from its special architectural or historic interest, character and

significance or its setting.

DM12.4 Archaeology

1. To require planning applications which involve excavation or ground works on sites

of archaeological potential to be accompanied by an archaeological assessment and

evaluation of the site, including the impact of the proposed development.

2. To preserve, protect, safeguard and enhance archaeological monuments, remains

and their settings in development, and to seek a public display and interpretation,

where appropriate.

3. To require proper investigation and recording of archaeological remains as an

integral part of a development programme, and publication and archiving of results to

advance understanding.

DM15.1 Sustainability requirements

1. Sustainability Statements must be submitted with all planning applications in order

to ensure that sustainability is integrated into designs for all development.

2. For major development (including new development and refurbishment) the

Sustainability Statement should include as a minimum:

a) BREEAM or Code for Sustainable Homes pre-assessment;

b) an energy statement in line with London Plan requirements;

c) demonstration of climate change resilience measures.

3. BREEAM or Code for Sustainable Homes assessments should demonstrate

sustainability in aspects which are of particular significance in the City's high density

urban environment. Developers should aim to achieve the maximum possible credits

to address the City's priorities.

4. Innovative sustainability solutions will be encouraged to ensure that the City's

buildings remain at the forefront of sustainable building design. Details should be

included in the Sustainability Statement.

5. Planning conditions will be used to ensure that Local Plan assessment targets are

met.

DM15.2 Energy and CO2 emissions

1. Development design must take account of location, building orientation, internal

layouts and landscaping to reduce likely energy consumption.

2. For all major development energy assessments must be submitted with the

application demonstrating:

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a) energy efficiency - showing the maximum improvement over current Building

Regulations to achieve the required Fabric Energy Efficiency Standards;

b) carbon compliance levels required to meet national targets for zero carbon

development using low and zero carbon technologies, where feasible;

c) where on-site carbon emission reduction is unviable, offsetting of residual CO2

emissions through "allowable solutions" for the lifetime of the building to achieve

national targets for zero-carbon homes and non-domestic buildings. Achievement

of zero carbon buildings in advance of national target dates will be encouraged;

d) anticipated residual power loads and routes for supply.

DM15.3 Low and zero carbon technologies

1. For development with a peak heat demand of 100 kilowatts or more developers

should investigate the feasibility and viability of connecting to existing decentralised

energy networks. This should include investigation of the potential for extensions of

existing heating and cooling networks to serve the development and development of

new networks where existing networks are not available. Connection routes should be

designed into the development where feasible and connection infrastructure should

be incorporated wherever it is viable.

2. Where connection to offsite decentralised energy networks is not feasible,

installation of on-site CCHP and the potential to create new localised decentralised

energy infrastructure through the export of excess heat must be considered

3. Where connection is not feasible or viable, all development with a peak heat

demand of 100 kilowatts or more should be designed to enable connection to potential

future decentralised energy networks.

4. Other low and zero carbon technologies must be evaluated. Non combustion based

technologies should be prioritised in order to avoid adverse impacts on air quality.

DM15.4 Offsetting carbon emissions

1. All feasible and viable on-site or near-site options for carbon emission reduction

must be applied before consideration of offsetting. Any remaining carbon emissions

calculated for the lifetime of the building that cannot be mitigated on-site will need to

be offset using "allowable solutions".

2. Where carbon targets cannot be met on-site the City Corporation will require carbon

abatement elsewhere or a financial contribution, negotiated through a S106 planning

obligation to be made to an approved carbon offsetting scheme.

3. Offsetting may also be applied to other resources including water resources and

rainwater run-off to meet sustainability targets off-site where on-site compliance is not

feasible.

DM15.5 Climate change resilience

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1. Developers will be required to demonstrate through Sustainability Statements that

all major developments are resilient to the predicted climate conditions during the

building's lifetime.

2. Building designs should minimise any contribution to the urban heat island effect

caused by heat retention and waste heat expulsion in the built environment.

DM15.6 Air quality

1. Developers will be required to consider the impact of their proposals on air quality

and, where appropriate, provide an Air Quality Impact Assessment.

2. Development that would result in deterioration of the City's nitrogen dioxide or

PM10 pollution levels will be resisted.

3. Major developments will be required to maximise credits for the pollution section of

the BREEAM or Code for Sustainable Homes assessment relating to on-site

emissions of oxides of nitrogen (NOx).

4. Developers will be encouraged to install non-combustion low and zero carbon

energy technology. A detailed air quality impact assessment will be required for

combustion based low and zero carbon technologies, such as CHP plant and biomass

or biofuel boilers, and necessary mitigation must be approved by the City Corporation.

5. Construction and deconstruction and the transport of construction materials and

waste must be carried out in such a way as to minimise air quality impacts.

6. Air intake points should be located away from existing and potential pollution

sources (e.g. busy roads and combustion flues). All combustion flues should terminate

above the roof height of the tallest building in the development in order to ensure

maximum dispersion of pollutants.

DM15.7 Noise and light pollution

1. Developers will be required to consider the impact of their developments on the

noise environment and where appropriate provide a noise assessment. The layout,

orientation, design and use of buildings should ensure that operational noise does not

adversely affect neighbours, particularly noise-sensitive land uses such as housing,

hospitals, schools and quiet open spaces.

2. Any potential noise conflict between existing activities and new development should

be minimised. Where the avoidance of noise conflicts is impractical, mitigation

measures such as noise attenuation and restrictions on operating hours will be

implemented through appropriate planning conditions.

3. Noise and vibration from deconstruction and construction activities must be

minimised and mitigation measures put in place to limit noise disturbance in the vicinity

of the development.

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4. Developers will be required to demonstrate that there will be no increase in

background noise levels associated with new plant and equipment.

5. Internal and external lighting should be designed to reduce energy consumption,

avoid spillage of light beyond where it is needed and protect the amenity of light-

sensitive uses such as housing, hospitals and areas of importance for nature

conservation.

DM15.8 Contaminated land and water quality

Where development involves ground works or the creation of open spaces, developers

will be expected to carry out a detailed site investigation to establish whether the site

is contaminated and to determine the potential for pollution of the water environment

or harm to human health and non-human receptors. Suitable mitigation must be

identified to remediate any contaminated land and prevent potential adverse impacts

of the development on human and non-human receptors, land or water quality.

DM16.1 Transport impacts of development

1. Development proposals that are likely to have effects on transport must be

accompanied by an assessment of the transport implications during both construction

and operation, in particular addressing impacts on:

a) road dangers;

b) pedestrian environment and movement;

c) cycling infrastructure provision;

d) public transport;

e) the street network.

2. Transport Assessments and Travel Plans should be used to demonstrate

adherence to the City Corporation's transportation standards.

DM16.2 Pedestrian movement

1. Pedestrian movement must be facilitated by provision of suitable pedestrian routes

through and around new developments, by maintaining pedestrian routes at ground

level, and the upper level walkway network around the Barbican and London Wall.

2. The loss of a pedestrian route will normally only be permitted where an alternative

public pedestrian route of at least an equivalent standard is provided having regard

to:

a) the extent to which the route provides for current and all reasonably foreseeable

future demands placed upon it, including at peak periods;

b) the shortest practicable routes between relevant points.

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3. Routes of historic importance should be safeguarded as part of the City's

characteristic pattern of lanes, alleys and courts, including the route's historic

alignment and width.

4. The replacement of a route over which pedestrians have rights, with one to which

the public have access only with permission will not normally be acceptable.

5. Public access across private land will be encouraged where it enhances the

connectivity, legibility and capacity of the City's street network. Spaces should be

designed so that signage is not necessary and it is clear to the public that access is

allowed.

6. The creation of new pedestrian rights of way will be encouraged where this would

improve movement and contribute to the character of an area, taking into

consideration pedestrian routes and movement in neighbouring areas and boroughs,

where relevant.

DM16.3 Cycle parking

1. On-site cycle parking must be provided in accordance with the local standards set

out in Table 16.2 or, for other land uses, with the standards of the London Plan.

Applicants will be encouraged to exceed the standards set out in Table 16.2.

2. On-street cycle parking in suitable locations will be encouraged to meet the needs

of cyclists.

DM16.4 Encouraging active travel

1. Ancillary facilities must be provided within new and refurbished buildings to support

active transport modes such as walking, cycling and running. All commercial

development should make sufficient provision for showers, changing areas and

lockers/storage to cater for employees wishing to engage in active travel.

2. Where facilities are to be shared with a number of activities they should be

conveniently located to serve all proposed activities.

DM16.5 Parking and servicing standards

1. Developments in the City should be car-free except for designated Blue Badge

spaces. Where other car parking is exceptionally provided it must not exceed London

Plan's standards.

2. Designated parking must be provided for Blue Badge holders within developments

in conformity with London Plan requirements and must be marked out and reserved

at all times for their use. Disabled parking spaces must be at least 2.4m wide and at

least 4.8m long and with reserved areas at least 1.2m wide, marked out between the

parking spaces and at the rear of the parking spaces.

3. Except for dwelling houses (use class C3), whenever any car parking spaces (other

than designated Blue Badge parking) are provided, motor cycle parking must be

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provided at a ratio of 10 motor cycle parking spaces per 1 car parking space. At least

50% of motor cycle parking spaces must be at least 2.3m long and at least 0.9m

wide and all motor cycle parking spaces must be at least 2.0m long and at least 0.8m

wide.

4. On site servicing areas should be provided to allow all goods and refuse collection

vehicles likely to service the development at the same time to be conveniently loaded

and unloaded. Such servicing areas should provide sufficient space or facilities for all

vehicles to enter and exit the site in a forward gear. Headroom of at least 5m where

skips are to be lifted and 4.75m for all other vehicle circulation areas should be

provided.

5. Coach parking facilities for hotels (use class C1) will not be permitted.

6. All off-street car parking spaces and servicing areas must be equipped with the

facility to conveniently recharge electric vehicles.

7. Taxi ranks are encouraged at key locations, such as stations, hotels and shopping

centres. The provision of taxi ranks should be designed to occupy the minimum

practicable space, using a combined entry and exit point to avoid obstruction to other

transport modes.

DM17.1 Provision for waste

1. Waste facilities must be integrated into the design of buildings, wherever feasible,

and allow for the separate storage and collection of recyclable materials, including

compostable material.

2. On-site waste management, through techniques such as recyclate sorting or

energy recovery, which minimises the need for waste transfer, should be incorporated

wherever possible.

DM17.2 Designing out construction waste

New development should be designed to minimise the impact of deconstruction and

construction waste on the environment through:

a) reuse of existing structures;

b) building design which minimises wastage and makes use of recycled materials;

c) recycling of deconstruction waste for reuse on site where feasible;

d) transport of waste and construction materials by rail or river wherever

practicable;

e) application of current best practice with regard to air quality, dust, hazardous

waste, waste handling and waste management .

DM18.1 Development in Flood Risk Area

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1. Where development is proposed within the City Flood Risk Area evidence must be

presented to demonstrate that:

a) the site is suitable for the intended use (see table 18.1), in accordance with

Environment Agency and Lead Local Flood Authority advice;

b) the benefits of the development outweigh the flood risk to future occupants;

c) the development will be safe for occupants and visitors and will not compromise

the safety of other premises or increase the risk of flooding elsewhere.

2. Development proposals, including change of use, must be accompanied by a site-

specific flood risk assessment for:

a) all sites within the City Flood Risk Area as shown on the Policies Map; and

b) all major development elsewhere in the City.

3. Site specific flood risk assessments must address the risk of flooding from all

sources and take account of the City of London Strategic Flood Risk Assessment.

Necessary mitigation measures must be designed into and integrated with the

development and may be required to provide protection from flooding for properties

beyond the site boundaries, where feasible and viable.

4. Where development is within the City Flood Risk Area, the most vulnerable uses

must be located in those parts of the development which are at least risk. Safe access

and egress routes must be identified.

5. For minor development outside the City Flood Risk Area, an appropriate flood risk

statement may be included in the Design and Access Statement.

6. Flood resistant and resilient designs which reduce the impact of flooding and

enable efficient recovery and business continuity will be encouraged.

DM18.2 Sustainable drainage systems

1. The design of the surface water drainage system should be integrated into the

design of proposed buildings or landscaping, where feasible and practical, and should

follow the SuDS management train (Fig T) and London Plan drainage hierarchy.

2. SuDS designs must take account of the City's archaeological heritage, complex

underground utilities, transport infrastructure and other underground structures,

incorporating suitable SuDS elements for the City's high density urban situation.

3. SuDS should be designed, where possible, to maximise contributions to water

resource efficiency, biodiversity enhancement and the provision of multifunctional

open spaces.

DM19.1 Additional open space

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1. Major commercial and residential developments should provide new and enhanced

open space where possible. Where on-site provision is not feasible, new or enhanced

open space should be provided near the site, or elsewhere in the City.

2. New open space should:

a) be publicly accessible where feasible; this may be achieved through a legal

agreement;

b) provide a high quality environment;

c) incorporate soft landscaping and Sustainable Drainage Systems, where

practicable;

d) have regard to biodiversity and the creation of green corridors;

e) have regard to acoustic design to minimise noise and create tranquil spaces.

3. The use of vacant development sites to provide open space for a temporary period

will be encouraged where feasible and appropriate.

DM19.2 Biodiversity and urban greening

Developments should promote biodiversity and contribute to urban greening by

incorporating:

a) green roofs and walls, soft landscaping and trees;

b) features for wildlife, such as nesting boxes and beehives;

c) a planting mix which encourages biodiversity;

d) planting which will be resilient to a range of climate conditions;

e) maintenance of habitats within Sites of Importance for Nature Conservation.

DM21.3 Residential environment

1. The amenity of existing residents within identified residential areas will be protected

by:

a) resisting other uses which would cause undue noise disturbance, fumes and smells

and vehicle or pedestrian movements likely to cause disturbance;

b) requiring new development near existing dwellings to demonstrate adequate

mitigation measures to address detrimental impact.

2. Noise-generating uses should be sited away from residential uses, where possible.

Where residential and other uses are located within the same development or area,

adequate noise mitigation measures must be provided and, where required, planning

conditions will be imposed to protect residential amenity.

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3. All development proposals should be designed to avoid overlooking and seek to

protect the privacy, day lighting and sun lighting levels to adjacent residential

accommodation.

4. All new residential development proposals must demonstrate how potential

adverse noise impacts on and between dwellings will be mitigated by housing layout,

design and materials.

5. The cumulative impact of individual developments on the amenity of existing

residents will be considered.

London Plan Policies

• Policy GG1: Building Strong and Inclusive Communities

• Policy GG2 :Making the Best Use of Land

• Policy GG3: Creating a Healthy City

• Policy GG5: Growing a Good Economy

• Policy GG6: Increasing Efficiency and Resilience

• Policy SD4: The Central Activities Zone (CAZ)

• Policy SD5: Offices, and Other Strategic Functions and Residential Development

in the CAZ

• Policy D1: London’s Form, Character and Capacity for Growth

• Policy D2: Infrastructure Requirements for Sustainable Densities

• Policy D3: Optimising Site Capacity through the Design-led approach

• Policy D4: Delivering Good Design

• Policy D5: Inclusive Design

• Policy D8: Public Realm

• Policy D10: Basement Development

• Policy D11: Safety, Security and Resilience to Emergency

• Policy D12: Fire Safety

• Policy D14: Noise

• Policy S6: Public Toilets

• Policy E1: Offices

• Policy E10: Visitor Infrastructure

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• Policy E11: Skills and Opportunities for All

• Policy HC1: Heritage Conservation and Growth

• Policy HC2: World Heritage Sites

• Policy HC3: Strategic and Local Views

• Policy HC4 London View Management Framework

• Policy HC5: Supporting London’s Culture and Creative Industries

• Policy G5: Urban Greening

• Policy G6: Biodiversity and Access to Nature

• Policy G7: Trees and Woodlands

• Policy SI1: Improving Air Quality

• Policy SI2: Minimising Greenhouse Gas Emissions

• Policy SI3: Energy Infrastructure

• Policy SI4: Managing Heat Risk

• Policy SI5: Water Infrastructure

• Policy SI7: Reducing Waste and Supporting the Circular Economy

• Policy SI8: Waste Capacity and Net Waste Self-sufficiency

• Policy SI13: Sustainable Drainage

• Policy T1: Strategic Approach to Transport

• Policy T2: Healthy Streets

• Policy T3: Transport Capacity, Connectivity and Safeguarding

• Policy T4: Assessing and Mitigating Transport Impacts

• Policy T5: Cycling

• Policy T6: Car Parking

• Policy T7: Deliveries, Servicing and Construction

• Policy T9: Funding Transport Infrastructure through Planning

Relevant GLA Supplementary Planning Guidance (SPG):

• Accessible London: Achieving an Inclusive Environment SPG (October 2014);

184

• Control of Dust and Emissions during Construction and Demolition SPG

(September 2014);

• Sustainable Design and Construction (September 2014);

• Social Infrastructure (May 2015);

• Culture and Night-Time Economy SPG (November 2017);

• London Environment Strategy (May 2018);

• Cultural Strategy (2018);

• Mayoral CIL 2 Charging Schedule (April 2019);

• Central Activities Zone (March 2016);

• Mayor’s Transport Strategy (2018) .

Relevant City Corporation Guidance and Supplementary Planning Documents

(SPDs)

• Air Quality SPD (July 2017);

• Archaeology and Development Guidance SPD (July 2017);

• City of London Lighting SPD (October 2023);

• City Transport Strategy (May 2019);

• City Waste Strategy 2013-2020 (January 2014);

• Protected Views SPD (January 2012);

• Preventing Suicides in High Rise Buildings and Structures Planning Advice

Note (April 2022)

• Planning Obligations SPD (July 2014);

• Open Space Strategy (2016);

• Office Use SPD (2015);

• City Public Realm (2016);

• Cultural Strategy 2018 – 2022 (2018);

• Chancery Lane Conservation Area, Character Summary & Management Strategy

SPD (February 2016);

• Fleet Street Area, Healthy Streets Plan (2023).

185

Relevant Draft City Plan 2040 Policies

• Strategic Policy S1: Healthy and Inclusive City

• Policy HL1: Inclusive Buildings and Spaces

• Policy HL2: Air Quality

• Policy HL3: Noise

• Policy HL4: Contaminated Land and Water Quality

• Policy HL6: Public toilets

• Policy HL9: Health Impact Assessments

• Strategic Policy S2: Safe and Secure City

• Policy SA1: Publicly Accessible Locations

• Policy SA2: Dispersal Routes

• Policy SA3: Designing in Security

• Strategic Policy S3: Housing

• Policy HS3: Residential Environment

• Strategic Policy S4: Offices

• Policy OF1: Office Development

• Policy OF2: Protection of Existing Office Floorspace

• Strategic Policy S5: Retail

• Policy RE2: Active frontages

• Strategic Policy S6: Culture and Visitors

• Policy CV2: Provision of Arts, Culture and Leisure Facilities

• Policy CV3: Provision of Visitor Facilities

• Policy CV5: Evening and Nigh-Time Economy

• Policy CV6: Public Art

• Strategic Policy S7: Infrastructure and Utilities

• Policy IN1: Infrastructure Provision and Connection

• Policy IN2: Infrastructure Capacity

• Policy IN3: Pipe Subways

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• Strategic Policy S8: Design

• Policy DE1: Sustainable Design

• Policy DE2: Design Quality

• Policy DE3: Public Realm

• Policy DE4: Terraces and viewing galleries

• Policy DE7: Daylight and Sunlight

• Policy DE8: Lighting

• Strategic Policy S9: Transport and Servicing

• Policy VT1: The Impacts of Development on Transport

• Policy VT2: Freight and Servicing

• Policy VT3: Vehicle Parking

• Strategic Policy S10: Active Travel and Healthy Streets

• Policy AT1: Pedestrian Movement, Permeability and Wayfinding

• Policy AT2: Active Travel Including Cycling

• Policy AT3: Cycle Parking

• Strategic Policy S11: Historic Environment

• Policy HE1: Managing Change to the Historic Environment

• Policy HE2: Ancient Monuments and Archaeology

• Strategic Policy S13: Protected Views

• Strategic Policy S14: Open spaces and Green Infrastructure

• Policy OS1: Protection and Provision of Open Spaces

• Policy OS2: Urban greening

• Policy OS3: Biodiversity

• Policy OS4: Biodiversity Net Gain

• Policy OS5: Trees

• Strategic Policy S15: Climate Resilience and Flood Risk

• Policy CR1: Overheating and Urban Heat Island Effect

• Policy CR2: Flood Risk

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• Policy CR3: Sustainable Drainage Systems (SuDS)

• Strategic Policy S16: Circular Economy and Waste

• Policy CE1: Sustainable Waste Facilities and Transport

• Strategic Policy S26: Planning Contributions

188

SCHEDULE

APPLICATION: 23/01322/FULMAJ

38-41 Furnival Street & 31-33 High Holborn

Change of use of existing deep level tunnels (Sui Generis) to visitor and cultural

attraction (Use Class F1(b)(c)), including bar (Sui Generis); demolition and

reconstruction of existing building at 38-39 Furnival Street; redevelopment of

40-41 Furnival Street, for the principal visitor attraction pedestrian entrance at

ground floor, with ancillary retail at first and second floor levels and ancillary

offices at third and fourth levels, excavation of additional basement levels at 40-

41 Furnival Street and 38-39 Furnival Street, and widening of lift shaft at 38-39

Furnival Street; creation of new, pedestrian entrance at 31-33 High Holborn, to

provide secondary visitor attraction entrance (including principal bar entrance),

deepening of lift shaft at 31-33 High Holborn; provision of ancillary cycle

parking, substation, servicing and plant, and other associated works (Duplicate

application submitted to the London Borough of Camden as the site area

extends across the borough boundary). Re-consultation: Due to amended

details.

CONDITIONS

1. The development hereby permitted shall be begun before the expiration of three

years from the date of this permission.

REASON: To ensure compliance with the terms of Section 91 of the Town and

Country Planning Act 1990.

Use Class

2. The entirety of the site, save for the bar, herby approved shall be used for Visitor

and Cultural Attraction (Use Class F1 (b)(c)), including any ancillary spaces,

and for no other purpose (including any other purpose within Class F of the

Schedule to the Town and Country Planning (Use Classes) Order 1987 (as

amended by the Town and Country Planning (Use

Classes)(Amendment)(England) Regulations 2020) or in any provision

equivalent to that Class in any statutory instrument revoking and re-enacting

that Order with or without modification.

REASON: To ensure City of London's contribution to London's world-class

cultural offer in accordance with the following policy of the draft City Plan 2040:

S6.

Floor Areas

3. The development shall provide (all figures GIA and excluding plant):

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- 10,341sq.m Visitor and Cultural Attraction (Class F1(b)(c));

- 284 sq.m Bar Use (Sui Generis);

REASON: To ensure the development is carried out in accordance with the

approved plans.

Operation hours

4. The permanent Visitor and Cultural Attraction (Use Class F1(b)(c)) hereby

permitted shall not be open to customers between the hours of 8pm on one day

and 10am on the following day.

REASON: To safeguard the amenity of the adjoining premises and the area

generally in accordance with the following policies of the Local Plan: DM15.7,

DM21.3.

Design and Heritage

5. Before any works thereby affected are begun the following details shall be

submitted to and approved in writing by the Local Planning Authority and all

development pursuant to this permission shall be carried out in accordance with

the approved details:

a) particulars and samples of the materials to be used on all external

faces of the building including details of compliance with the approved

Circular Economy Strategy;

b) construction of 1:1 sample material and facade panels of agreed

sections of the facades;

c) detailed drawings of a scale no less than 1:20, in plan, section and

elevation, of agreed typical bays;

d) details of all new ground floor elevations including all entrances, service

doors, crane, soffits, and information boards;

e) Details of new entrance;

f) details of all new flanking elevations;

g) irrespective of approved drawings, details of plant screening including

the 5

elevation;

h) details of terrace including all elevations, hard and soft landscaping,

entrances, fenestration, planters, seating, lighting, soffit, drainage, irrigation

and any infrastructure required

i) details of railings, balustrades, ramps, screens, handrails etc, bounding

or within the site;

j) details of the integration of window cleaning equipment and the

garaging thereof, plant, flues, and other excrescences at roof level including

within the plant room;

k) details of the integration of M&E and building services into the external

envelope;

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l) details of external ducts, vents, louvres and extracts;

m) details of signage for all aspects of the building;

n) Details of access to the roof for cleaning and maintenance, including

details of mansafe equipment.

REASON: To ensure that the Local Planning Authority may be satisfied with

the detail of the proposed development and to ensure a satisfactory external

appearance in accordance with the following policies of the Local Plan:

DM3.2, DM10.1, DM10.5, DM12.2 and emerging policies SE1, DE2, DE6 and

HE1 of the Draft City Plan 2036.

6. Prior to the commencement of relevant works, a method statement shall be

submitted to and approved by the local planning authority setting out the

methodology for the dismantlement, storing and reconstructing the brick façade

of No.38-39 Furnival Street including the concrete grill. The development shall

be carried out in accordance with the approved details.

REASON: To ensure that the Local Planning Authority may be satisfied with the

detail of the proposed development and to ensure a satisfactory external

appearance in accordance with the following policies of the Local Plan: DM10.1,

DM12.2, DM12.3.

Archaeology

7. No demolition or development shall take place until a stage 1 written scheme

of investigation (WSI) has been submitted to and approved by the local planning

authority in writing. For land that is included within the WSI, no demolition or

development shall take place other than in accordance with the agreed WSI,

and the programme and methodology of site evaluation and the nomination of

a competent person(s) or organisation to undertake they're great works.

If heritage assets of archaeological interest are identified by stage 1 then for

those parts of the site would have archaeological interest a state 2 WSI shall

be submitted to and approved by the local planning authority in writing. For land

that is included within the stage 2 WSI, no demolition/development shall take

place other than in accordance with the agreed stage 2 WSI with cell include:

A. the statement off significance and the research objectives, the

programme and methodology of site investigation and recording and the

nomination of a competent person(s) or organisation to undertake the agreed

works

B. where appropriate, details of a programme for delivering related positive

public benefits

C. the programme for post investigation assessment and subsequent

analysis, publication & dissemination and deposition of resulting material. This

part of the condition shall not be discharged until these elements have been

fulfilled in accordance with the programme set out in the stage 2 WSI.

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No demolition shall take place until a written scheme of historic building

investigation (WSI) has been submitted to and approved by the local planning

authority in writing. For buildings that are included within the WSI, no

demolition or development shall take place other than in accordance with the

agreed WSI, which shall include this statement of significance and research

objectives, and

a. the programme and methodology of historic building investigation and

recording and the nomination of a competent person(s) or organisation to

undertake the agreed works

b. the programme for post-investigation assessment and subsequent

analysis, publication & dissemination and deposition of resulting material. This

part of the conditions shall not be discharged until these elements have been

fulfilled in accordance with the programme set out in the WSI.

REASON: To safeguard the archaeological interest on this site and the

preservation of archaeological remains following archaeological investigation

in accordance with the following policy of the Local Plan: DM12.4.

Public Access and Inclusivity

8. Before any construction work hereby permitted are begun, details of the

proposed lifts shall be submitted to and approved in writing by the local planning

authority. The development shall then be implemented in accordance with the

approved details and be retained as such in perpetuity.

REASON: To ensure that the development will be accessible for people with

disabilities in accordance with the following policy of the Local Plan: DM10.8.

These details are required prior to construction work commencing in order that

any changes to satisfy this condition are incorporated into the development

before the design is too advanced to make changes.

9. Prior to the commencement of works including demolition, a site condition

survey of the adjacent highways and other land at the perimeter of the site shall

be carried out and details must be submitted to and approved in writing by the

local planning authority. Proposed finished floor levels at basement and

threshold ground floor (threshold review) levels in relation to the existing

Ordnance Datum levels of the adjoining streets and open spaces, must be

submitted and agreed with the Highways Authority. The development shall be

carried out in accordance with the approved levels unless otherwise agreed in

writing by the local planning authority.

REASON: To ensure continuity between the level of existing streets and the

finished floor levels in the proposed building and to ensure a satisfactory

treatment at ground level in accordance with the following policies of the Local

Plan: DM10.8, DM16.2. These details are required prior to commencement in

order that a record is made of the conditions prior to changes caused by the

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development and that any changes to satisfy this condition are incorporated

into the development before the design is too advanced to make changes.

10. Before any construction work hereby permitted are begun, a scheme indicating

the provision to be made for disabled people to gain access to all areas shall

be submitted to and approved in writing by the Local Planning Authority. The

agreed scheme shall be implemented in accordance with the approved details

before the development hereby permitted is brought into use.

REASON: To ensure that the development will be accessible for people with

disabilities in accordance with the following policy of the Local Plan: DM10.8.

These details are required prior to construction work commencing in order that

any changes to satisfy this condition are incorporated into the development

before the design is too advanced to make changes.

11. The threshold of the private public realm and public route entrances shall be at

the same level as the rear of the adjoining footway.

REASON: To maintain a level passage for pedestrians in accordance with the

following policies of the Local Plan: DM10.8, DM16.2.

12. Prior to the occupation of the building, the applicant is required to submit to the

Local Planning Authority for approval of a wayfinding strategy. The developer

is to consider the implementation or removal of legible London signage within

the site and surrounding locations including transport nodes and tube stations.

The applicant shall have agreed terms and extent of the works with TfL, prior

to submission.

REASON: In the interests of visual amenity and satisfactory pedestrian

circulation of the site, in accordance with the following policies of the Local Plan:

DM10.1, DM19.2.

13. Prior to the occupation of the building, a Signage and Wayfinding Strategy,

highlighting and signposting destinations, accessible routes and facilities, cycle

parking, cultural exhibition areas and any other relevant facilities shall be

submitted to and approved in writing by the Local Planning Authority. The

strategy should include details of navigation on the site and should be designed

with reference to guidance in PAS 6463: Design for the Mind and following the

principle of ‘two senses’.

REASON: To support inclusion, public access, legibility and wayfinding in

accordance with the following policies of the Local Plan: CS10, DM10.1,

DM10.4, DM10.8, CS11, DM16.2 and DM16.4.

Construction

14. Demolition works shall not begin until a Deconstruction Logistics Plan to

manage all freight vehicle movements to and from the site during

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deconstruction of the existing building(s) has been submitted to and approved

in writing by the Local Planning Authority. The Deconstruction Logistics Plan

shall be completed in accordance with the Mayor of London's Construction

Logistics Plan Guidance dated July 2017, and shall specifically address the

safety of vulnerable road users through compliance with the Construction

Logistics and Community Safety (CLOCS) Standard. The Plan must

demonstrate how Work Related Road Risk is to be managed. The demolition

shall not be carried out otherwise than in accordance with the approved

Deconstruction Logistics Plan or any approved amendments thereto as may be

agreed in writing by the Local Planning Authority.

REASON: To ensure that demolition works do not have an adverse impact on

public safety and the transport network in accordance with London Plan Policy

6.14 and the following policies of the Local Plan: DM15.6, DM16.1. These

details are required prior to demolition work commencing in order that the

impact on the transport network is minimised from the time that demolition

starts.

15. Construction works shall not begin until a Construction Logistics Plan (CLP)

has been submitted to and approved in writing by the Local Planning Authority,

and in consultation with TfL. The CLP aims to manage all freight vehicle

movements to and from the site during construction of the development. The

plan must be in line with TfL’s Construction Logistic Guidance, and shall

specifically address the safety of vulnerable road users through compliance

with the Construction Logistics and Community Safety (CLOCS) Standard. The

development shall not be carried out otherwise than in accordance with the

approved CLP. Any amendments thereto must be agreed in writing by the

Local Planning Authority.

REASON: To ensure that construction works do not have an adverse impact

on public safety and the transport network in accordance with London Plan

Policy 6.14 and the following policies of the Local Plan: DM15.6, DM16.1.

These details are required prior to construction work commencing in order that

the impact on the transport network is minimised from the time that construction

starts.

Cycle Parking

16. Details of the all long stay cycle parking and facilities linked to the cycle stores

shall be submitted to and approved in writing by the Local Planning Authority,

prior to the occupation of the building hereby permitted. Details shall include

permanently installed pedal cycle racks sufficient to accommodate a minimum

of 14 spaces including adaptable spaces with a range of cycle space types split

across the two bike stores. The cycle parking spaces shall be designed in line

with London Cycle Design Standards and shall be implemented prior to

occupation of the building. All doors on the access to the parking area shall be

194

automated, push button or pressure pad operated. The cycle parking spaces

and facilities shall be thereafter operated in accordance with the approved

details for the life of the building.

REASON: To ensure provision is made for cycle parking and that the Local

Planning Authority may be satisfied that the scheme provides a sustainable

transport strategy and does not have an adverse impact on the transport

network in accordance with the following policies of the Local Plan: DM16.1,

DM 16.3, and emerging policy AT3 of the Draft City Plan 2040.

17. A minimum of 5% of the long stay cycle spaces shall be accessible for larger

cycles, including adapted cycles for disabled people.

REASON: To ensure that satisfactory provision is made for people with

disabilities in accordance with Local Plan policy DMI0.8, London Plan policy TS

cycling, emerging policy AT3 of the Draft City Plan 2040.

18. Details of mobility scooter storage within the ground floor bike store, to include

fire-guarding as required, and accessible charging points at a minimum height

of 400mm above floor level.

REASON: To ensure that the development will be accessible for people with

disabilities in accordance with the following policy of the Local Plan: DM10.8.

Section 153

19. No doors, gates or windows at ground floor level shall open over the public

highway.

REASON: In the interests of public safety and to comply with section 153 of the

Highways Act 1980.

Refuse/ Recycling

20. The refuse/ recycling collection and storage facilities shown on the drawings

hereby approved shall be provided and maintained throughout the life of the

building for the use of all the occupiers.

REASON: To ensure the satisfactory servicing of the building in accordance

with the following policy of the Local Plan: DM17.1.

21. On a daily basis, and outside of the opening hours for the exhibition spaces and

ancillary areas hereby approved, the on-site FM team will transfer the bins from

the main waste storage areas to a waste presentation area on Furnival Street.

The waste management contractor appointed by the on-site FM team will

collect the bins from the waste presentation area.

REASON: To ensure the satisfactory servicing of the building in accordance

with the following policy of the Local Plan: DM17.1.

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TfL (Infrastructure Protection)

22. The development hereby permitted shall not commence until the following

documents, in consultation with TfL Infrastructure Protection, have been

submitted to and approved in writing by the local planning authority, which:

a) provide details on the use of scaffold/tall plant i.e cranes and lifting

equipment;

b) accommodate ground movement impact on all identified LU assets

arising from the development construction. A Ground Movement

Assessment (GMA) should be submitted to TfL IP for approval;

c) mitigate the effects of noise and vibration arising from the adjoining

operations within the railway structures and tunnels;

d) no works to commence near or on the boundary with London Underground

assets until any party wall agreements required with TfL Engineering, TfL

Property or TfL Legal have been agreed and signed by all parties. As shown on

Title No. LN170205, London Underground own the Fulwood Place Vent Shaft

and other assets located at 31-33 High Holborn;

e) demonstrate that the Fulwood Place Vent Shaft and its ancillary

equipment/facilities will not be impacted by the development.

f) demonstrate that no ventilation or exhaust gases are discharged into TfL /

LUL assets or airspace.

g) demonstrate that TfL access to the vent shaft from Fulwood Place is not

impeded or altered.

REASON: To ensure that the development does not impact on existing London

Underground transport infrastructure, in accordance with London Plan 2021,

draft London Plan policy T3 and ‘Land for Industry and Transport’

Supplementary Planning Guidance 2012.

Air Quality

23. Prior to the installation of any generator. A report shall be submitted to show

what alternatives have been considered including a secondary electrical power

supply, battery backup or alternatively fuelled generators such as gas fired or

hydrogen. The details of the proposed generator shall be submitted for

approval. Where it is not possible to deploy alternatives, any diesel generators

must be the latest Euro standard available. The generator shall be used solely

on brief intermittent and exceptional occasions when required in response to a

life-threatening emergency and for the testing necessary to meet that purpose

and shall not be used at any other time.

REASON: In accordance with the following policy of the Local Plan: DM15.6

and to maintain local air quality and ensure that exhaust does not contribute to

local air pollution, particularly nitrogen dioxide and particulates PM10, in

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accordance with the City of London Air Quality Strategy 2019 and the London

Plan Policies SI1 and SD4 D.

24. Unless otherwise agreed in writing by the local planning authority all

combustion flues must terminate at least 1m above the highest roof in the

development in order to ensure maximum dispersion of pollutants, and must be

located away from ventilation intakes and accessible roof gardens and terraces.

REASON: In order to ensure that the proposed development does not have a

detrimental impact on occupiers of residential premises in the area and to

maintain local air quality and ensure that exhaust does not contribute to local

air pollution, particularly nitrogen dioxide and particulates PM10 and 2.5, in

accordance with the City of London Air Quality Strategy 2019, Local Plan Policy

DM15.6 and London Plan policy SI1.

25. Prior to the commencement of the development, the developer/ construction

contractor shall sign up to the Non-Road Mobile Machinery Register. The

development shall be carried out in accordance with the Mayor of London

Control of Dust and Emissions during Construction and Demolition SPG July

2014 (Or any subsequent iterations) to ensure appropriate plant is used and

that the emissions standards detailed in the SPG are met. An inventory of all

NRMM used on site shall be maintained and provided to the Local Planning

Authority upon request to demonstrate compliance with the regulations.

REASON: To reduce the emissions of construction and demolition in

accordance with the Mayor of London Control of Dust and Emissions during

Construction and Demolition SPG July 2014 (or any updates thereof), Local

Plan Policy DM15.6 and London Plan Policy SI1D. Compliance is required to

be prior to commencement due to the potential impact at the beginning of the

construction.

26. An Indoor Air Quality report should be submitted and approved in writing by the

Local Planning Authority. The report should detail the air pollution environment

within the deep level tunnels, and the requirement(s) to ensure suitable air

quality is maintained for the proposed usage.

REASON: In order to ensure the proposed development reduces exposure to

poor air quality in accordance with the following policies: Local Plan policy

DM15.6, London Plan policy SI1.

Environmental Health

27. Before the development hereby permitted shall commence, unless otherwise

agreed with the Local Planning Authority, the following works shall be

undertaken in accordance with the requirements of DEFRA and the

Environment Agency’s Land Contamination Risk Management (LCRM)

guidance and be submitted to City of London for approval with due

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consideration given to impact of development works (including remediation) on

off-site receptors, sustainable development, and future foreseeable events

within the development lifespan (e.g., climate change and extreme weather

events):

a) a preliminary risk assessment (PRA) shall be completed to identify the

potential for contamination at the site, define the conceptual site model (CSM),

and to identify and assess potential contaminant linkages associated with the

proposed development.

b) an intrusive site investigation shall be carried out followed by an

appropriate level of risk assessment to establish if the site is affected by

contamination and to determine the potential for harm to human health and non-

human receptors and pollution of controlled waters and the wider environment

(e.g., groundwater dependent terrestrial ecosystems and statutory ecological

receptors) associated with the development. The method and extent of this site

investigation shall be based on the findings of the preliminary risk assessment

(PRA), formulated in accordance with relevant British Standards, and be agreed

in writing with the Local Planning Authority prior to commencement of the work.

c) A remediation strategy to include details of measures to prevent

identified unacceptable risk to receptors from gross contamination (e.g. non

aqueous phase liquid, asbestos containing material), soil contamination,

pollution of controlled waters, and to bring the site to a condition suitable for the

intended use including provisions for long term monitoring where required, shall

then be submitted to and approved in writing by the Local Planning Authority

before the development commences . The remediation scheme must ensure

that the site will not qualify as contaminated land under Part 2A of the

Environmental Protection Act 1990 in relation to the intended use of the land

after remediation and that the site is suitable for its intended use. The

development shall proceed in strict accordance with the measures approved.

REASON: To ensure that risks from land contamination to the future users of

the land and neighbouring land are minimised, together with those to controlled

waters, to prevent pollution of the water environment, property and ecological

systems, and to ensure that the development can be carried out safely without

unacceptable risks to workers, neighbours and other offsite receptors in

accordance with the Local Plan DM15.8. These details are required prior to

commencement in order that any changes to satisfy this condition are

incorporated into the development before the design is too advanced to make

changes.

28. Prior to occupation and unless otherwise agreed with the Local Planning

Authority, a verification report produced in accordance with LCRM and other

associated guidance detailing the remediation measures completed and final

condition of the site must be submitted to and approved in writing by the Local

Planning Authority. The developer must include a statement to confirm that the

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site development is safe, suitable for its intended use, and would not be

considered under Part 2A of the Environmental Protection Act 1990.

REASON: To ensure that the development is safe and suitable for its intended

use for the future users of the land, neighbouring land, and that risks to

controlled waters, property and ecological systems are minimised, in

accordance with the Local Plan DM15.8. These details are required prior to

occupation in order that appropriate evidence of the remedial works is agreed

and accepted by the Local Planning Authority prior to any potential exposure of

occupiers or harm to the environment from land contamination.

29. Should unexpected contamination be identified during development hereby

approved, the Local Planning Authority must be notified in writing within five

working days. An investigation and risk assessment must be undertaken in

accordance with the requirements of DEFRA and the Environment Agency’s

Land Contamination Risk Management.

Where remediation is necessary a detailed remediation scheme to bring the

site to a condition suitable for the intended use must be submitted to and

approved in writing by the Local Planning Authority. Unless otherwise agreed

in writing by the Local Planning Authority the remediation scheme must ensure

that the site will not qualify as contaminated land under Part 2A of the

Environmental Protection Act 1990 in relation to the intended use of the land

after remediation.

Following completion of measures identified in the approved remediation

scheme a verification report must be submitted to and approved in writing of

the Local Planning Authority.

REASON: To ensure that risks from land contamination to the future users of

the land and neighbouring land are minimised, together with those to controlled

waters, property and ecological systems, and to ensure that the development

can be carried out safely without unacceptable risks to workers, neighbours and

other offsite receptors in accordance with the Local Plan DM15.8. These details

are required prior to commencement in order that any changes to satisfy this

condition are incorporated into the development before the design is too

advanced to make changes.

30. No part of the roof areas except those shown as roof terraces on the drawings

hereby approved shall be used or accessed by occupiers of the building, other

than in the case of emergency or for maintenance purposes.

REASON: To safeguard the amenity of the adjoining premises and the area

generally in accordance with the following policies of the Local Plan: DM15.7,

DM21.3.

31. No live or recorded music that can be heard outside the premises shall be

played.

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REASON: To safeguard the amenity of the adjoining premises and the area

generally in accordance with the following policies of the Local Plan: DM15.7,

DM21.3.

32. No servicing of the premises shall be carried out between the hours of 23:00

on one day and 07:00 on the following day from Monday to Saturday and

between 23:00 on Saturday and 07:00 on the following Monday and on Bank

Holidays. Servicing includes the loading and unloading of goods from vehicles

and putting rubbish outside the building.

REASON: To avoid obstruction of the surrounding streets and to safeguard the

amenity of the occupiers of adjacent premises, in accordance with the following

policies of the Local Plan: DM15.7, DM16.2, DM21.3.

33. The roof terrace on level 4 hereby permitted shall not be used or accessed

between the hours of 20:00 on one day and 08:00 on the following day and not

at any time on Sundays or Bank Holidays, other than in the case of emergency.

REASON: To safeguard the amenity of the adjoining premises and the area

generally in accordance with the following policies of the Local Plan: DM15.7,

DM21.3.

34. No amplified or other music shall be played on the roof terraces.

REASON: To safeguard the amenity of the adjoining premises and the area

generally in accordance with the following policies of the Local Plan: DM15.7,

DM21.3.

35. There shall be no promoted events on the premises. A promoted event for this

purpose, is an event involving music and dancing where the musical

entertainment is provided at any time by a disc jockey or disc jockeys one or

some of whom are not employees of the premises licence holder and the event

is promoted to the general public.

REASON: To safeguard the amenity of the adjoining premises and the area

generally in accordance with the following policies of the Local Plan: DM15.7,

DM21.3.

36. (a) The level of noise emitted from any new plant shall be lower than the existing

background level by at least 10 dBA. Noise levels shall be determined at one

metre from the window of the nearest noise sensitive premises. The

background noise level shall be expressed as the lowest LA90 (10 minutes)

during which plant is or may be in operation.

(b) Following installation but before the new plant comes into operation

measurements of noise from the new plant must be taken and a report

demonstrating that the plant as installed meets the design requirements shall

be submitted to and approved in writing by the Local Planning Authority.

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whole or in part as often is required to ensure compliance with the noise levels

approved by the Local Planning Authority.

REASON: To protect the amenities of neighbouring residential/commercial

occupiers in accordance with the following policies of the Local Plan: DM15.7,

DM21.3.

37. There shall be no demolition on the site until a scheme for protecting nearby

residents and commercial occupiers from noise, dust and other environmental

effects has been submitted to and approved in writing by the Local Planning

Authority. The scheme shall be based on the Department of Markets and

Consumer Protection's Code of Practice for Deconstruction and Construction

Sites and arrangements for liaison and monitoring (including any agreed

monitoring contribution) set out therein. A staged scheme of protective works

may be submitted in respect of individual stages of the demolition process but

no works in any individual stage shall be commenced until the related scheme

of protective works has been submitted to and approved in writing by the Local

Planning Authority. The demolition shall not be carried out other than in

accordance with the approved scheme (including payment of any agreed

monitoring contribution).

REASON: In the interests of public safety and to ensure a minimal effect on the

amenities of neighbouring premises and the transport network in accordance

with the following policies of the Local Plan: DM15.6, DM15.7, DM21.3. These

details are required prior to demolition in order that the impact on amenities is

minimised from the time that development starts.

38. There shall be no construction on the site until a scheme for protecting nearby

residents and commercial occupiers from noise, dust and other environmental

effects during construction has been submitted to and approved in writing by

the Local Planning Authority. The scheme shall be based on the Department of

Markets and Consumer Protection's Code of Practice for Deconstruction and

Construction Sites and arrangements for liaison and monitoring (including any

agreed monitoring contribution) set out therein. A staged scheme of protective

works may be submitted in respect of individual stages of the construction

process but no works in any individual stage shall be commenced until the

related scheme of protective works has been submitted to and approved in

writing by the Local Planning Authority. The development shall not be carried

out other than in accordance with the approved scheme (including payment of

any agreed monitoring contribution).

REASON: In the interests of public safety and to ensure a minimal effect on the

amenities of neighbouring premises and the transport network in accordance

with the following policies of the Local Plan: DM15.6, DM15.7, DM21.3. These

details are required prior to demolition in order that the impact on amenities is

minimised from the time that the construction starts.

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39. Before any mechanical plant is used on the premises it shall be mounted in a

way which will minimise transmission of structure borne sound or vibration to

any other part of the building in accordance with a scheme to be submitted to

and approved in writing by the Local Planning Authority.

REASON: In order to protect the amenities of commercial occupiers in the

building in accordance following policy of the Local Plan: DM15.7.

40. Before any piling or construction of basements is commenced a scheme for the

provision of sewer vents within the building shall be submitted to and approved

in writing by the local planning authority. Unless otherwise agreed in writing by

the local planning authority the agreed scheme for the provision of sewer vents

shall be implemented and brought into operation before the development is

occupied and shall be so maintained for the life of the building.

REASON: To vent sewerage odour from (or substantially from) the

development hereby permitted and mitigate any adverse air pollution or

environmental conditions in order to protect the amenity of the area in

accordance with the following policy of the Local Plan: DM10.1. These details

are required prior to piling or construction work commencing in order that any

changes to satisfy this condition are incorporated into the development before

the design is too advanced to make changes.

41. Prior to the commencement of development the developer/construction

contractor shall sign up to the Non-Road Mobile Machinery Register. The

development shall be carried out in accordance with the NRMM Regulations

and the inventory of all NRMM used on site shall be maintained and provided

to the Local Planning Authority upon request to demonstrate compliance with

the regulations.

REASON: To reduce the emissions of construction and demolition in

accordance with the Mayor of London Control of Dust and Emissions during

Construction and Demolition SPG July 2014. Compliance is required to be prior

to commencement due to the potential impact at the beginning of the

construction.

42. All parts of the ventilation and extraction equipment including the odour control

systems installed shall be cleaned, serviced and maintained in accordance with

Section 5 of ‘Control of Odour & Noise from Commercial Kitchen Extract

Systems’ dated September 2018 by EMAQ+ (or any subsequent updated

version). A record of all such cleaning, servicing and maintenance shall be

maintained and kept on site and upon request provided to the Local Planning

Authority to demonstrate compliance.

REASON: To protect the occupiers of existing and adjoining premises and

public amenity in accordance with Policies DM 10.1, DM 15.7 and DM 21.3.

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Lighting Strategy

43. Prior to the commencement of the relevant works, a full Lighting Strategy and

a Technical Lighting Design shall be submitted to and approved in writing by

the Local Planning Authority, which should include full details of:

a. all luminaires both decorative, functional or ambient (including

associated infrastructure);

b. lighting layouts;

c. a lighting control methodology;

d. proposed operational timings and associated design and management

measures to reduce the impact on the local environment and residential

amenity including light pollution, light spill, and potential harm to local ecologies;

e. all external, semi-external and public-facing parts of the building and of

any internal lighting in relation spaces and terraces so far that it creates visual

or actual physical impact on the lit context to show how the facade and/or the

lighting has been designed to help reduce glare, excessive visual brightness,

and light trespass;

f. the impact on the public realm, including typical illuminance levels,

uniformity, colour appearance and colour rendering.

All works and management measures pursuant to this consent shall be carried

out and maintained in accordance with the approved details and Lighting

Strategy.

REASON: To ensure that the Local Planning Authority may be satisfied with the

detail of the proposed development and to ensure a satisfactory external

appearance in accordance with the following policies of the Local Plan: DM10.1,

15.7 and emerging policy DE8 of the Draft City Plan 2040.

Thames Water

44. No piling shall take place until a PILING METHOD STATEMENT (detailing the

depth and type of piling to be undertaken and the methodology by which such

piling will be carried out, including measures to prevent and minimise the

potential for damage to subsurface sewerage infrastructure, and the

programme for the works) has been submitted to and approved in writing by the

local planning authority in consultation with Thames Water. Any piling must be

undertaken in accordance with the terms of the approved piling method

statement.

REASON: The proposed works will be in close proximity to underground

sewerage utility infrastructure. Piling has the potential to significantly impact /

cause failure of local underground sewerage utility infrastructure. Please read

our guide ‘working near our assets’ to ensure your workings will be in line with

the necessary processes you need to follow if you’re considering working above

or near our pipes or other structures.

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45. No construction shall take place within 5m of the water main. Information

detailing how the developer intends to divert the asset / align the development,

so as to prevent the potential for damage to subsurface potable water

infrastructure, must be submitted to and approved in writing by the local

planning authority in consultation with Thames Water. Any construction must

be undertaken in accordance with the terms of the approved information.

Unrestricted access must be available at all times for the maintenance and

repair of the asset during and after the construction works.

REASON: The proposed works will be in close proximity to underground

strategic water main, utility infrastructure. The works has the potential to impact

on local underground water utility infrastructure.

46. No piling shall take place until a piling method statement (detailing the depth

and type of piling to be undertaken and the methodology by which such piling

will be carried out, including measures to prevent and minimise the potential for

damage to subsurface water infrastructure, and the programme for the works)

has been submitted to and approved in writing by the local planning authority

in consultation with Thames Water. Any piling must be undertaken in

accordance with the terms of the approved piling method statement.

REASON: The proposed works will be in close proximity to underground water

utility infrastructure. Piling has the potential to impact on local underground

water utility infrastructure.

Carbon and Energy

47. Prior to the commencement of the development, (excluding demolition), an

update to the approved detailed Whole Life-Cycle Carbon assessment shall be

submitted to and approved in writing by the Local Planning Authority. The

assessment must be based on a highest use scenario, full fit-out, (including

fixtures and equipment, specifically audio-visual equipment) and “best guess”

frequency of operation (special exhibitions and events). The assessment

should include details of measures to reduce carbon emissions throughout the

whole life-cycle of the development and provide calculations in line with the

Mayor of London's guidance on Whole Life-Cycle Carbon Assessments, and

the development shall be carried out in accordance with the approved details

and operated and managed in accordance with the approved assessment for

the life-cycle of the development.

REASON: To ensure that the Local Planning Authority may be satisfied with the

detail of the proposed development so that it maximises the reduction of carbon

emissions of the development throughout the whole life cycle of the

development in accordance with the following policies in the Development Plan

and draft Development Plans: London Plan: D3, SI 2, SI 7 - Local Plan: CS 17,

DM 15.2, DM 17.2 - Draft City Plan 2036: CE 1. These details are required prior

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to demolition (as specified above) and construction work commencing in order

to be able to account for embodied carbon emissions resulting from the

demolition and construction phase (including recycling and reuse of materials)

of the development.

48. Once the as-built design has been completed (upon commencement of RIBA

Stage 6) and prior to the development being occupied (or if earlier, prior to the

development being handed over to a new owner or proposed occupier,) the

post-construction Whole Life-Cycle Carbon (WLC) Assessment (to be

completed in accordance with and in line with the criteria set out in in the GLA's

WLC Assessment Guidance) shall be submitted to the Local Planning Authority

. The post-construction assessment should provide an update of the information

submitted at planning submission stage (RIBA Stage 2/3), including the WLC

carbon emission figures for all life-cycle modules based on the actual materials,

products and systems used. The assessment should be submitted along with

any supporting evidence as per the guidance and should be received three

months post as-built design completion, unless otherwise agreed.

REASON: To ensure whole life-cycle carbon emissions are calculated and

reduced and to demonstrate compliance with Policy SI 2 of the London Plan.

49. The development shall be designed to allow for connection into a district

heating network if this becomes available during the lifetime of the

development. This is to include a strategy with relevant plan drawings for:

equipment, allocation of plant space and a protected route for connection in

and out of the site. This is in addition to the requirement to find a beneficial use

for the waste heat produced through the development’s operations.

REASON: To minimise carbon emissions by enabling the building to be

connected to a district heating and cooling network if one becomes available

during the life of the building in accordance with the following policies of the

Local Plan: DM15.1, DM15.2, DM15.3, DM15.3, DM15.4.

50. Prior to the commencement of development, excluding demolition, an updated

Energy Assessment confirming the detailed design stage highest use scenario

full fit-out, (including fixtures and equipment, specifically audio-visual

equipment) and “best guess” frequency of operation (special exhibitions and

events) is to be submitted to and approved in writing by the Local Planning

Authority. The development shall be carried out in accordance with the

approved Energy Assessment and the carbon reduction measures contained

with the approved Energy Assessment shall remain in place for the lifetime of

the development.

REASON: To demonstrate that carbon emissions have been minimised and

that the development is sustainable in accordance with the following policy of

the Local Plan: CS15, DM15.1, DM15.2. These details are required prior to

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demolition and construction work commencing in order to be able to account

for the carbon emissions associated with the proposed fit-out.

Circular Economy

51. (a) Prior to demolition of the development an updated pre-demolition audit in

accordance with section 4.6 of the GLA’s adopted Circular Economy Statement

guidance shall be submitted to and approved in writing by the Local Planning

Authority, that demonstrates that the development is designed to meet the

relevant targets set out in the GLA Circular Economy Statement Guidance. The

development shall be carried out in accordance with the approved details and

operated & managed in accordance with the approved details throughout the

lifecycle of the development.

b) Prior to the commencement of the development (excluding demolition), after

RIBA Stage 4, an update to the approved detailed Circular Economy Statement

to reaffirm the proposed strategy, to include a site waste management plan and

details of the proposed demountable partition design, shall be submitted to and

approved in writing the Local Planning Authority, that demonstrates that the

Statement has been prepared in accordance with the GLA Circular Economy

Guidance and that the development is designed to meet the relevant targets

set out in the GLA Circular Economy Guidance. The end-of-life strategy of the

statement should include the approach to storing detailed building information

relating to the structure and materials of the new building elements and of the

interventions in order to distinguish the historic from the new fabric. The

development shall be carried out in accordance with the approved details and

operated & managed in accordance with the approved details throughout the

lifecycle of the development.

REASON : To ensure that the Local Planning Authority may be satisfied with

the detail of the proposed development so that it reduces the demand for

redevelopment, encourages re-use and reduces waste in accordance with the

following policies in the Development Plans and draft Development Plans:

London Plan; D3, SI 7, SI 8 - Local Plan; CS 17, DM 17.2 - Draft City Plan 2036;

S16, CEW 1. These details are required prior to construction work commencing

in order to establish the extent of recycling and minimised waste from the time

that construction start.

52. No later than 3 months after completion of the building, a post-construction

Circular Economy Statement shall be submitted to and approved in writing by

the local planning authority to demonstrate that the targets and actual outcomes

achieved are in compliance with or exceed the proposed targets stated in the

approved Circular Economy Statement for the development.

REASON: To ensure that circular economy principles have been applied and

Circular Economy targets and commitments have been achieved to

demonstrate compliance with Policy SI 7 of the London Plan.

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Greening and Biodiversity

53. Within 6 months of completion of the development, details of the final

landscaping design and an Ecological Management Plan, to include plant and

habitat species (with information on coverage and biodiversity improvement),

scaled drawings identifying measures and maintenance strategies, shall be

submitted to the Local Planning Authority. Landscaping and biodiversity

measures shall be maintained in accordance with the submission documents

to ensure the approved standard is preserved for the lifetime of the

development.

REASON: To support the environmental sustainability of the development and

provide a habitat that will encourage biodiversity in accordance with the

following policies of the Local Plan: DM18.2, DM19.2, and Draft City Plan: S14,

OS2 whilst ensuring these benefits are maintained in the long term.

Water Management

54. Before any construction works hereby permitted are begun the following details

shall be submitted to and approved in writing by the Local Planning Authority in

conjunction with the Lead Local Flood Authority and all development pursuant

to this permission shall be carried out in accordance with the approved details:

(a) Fully detailed design and layout drawings for the proposed SuDS

components including but not limited to: attenuation systems, blue roofs,

rainwater pipework, flow control devices, design for system exceedance,

design for ongoing maintenance; surface water flow rates shall be restricted to

no greater than 1.5 l/s from each outfall and from no more than one distinct

outfall, provision should be made for an attenuation volume capacity capable

of achieving this, which should be no less than 25m3;

(b) Full details of measures to be taken to prevent flooding (of the site or caused

by the site)during the course of the construction works.

Before the shell and core is complete the following details shall be submitted to

and approved in writing by the Local Planning Authority in conjunction with the

Lead Local Flood Authority and all development pursuant to this permission

shall be carried out in accordance with the approved details:

(a) A Lifetime Maintenance Plan for the SuDS system to include:

- A full description of how the system would work, it's aims and objectives and

the flow control arrangements;

- A Maintenance Inspection Checklist/Log;

- A Maintenance Schedule of Work itemising the tasks to be undertaken, such

as the frequency required and the costs incurred to maintain the system.

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REASON: To improve sustainability, reduce flood risk and reduce water runoff

rates in accordance with the following policy of the Local Plan: DM18.1, DM18.2

and DM18.3.

Climate Resilience

55. Prior to the commencement of the development, excluding demolition, a

Climate Change Resilience Sustainability Statement (CCRSS) shall be

submitted to and approved in writing by the Local Planning Authority, that

demonstrates that the development is resilient and adaptable to predicted

climate conditions during the lifetime of the development. The CCRSS shall

include details of the climate risks that the development faces (including flood,

heat stress, water stress, natural capital, pests and diseases) and the climate

resilience solutions for addressing such risks. The CCRSS will demonstrate that

the potential for resilience and adaptation measures (including but not limited

to solar shading to prevent solar gain; high thermal mass of building fabric to

moderate temperature fluctuations; cool roofs to prevent overheating; urban

greening; rainwater attenuation and drainage; flood risk mitigation; biodiversity

protection; passive ventilation and heat recovery and air quality assessment to

ensure building services do not contribute to worsening photochemical smog)

has been considered and appropriate measures incorporated in the design of

the building. The CCRSS shall also demonstrate how the development will be

operated and managed to ensure the identified measures are maintained for

the life of the development. The development shall be carried out in accordance

with the approved CCRSS and operated and managed in accordance with the

approved CCRSS for the life of the development.

REASON: To comply with Local Plan Policy DM 15.5 Climate change resilience

and adaptation.

56. Within 6 months of completion details of climate change resilience measures

must be submitted to the Local Planning Authority demonstrating the measures

that have been incorporated to ensure that the development is resilient to the

predicted weather patterns during the lifetime of the building. This should

include details of the climate risks that the site faces (flood, heat stress, water

stress, natural capital, pests and diseases) and the climate resilience solutions

that have been implemented.

REASON: To comply with Local Plan Policy DM 15.5 Climate change resilience

and adaptation.

BREEAM

57. A post construction BREEAM assessment demonstrating that a target rating of

at least 'Excellent' has been achieved (or such other target rating as the local

planning authority may agree provided that it is satisfied all reasonable

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endeavours have been used to achieve an 'Excellent' rating) shall be submitted

as soon as practicable after practical completion.

REASON: To demonstrate that carbon emissions have been minimised and

that the development is sustainable in accordance with the following policy of

the Local Plan: CS15, DM15.1, DM15.2.

Security

58. Prior to occupation, security measures must be provided within the

development, having being developed in consultation with City Police, such as

CCTV, lighting, entrances and improvements to secure access.

REASON: To ensure safety and security in accordance with Local Plan policies

CS3 and DM3.2.

Suicide Prevention Measures

59. Prior to the occupation of the roof terrace, details of suicide prevention

measures to prevent jumping or falling from the development shall be submitted

to and approved in writing by the Local Planning Authority. All development

pursuant to this permission shall be carried out in accordance with the approved

details and maintained for the life of the building.

REASON: To ensure that the Local Planning Authority may be satisfied with the

detail of the proposed development and to ensure adequate safety measures

are in place in accordance with Local Plan Policy CS3 and emerging draft City

Plan 2036 Policy DE2 and DE5.

Telecommunications equipment

60. Unless otherwise approved by the LPA no plant or telecommunications

equipment shall be installed on the exterior of the building, including any plant

or telecommunications equipment permitted by the Town & Country Planning

(General Permitted Development) Order 2015 or in any provisions in any

statutory instrument revoking and re-enacting that Order with or without

modification.

REASON: , To ensure a satisfactory external appearance in accordance with

the following policy of the Local Plan: DM10.1.

Approved Plans

61. The development shall not be carried out other than in accordance with the

following approved drawings and particulars or as approved under conditions

of this planning permission:

Site Location Plan 01820-WEA-XX-ST-PD-A-0003 Rev 00

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Demolition: PD-A-0150 Rev 00, PD-A-0151 Rev 00, PD-A-0152 Rev 01, PD-A-

0349 Rev 00, PD-A-0350 Rev 00, PD-A-0351 Rev 00, PD-A-0352 Rev 00, and

PD-A-0353 Rev 00.

Proposed Furnival Street:

PROPOSED B3 PLAN – 01-B3-PD-A-1097 Rev 00;

PROPOSED B2 PLAN – 01-B2-PD-A-1098 Rev 00;

PROPOSED B1 PLAN – 01-B1-PD-A-1099 Rev 02;

PROPOSED L00 PLAN – 01-00-PD-A-1100 Rev 04;

PROPOSED L01 PLAN – 01-01-PD-A-1101 Rev 00;

PROPOSED L02 PLAN – 01-02-PD-A-1102 Rev 01;

PROPOSED L03 PLAN – 01-03-PD-A-1103 Rev 00;

PROPOSED L04 PLAN – 01-04-PD-A-1104 Rev 00;

PROPOSED L05 PLAN – 01-05-PD-A-1105 Rev 00;

PROPOSED ROOF PLAN – 01-RF-PD-A-1106 Rev 00;

OVERALL PROPOSED WEST ELEVATION – 01-W-PD-A-2100 Rev 01;

PROPOSED WEST ELEVATION – 01-W-PD-A-2104 Rev 01;

PROPOSED NORTH ELEVATION – 01-N-PD-A-2101 Rev 00;

PROPOSED SOUTH ELEVATION – 01-S-PD-A-2102 Rev 01;

PROPOSED EAST ELEVATION – 01-E-PD-A-2103 Rev 01;

WEST FAÇADE SETTING OUT – 01-ZZ-PD-A-3050 Rev 00;

GA BUILDING SECTION AA – 01-AA-PD-A-3100 Rev 01;

GA BUILDING SECTION BB – 01-BB-PD-A-3101 Rev 01;

GA BUILDING SECTION CC – 01-CC-PD-A-3102 Rev 01;

GA SHAFT SECTION AA – 01-AA-PD-A-3103 Rev 01;

GA SHAFT SECTION CC – 01-CC-PD-A-3105 Rev 01;

CENTRAL LIFT DETAIL – 01-ZZ-A-4150 Rev 00;

STAFF BIKE STORE (Ground floor plan) – 01-00-A-4151 Rev 02;

FAÇADE TYPE 01 - GLASS BRICK LOWER – 01-ZZ-PD-A-5101 Rev 01;

FAÇADE TYPE 01B - GLASS BRICK – UPPER – 01-ZZ-PD-A-5107 Rev 01;

FAÇADE TYPE 02 - REINSTATED BRICK – 01-ZZ-PD-A-5102 Rev 01;

FAÇADE TYPE 03 - GROUND FLOOR EXIT – 01-ZZ-PD-A-5103 Rev 01;

FACADE TYPE 03B - GROUND FLOOR ENTRANCE – 01-ZZ-PD-A-5108

Rev01;

FAÇADE TYPE 04 - L04 TERRACE – 01-ZZ-PD-A-5104 Rev 01;

FAÇADE TYPE 05 - PLANT SCREEN – 01-ZZ-PD-A-5105 Rev 01;

FAÇADE TYPE 06 - PARTY WALL – 01-ZZ-PD-A-5106 Rev 00;

Plan showing extend of Section 278 works – 70106185-TP-SK-1 P02;

Proposed Tunnels GAs:

PROPOSED LMINUS 01 – PLAN 03-M1-PD-A-0099 Rev 00;

PROPOSED LPLUS 01 PLAN – 03-01-PD-A-1001 Rev 00;

PROPOSED LPLUS 02 PLAN – 03-02-PD-A-1002 Rev 00;

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PROPOSED LPLUS 03 PLAN – 03-03-PD-A-1003 Rev 00;

PROPOSED SECTOR A PLAN – 03-ZZ-PD-A-1010 Rev 01;

PROPOSED SECTOR B PLAN – 03-ZZ-PD-A-1011 Rev 01;

PROPOSED SECTOR C & D PLAN – 03-ZZ-PD-A-1012 Rev 01;

PROPOSED SECTOR B PLAN – 03-ZZ-PD-A-1013 Rev 01;

PROPOSED - CROSS SECTIONS – 03-ZZ-PD-A-3300 Rev 00.

REASON: To ensure that the development of this site is in compliance with

details and particulars which have been approved by the Local Planning

Authority.

INFORMATIVES

1. In dealing with this application the City has implemented the requirements of

the National Planning Policy Framework to work with the applicant in a positive

and proactive manner based on seeking solutions to problems arising in dealing

with planning applications in the following ways:

- detailed advice in the form of statutory policies in the Local Plan,

Supplementary Planning documents, and other written guidance has been

made available;

- a full pre application advice service has been offered;

where appropriate the City has been available to provide guidance on

how outstanding planning concerns may be addressed.

2. This approval relates only to the details listed above and must not be construed

as approval of any other details shown on the approved drawings.

3. Access for people with disabilities is a material consideration in the

determination of planning applications. The City of London Corporation has

published design standards giving advice on access for people with disabilities

and setting out the minimum standards it expects to see adopted in the City

buildings. These can be obtained from the City's Access Adviser, Chief

Planning Officer and District Surveyor. Further advice on improving access for

people with disabilities can be obtained from the City's Access Adviser. Your

attention is drawn to the Disability Discrimination provisions of the Equality Act

2010 to ensure that disabled people are not significantly disadvantaged.

Service providers, etc., should make "reasonable adjustments" to facilitate

access to their premises and the City asks all applicants for planning permission

to ensure that physical barriers to access premises are minimised in any works

carried out.

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4. Service providers are required to have regard to obligations under the Equality

Act 2010. In the exercise of their functions, due regard needs to be given to:

• elimination of discrimination, harassment and victimisation and any other

conduct that is prohibited by or under this Act;

• advancement of equality of opportunity between persons who share a

relevant protected characteristic and persons who do not share it;

• fostering good relations between persons who share a relevant

protected characteristic and persons who do not share it

The relevant protected characteristics are age, disability, gender reassignment,

pregnancy and maternity, race, religion or belief, sex and sexual orientation.

Public authorities also need to have due regard to the need to eliminate

unlawful discrimination against someone because of their marriage or civil

partnership status.

5. The developer should be aware that, in creating a roof terrace, and therefore

access to the roof, users of the roof could be exposed to emissions of air

pollutants from any chimneys that extract on the roof e.g. from gas boilers /

generators / CHP. In order to minimise risk, as a rule of thumb, we would

suggest a design that places a minimum of 3 metres from the point of efflux of

any chimney serving combustion plant, to any person using the roof terrace.

This distance should allow the gases to disperse adequately at that height,

minimising the risk to health.

6. Generators and combustion plant

Please be aware that backup/emergency generators may require permitting

under the MCP directive and require a permit by the appropriate deadline.

Further advice can be obtained from here: Medium combustion plant and

specified generators: environmental permits - GOV.UK (www.gov.uk)

7. Environmental Agency: Water Resources

Increased water efficiency for all new developments potentially enables more

growth with the same water resources. Developers can highlight positive

corporate social responsibility messages and the use of technology to help sell

their homes. For the homeowner lower water usage also reduces water and

energy bills.

We endorse the use of water efficiency measures especially in new

developments. Use of technology that ensures efficient use of natural resources

could support the environmental benefits of future proposals and could help

attract investment to the area. Therefore, water efficient technology, fixtures

and fittings should be considered as part of new developments.

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We recommend that all new non-residential development of 1000sqm gross

floor area or more should meet the BREEAM ‘excellent’ standards for water

consumption.

8. Thames Water

Waste –

“A Groundwater Risk Management Permit from Thames Water will be required

for discharging groundwater into a public sewer. Any discharge made without

a permit is deemed illegal and may result in prosecution under the provisions

of the Water Industry Act 1991. We would expect the developer to demonstrate

what measures he will undertake to minimise groundwater discharges into the

public sewer. Permit enquiries should be directed to Thames Water’s Risk

Management Team by telephoning 020 3577 9483 or by emailing

[email protected]. Application forms should be completed on

line via www.thameswater.co.uk. Please refer to the Wholesale; Business

customers; Groundwater discharges section.

Water –

Thames Water will aim to provide customers with a minimum pressure of 10m

head (approx 1 bar) and a flow rate of 9 litres/minute at the point where it leaves

Thames Waters pipes. The developer should take account of this minimum

pressure in the design of the proposed development.

9. This permission must in no way be deemed to be an approval for the display of

advertisement matter indicated on the drawing(s) which must form the subject

of a separate application under the Advertisement Regulations.

10. This permission must in no way be deemed to prejudice any rights of light which

may be enjoyed by the adjoining owners or occupiers under Common Law.

11. WilkinsonEyre Architects should be retained for the detailed construction stage

of the project.

12. This permission is granted having regard to planning considerations only and

is without prejudice to the position of the City of London Corporation or

Transport for London as Highway Authority; and work must not be commenced

until the consent of the Highway Authority has been obtained.

13. Improvement or other works to the public highway shown on the submitted

drawings require separate approval from the local highway authority and the

planning permission hereby granted does not authorise these works.

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14. The correct street number or number and name must be displayed prominently

on the premises in accordance with regulations made under Section 12 of the

London Building Acts (Amendment) Act 1939. Names and numbers must be

agreed with the Department of the Built Environment prior to their use including

use for marketing.

15. The landowners, managing operators and tenants are required to adhere to the

actions of the Considerate Lighting Charter as set in the City of London

Appendix A of the City of London Lighting Supplementary Planning Document

17/11/2022

16. The Crime Prevention Design Advisor for the City of London Police and the

Counter-Terrorism Security Advisor should be consulted with regard to

guidance on all aspects of security, means of crime prevention in new

development and on current crime trends.

17. The grant of approval under the Town and Country Planning Acts does not

overcome the need to also obtain any licences and consents which may be

required by other legislation. The London Fire Brigade should form a key

stakeholder at detailed design stage including Qualitative Design Review

(QDR) process, fire precautions and certification stages.

Archaeology

18. The Written Scheme of Investigation will need to be prepared and implemented

by a suitably professionally accredited heritage practice in accordance with

Historic England’s Guidelines for Archaeological Projects in Greater London.

The pre-commencement conditions are necessary to safeguard the

archaeological interest on this site. Approval of the WSI before works begin on

site provides clarity on what investigations are required, and their timing in

relation to the development programme.

Evaluation: An archaeological field evaluation involves exploratory fieldwork to

determine if significant remains are present on a site and if so to define their

character, extend, quality and preservation. Field evaluation may involve one

or more techniques depending on the nature of the site and its archaeological

potential. It will normally include excavation of trial trenches.

Historic Building Recording: Historic building recording is an investigation to

establish the character, history, dating, form and development of a historic

building or structure which normally takes place as a condition of planning

permission before any alteration or demolition takes place. The outcome will be

an archive and a report which may be published. You can find more information

on archaeology and planning in Greater London on GLAAS website.

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19. The Directorate of the Built Environment (District Surveyor) should be consulted

on means of escape and constructional details under the Building Regulations

and London Building Acts.