ST. JOHN’S WOOD SQUARE PROJECT S73 SBMISSION · 2018-07-20 · THE ST JOHN’S WOOD PROJECT...

ST. JOHN ’S WOOD SQUA R E PROJ ECT

S73 SU BMISSION

December 2016 | Applicant: St. John’s Wood Square Ltd | Prepared by: Ramboll Environ

V O L U M E 1 R E P L A C E M E N T– E N V I R O N M E N T A L S T A T E M E N T –

N O N T E C H N I C A L S U M M A R Y

Intended for

St John’s Wood Square Ltd

Date

December 2016

Project Number

UK11-23727

THE ST JOHN’S WOOD PROJECT VOLUME 1: NON-TECHNICAL SUMMARY

THE ST JOHN’S WOOD PROJECT VOLUME 1: NON-TECHNICAL SUMMARY

Ramboll Environ Artillery House 11-19 Artillery Row London SW1P 1RT United Kingdom T +44 207 808 1420 www.ramboll-environ.com

Project No. UK11-23727 Issue No. Final Date 23/12/2016 Made by Sheenagh Mann Checked by Sheenagh Mann Approved by Michelle Wheeler

Made by:

Checked/Approved by:

This report has been prepared by Ramboll Environ with all reasonable skill, care and diligence, and taking account of the Services and the Terms agreed between Ramboll Environ and the Client. This report is confidential to the Client, and Ramboll Environ accepts no responsibility whatsoever to third parties to whom this report, or any part thereof, is made known, unless formally agreed by Ramboll Environ beforehand. Any such party relies upon the report at their own risk. Ramboll Environ disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the Services. Version Control Log

Revision Date Made by Checked by Approved by Description

1 21/12/16 SM SM MW First Issue

Final 23/12/16 MW MW MW Final for Planning Submission

Volume 1: Non-Technical Summary St John’s Wood Project

CONTENTS

PREFACE I 1. INTRODUCTION 1 2. EIA PROCESS 4 2.1 Planning Policy Context 4 2.2 Baseline 5 2.3 Assessment Approach 6 3. CONSULTATION AND SCOPING 8 3.1 EIA Scoping and Consultation 8 4. ALTERNATIVES AND DESIGN EVOLUTION 10 4.1 Main Site 10 4.2 Pre-2015 Consent Preferred Option 12 4.3 Post-2015 Alternatives and Design Evolution 12 4.4 Do Nothing Scenario 13 4.5 Summary 13 5. DESCRIPTION OF PROPOSED DEVELOPMENT 14 6. SUMMARY OF POTENTIAL IMPACTS AND LIKELY EFFECTS 28 6.1 Socio Economics 28 6.2 Archaeology 30 6.3 Transport and Access 30 6.4 Air Quality 32 6.5 Noise and Vibration 34 6.6 Ground Conditions and Contamination 35 6.7 Water Resources, Hydrology and Flood Risk 37 6.8 Ecology 38 6.9 Daylight, Sunlight and Overshadowing 41 6.10 Wind 42 6.11 Heritage, Townscape and Visual Assessment 43 6.12 Cumulative Effects 46 LIST OF TABLES

Table 1: Main Site – Amended Proposed Development Schedule of Floorspace....................... 14 Table 2: Main Site Amended Proposed Development Residential Unit and Tenure Mix ............. 16 Table 3: Main Site Amended Proposed Development Car Parking Provision ............................ 17 LIST OF FIGURES

Figure 1: Main Site Location .............................................................................................. 1 Figure 2: Main Site Redline Boundary ................................................................................. 2 Figure 3: Representative Main Site Photographs .................................................................. 3 Figure 4: Pre-2015 Consent Site Layout Options for the Main Site ........................................ 11 Figure 5: Main Site Amended Proposed Development Layout ............................................... 15 Figure 6: Amended Proposed Development Main Site - Lower Ground 1 Level General

Arrangement ................................................................................................... 19 Figure 7: Amended Proposed Development Main Site - Lower Ground Level General

Arrangement ................................................................................................... 20 Figure 8: Amended Proposed Development Main Site - Ground Level General Arrangement .... 21 Figure 9: Amended Proposed Development Main Site – First Floor Level General

Arrangement ................................................................................................... 22 Figure 10: Amended Proposed Development Main Site – Fourth Floor Level General

Arrangement .................................................................................................. 23 Figure 11: Amended Proposed Development Main Site – Sixth Floor Level General

Arrangement .................................................................................................. 24 Figure 12: Amended Proposed Development Landscape Masterplan ..................................... 25

Volume 1: Non-Technical Summary St John’s Wood Project

Figure 13: Existing Site Habitats ...................................................................................... 39 Figure 14: Amended Proposed Development as seen from Queen’s Terrace looking North-

west (Summer View) ...................................................................................... 44 Figure 15: Amended Proposed Development as seen from Ordnance Hill at Rossetti Mews

looking South-east (Summer View) ................................................................... 45 Figure 16: Amended Proposed Development as seen from Finchley Road looking North

towards Queen’s Terrace (Summer view) .......................................................... 45

Volume 1: Non-Technical Summary The St John’s Wood Project

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PREFACE

Background

In August 2014, the following three planning applications were submitted to Westminster City Council (WCC) (collectively referred to as the ‘2014 Application’) on behalf of St John’s Wood Square Ltd (‘the Applicant’ for the St John’s Wood Square Project) and SJW Estates Ltd (‘the Applicant’ for Sentinel House) in accordance with the statutory procedures set out in the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (SI 2011/1824) (‘the EIA Regulations’):

• Full planning application for the St John’s Wood Square site (hereafter referred to as the ‘Main Site’): Ref 14/08070/FULL – “Demolition of existing Barracks buildings (except for the listed Riding School) and redevelopment for residential use (Class C3) to provide a total of 163 units including 59 affordable units. Use of the listed Riding School as private ancillary leisure facility with internal and external alterations. Provision of Class A1/A3 retail units and Class D1 at ground level at 1 - 7 Queen's Terrace, redevelopment behind the retained front facade and the erection of a mansard roof extension ,creation of landscaped areas and reconfigured vehicular and pedestrian access together with associated works including the provision of parking, circulation space, servicing and plant areas.”

• Listed building consent for the Main Site: Ref 14/08099/LBC – "Use of the listed Riding School as a private ancillary leisure facility, associated internal and external alterations, new side extension and the excavation of a lower ground floor beneath the Riding School."

• Full planning application for Sentinel House site (hereafter referred to as the ‘AAH Site’): Ref 14/08069/FULL – “Demolition of existing office building and construction of nine storey residential building comprising 41 affordable housing flats, landscaping along Old Marylebone Road and associated car parking and works.”

The 2014 Application was accompanied by an overarching Environmental Statement (hereafter referred to as the ‘2014 ES’) which reported on the outcomes of an Environmental Impact Assessment (EIA) of the above combined developments.

In April 2015 (hereafter referred to as the ‘2015 Consent’), WCC granted planning permission for the three planning applications (hereafter referred to as the ‘Consented Development’ for the Main Site and the ‘AAH Consented Development for the AAH Site’).

The Consented Development comprises the following:

• The demolition of all the buildings on-site, with the exception of the Grade II listed former Riding School and the south-western façade of 1-7 Queen’s Terrace;

• The erection of ten blocks (1-10) arranged along the north-east, south-east and south-west boundaries for the following:

• 163 new residential units consisting of 15 houses and 88 apartments including 59 affordable housing units;

• 460 m2 (GEA) of retail use (Use Class A1/A3);

• The refurbishment of the listed Riding School to accommodate private ancillary uses (i.e. an event space, gymnasium, spa and swimming pool) to the proposed residential units; and

• The provisioning of 189 car parking spaces.

The AAH Consented Development comprises the following:

• The demolition of the existing Sentinel House building;

• The construction of a single nine storey block to provide 41 affordable residential units; and

• The provisioning of 12 car parking spaces.


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Following the grant of full planning and listed building permission for the Main Site, the normal period of design refinement and technical development was undertaken. This resulted in the development of a series of refinements to the design of the Consented Development.

Following extensive and proactive WCC and stakeholder consultations, the Applicant is now seeking planning consent for the following amendments to the Consented Development:

• Increase in residential units from 163 to 171 units with associated change in unit mix;

• Amendment to Block 4 building typology from six detached houses and a terrace of four houses to a 5 storey apartment building and three villas;

• Increase in height of Block 9 (by 200 mm) and Block 10 (by 655 mm);

• Increase in Block 7 footprint (by 6 m) and reduction in Block 8 footprint (by 8 m);

• Increase in footprint of Block 4 by 2 m to the rear;

• Refinement to the façade treatment of all blocks;

• Amended construction methodology for the basement and associated increased development programme;

• Amendment of the demolition and construction access routing;

• Reduction in the extent and volume of basement excavation by 3.2 %;

• Marginal increase in the depth of the basement finished floor level (FFL) by 100 mm;

• Increase in car parking spaces from 189 to 203 (12 additional residential spaces and two additional visitor spaces);

• Introduction of an automated vehicle stacking system in the basement for the affordable housing units;

• Update of landscape masterplan and associated works comprising the following:

− Increase of planted perimeter surrounding The Square (previously referred to as the ‘The Riding School Square’) and relocation of three visitor parking/ drop off bays to the lower ground floor car park;

− Increase in provision of new ‘strategic’ trees on-site from 78 to 120;

− Amendment to the entrance and approach from Ordnance Hill to The Avenue (previously referred to as the ‘Linear Square’) to provide an improved alignment of landscape spaces, and subsequent redistribution of planting;

− Development of piazza paving and tree planting concept on The Avenue; and

− Amendment to the location of five proposed street trees on Ordnance Hill.

• Removal one tree on Ordnance Hill and two on Queens Terrace (increase from 40 trees removed to 43 in total);

• Amendments to the Grade II Listed Riding School comprising the following:

− Minor adjustments to the internal configuration of the pavilion buildings within the Riding School, and access between the ground and lower ground floors;

− Adjustment to the configuration of the residential facilities below ground;

− Adjustment to the design of the western pavilion and connection point into the Riding School; and

− Retention and repair of the existing external brickwork following the removal of the render.

Accordingly, the Applicant will be submitting a S73 Application (hereafter referred to as ‘the 2016 S73 Application’), as well as an amendment to the Listed Building Consent (hereafter referred to as ‘the S19 Listed Building Application’. Collectively the two applications are referred to as the ‘2016 Applications’).


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The Consented Development as amended by the above proposed amendments is hereafter collectively referred to as the ‘Amended Proposed Development’ and relates only to the Main Site.

No amendments are sought for the AAH Consented Development

In summary the Amended Proposed Development comprises the following:

• Demolition of all of the existing buildings within the Main Site with the exception of the listed Riding School and south-western façade of 1-7 Queen’s Terrace;

• Erection of ten blocks which vary in height from three storeys to seven storeys and re-use of listed Riding School to provide 171 residential units (including 59 affordable units), private ancillary leisure use (3,600 m2 GEA); community use (100 m2); and retail use (500 m2 GEA);

• Provision of 203 car parking spaces within a site wide, three level basement; and

• Landscaping and access arrangements.

Reason for Submission

The Amended Proposed Development falls within Schedule 2, Category 10b of the EIA Regulations 2011 (as amended in 2015) (hereafter referred to as the ‘EIA Regulations’) as an ‘urban development project’ which, owing to its nature, scale and location, has the potential to give rise to significant effects on the environment.

Accordingly, the Applicant has commissioned Ramboll Environ UK Limited (Ramboll Environ) to prepare an Addendum to the 2014 ES for the Amended Proposed Development, which would accompany the 2016 S73 Application and the S19 Listed Building Application. The ES Addendum format has been agreed in consultation with WCC. As there is no likelihood of significant combined environmental effects arising from the proposed amendments together with the AAH Consented Development, the AAH Site is not considered further in the ES Addendum.

The ES Addendum comprises five volumes:

• Volume 1: Replacement Non-Technical Summary (NTS) (this document);

• Volume 2 Addendum: ES Main Report;

• Volume 3 Addendum: Heritage, Townscape and Visual Assessment (HTVA);

• Volume 4 Addendum: Technical Appendices; and

• Volume 5: 2014 Environmental Statement (provided electronically).

This document comprises ES Volume 1 of the ES Addendum and is based on the 2014 NTS, but fully updated for the Amended Proposed Development.

The 2016 ES Addendum provides an up-to-date assessment of the Amended Proposed Development where relevant by reference to the 2014 ES. Where the content of the 2014 ES remains valid and accurate for the Amended Proposed Development, the 2016 ES Addendum refers to the relevant parts of the 2014 ES. Accordingly, the ES Addendum should be read in conjunction with the 2014 ES.

The 2016 Applications will be available for viewing at:

Westminster City Council

Westminster City Hall

64 Victoria Street

London, SW1 6QP

The ES comprising five volumes will be available for purchase at £10/CD copy at:

Ramboll Environ UK Ltd

Artillery House

11-19 Artillery Row, London, SW1P 1RT


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1. INTRODUCTION

The Main Site of the Amended Proposed Development is located within St John’s Wood, as shown in Figure 1, between Finchley Road to the west and Primrose Hill to the east, within the administrative boundary of WCC.

Figure 1: Main Site Location

The Main Site is largely located in the St John’s Wood Conservation Area (CA) with the exception of the Jubilee Buildings, located in the western part of the Main Site. The Main Site is identified as a ‘Strategic Housing Site’ within the Westminster’s City Plan: Strategic Policies (‘the City Plan’)1, with the preferred uses being ‘Residential with Community Uses’, and located within an area of open space deficiency, as designated in the City Plan.

There are a number of Grade II listed buildings in the vicinity of the Main Site, in addition to the Grade II listed Riding School on-site. Other buildings include the terrace of properties at 1-22 Queen’s Grove, along the south-west boundary, 4-12a, 14, and 19-25 Norfolk Road to the north-east.

1 Westminster City Council, 2016. Westminster City Plan: Strategic Policies. London. Westminster City Council.


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The surroundings of the Main Site are typical of the urban area around St John’s Wood, consisting predominantly of residential uses. The Main Site is bordered on all sides by residential developments.

As shown in Figure 2, the Main Site is roughly square in form and occupies an area of approximately 2.2 hectares (ha).

Figure 2: Main Site Redline Boundary

The Main Site is comprised predominantly of hardstanding and buildings, including the former Parade Square. Two soft landscaped gardens are located towards the north-eastern and eastern parts of the Main Site. The existing buildings on-site range from a single storey to five storeys in height, with the tallest buildings located along Queen’s Terrace.

A small single level basement, previously used as a plant room, is located beneath the Armoury Building in the south-west of the Main Site. A further two small single level basements are located beneath one of the landscaped gardens and near to the former Sergeant’s Mess in the eastern part of the Main Site.

Vehicular access to the Main Site is via an existing entrance from Ordnance Hill to the west.

The Main Site has remained largely vacant and unoccupied since the St John’s Wood Barracks ceased operation in 2012. One retail unit remains occupied at 1-7 Queen’s Terrace; and all of the 16 residential units located above the retail units are vacant.

Figure 3 shows representative photographs of the Main Site.


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North-western Boundary looking south North-eastern Boundary looking west

South-eastern Boundary looking north South-eastern Corner looking north-west

South-western Boundary looking north View within listed Riding School

Figure 3: Representative Main Site Photographs

Since the 2015 Consent the following works have been progressed at the Main Site in readiness for demolition of the existing buildings:

• Removal of asbestos within on-site buildings;

• Removal of external render to the Riding School;

• Removal of internal paint to the Riding School;

• Minor structural stabilisation to the Riding School façade;

• Historic Building Recording, as well as Archaeological Evaluation and Excavation Works;

• Site Investigations (SI); and

• Removal of minor vegetation and trees, installation of bat boxes and trimming of trees within the Sanctuary Garden.


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2. EIA PROCESS

EIA is a process that must be followed for certain types of development before a decision is made on whether planning permission should be granted. In 2014, the redevelopment proposals for the Main Site were considered to fall within the definition of an “urban development project” described in 10(b) of Schedule 2 of the 2011 EIA Regulations. The scale and nature of the AAH Site’s redevelopment proposals were not considered to fall within Schedule 2 of the EIA Regulations. However, given that both Sites formed part an integral part of the Proposed Development, i.e. the Main Site and the AAH Site combined, the Proposed Development contemplated at the time, required an EIA to be undertaken.

The Amended Proposed Development for the Main Site falls within Schedule 2, Category 10b of the EIA Regulations 2011 (as amended in 2015) (hereafter referred to as the ‘EIA Regulations’) as an ‘urban development project’ which, owing to its nature, scale and location, has the potential to give rise to significant effects on the environment.

The EIA Regulations enable the consideration of changes or extensions to development already authorised through Schedule 2, point 13(b)(i), in which an EIA is required where “… the development as changed or extended may have significant effects on the environment”. As the principle of the Consented Development for the Main Site, which was subject to an EIA, has been approved, the consideration is now whether any materially new or different significant effects, or changes to the conclusions previously drawn, are likely to arise from the Amended Proposed Development as a whole.

In respect of the 2016 S73 Application, the Planning Practice Guidance states that a “S73 application is considered to be a new application for planning permission under the Town and Country Planning (EIA) Regulations 2011”. The guidance goes further to address where an ES accompanied the initial application (i.e. the 2014 ES), and states that “Where an Environmental Impact Assessment was carried out on the original application, the planning authority will need to consider if further information needs to be added to the original Environmental Statement to satisfy the requirements of the Regulations”. It is concluded that whether changes to the initial ES are required or not, an ES must be submitted to accompany the 2016 S73 Application.

The results of the EIA process are presented within this ES Addendum, which describes the potential impacts and likely effects of the Amended Proposed Development during the demolition and construction stage and on completion and occupation of the Amended Proposed Development.

As agreed in consultation with WCC, there is no likelihood of significant combined environmental effects arising from the proposed amendments together with the AAH Consented Development and therefore, the AAH Site has not been considered in the ES Addendum. Accordingly, this NTS only focusses on the Amended Proposed Development for the Main Site.

The aim of the NTS is to summarise the content and main findings of the ES in a clear and concise manner to assist the public in understanding what the environmental impacts and significant effects of the Amended Proposed Development may be.

ES Volumes 2 and 3 and the supporting technical appendices in Volume 4A and 4B provide a more detailed description of the Main Site, the characteristics of the Amended Proposed Development and the findings of the ES Addendum.

2.1 Planning Policy Context

The Amended Proposed Development has been assessed within the context of relevant national, regional and local planning policies. Planning policy has been considered in each technical chapter of the ES Addendum as appropriate for the consideration of potential impacts and likely effects.


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In particular, the EIA has been undertaken by reference to the following documents:

• National Planning Policy Framework (NPPF)2;

• Planning Practice Guidance (PPG)3

• London Plan (2016)4;

• WCC City Plan: Strategic Policies (2016)5 and Updated Policies Map (2016); and

• WCC Replacement Unitary Development Plan saved policies (UDP) (2007)6.

At the national level, the policies contained within the NPPF set out Government's economic, environmental and social planning policies for England, and the NPPF is a key driver in delivering sustainable development. On a local scale, the WCC City Plan is the principal document of the Local Development Framework (LDF), it identifies the social, economic and environmental objectives for future development in the City of Westminster (CoW).

2.2 Baseline

The purpose of EIA is to predict how environmental conditions may change as a result of the Amended Proposed Development and to specify any investigative measures. This requires that the environmental conditions that currently exist (or at least in the near future, before demolition and construction of the Amended Proposed Development gets underway) and in the future, assuming no development, are established.

This is referred to as the baseline and is usually established through a combination of desk-based research, site survey, empirical studies and projections. Together, these describe the current and future character of a site, and the value and vulnerability of key environmental resources and receptors, against which any changes or effects resulting from the Amended Proposed Development can be identified, understood and assessed.

The baseline for the 2014 ES was been taken as the 'current' Main Site, and the immediate surroundings for the Main Site as described in 2014 ES Chapter 1: Introduction. This is because minimal change has occurred at the Main Site since the 2014 Consent and therefore the 2014 baseline position and environmental sensitivities of the Main Site, remain materially valid and representative for the purpose of the 2016 ES Addendum.

For the purposes of the Transport and Access, Air Quality and Noise and Vibration assessments within the 2014 ES, a 'Future Baseline' of 2019 was considered for the anticipated year in which the Proposed Development would be completed (also referred to as 'Year of Opening'). The year of opening is now anticipated to be 2022, however the baseline traffic flows remain valid as there is expected to be no significant background growth on the local highway network, as agreed through consultation with TfL.

Sensitive receptors in the vicinity of the Main Site, which have the potential to be affected by the Amended Proposed Development have been identified. The identified receptors include:

• Existing commercial occupants of the Main Site;

• Existing community facilities, residential occupants and commercial occupants in proximity to the Main Site;

2 Department for Communities and Local Government. March 2012. The National Planning Policy Framework. HMSO. 3 Department for Communities and Local Government, March 2014. National Planning Practise Guidance. DCLG. 4Greater London Authority, 2016. The London Plan: The Spatial Development Strategy for London Consolidated with Alterations Since 2011. Greater London Authority, London 5 City of Westminster, 2016. Westminster City Plan Consolidated Version incorporating Basement Revision and Mixed Use Revision. London. WCC. 6 Westminster City Council, 2007. Replacement Unitary Development Plan. London. Westminster City Council.


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• Future residential and commercial occupants of the Amended Proposed Development and committed or reasonably foreseeable schemes in the immediate surroundings of the Main Site;

• Potential archaeological assets on the Main Site;

• Setting of the Conservation Areas and listed buildings in proximity to the Main Site;

• Short, Medium and Long distance views to and from the Main Site;

• Local Air Quality;

• Local Transport Infrastructure (including road users of the immediate local road network surrounding the Main Site and the A41 Finchley Road);

• Pedestrians and uses of existing and proposed amenity areas;

• Water Resources; and

• Ecological Receptors (on-site roosting bats and off-site at the Primrose Hill site north-east of the Main Site and the St. John’s Wood Church Grounds south-west of the Main Site).

2.3 Assessment Approach

The EIA has considered the potential direct, indirect and cumulative impacts of the Amended Proposed Development:

• Direct impacts are those which arise as a direct consequence of a project action, e.g. the loss of habitat;

• Indirect impacts are those which arise as a result of the direct impacts, e.g. the decline in the abundance of a species as a result of the loss of habitat; and

• Cumulative impacts can occur in two ways; i) those which occur as a result of the Amended Proposed Development in combination with other committed developments within an agreed zone of influence, and ii) those which occur as a result of different types of impacts interacting i.e. the multiplying effect arising from noise, dust and visual impacts during construction.

As part of the EIA, an iterative approach has been adopted where potentially significant environmental impacts and effects have been avoided in the first instance through the initial design, and in subsequent design refinements and iterations. This has enabled many mitigation measures to be effectively designed into the Amended Proposed Development. Additional mitigation during the demolition and construction stage, and the completed development stage has also been identified as appropriate.

The 2014 ES and the 2016 ES Addendum has reported on the residual effects, which are those effects that remain following the incorporation of any identified mitigation measures.

The assessment of residual environmental effects is important in that it informs the determination by the planning authority of the overall acceptability of the proposal. Specific criteria have been developed to define the significance of an effect, wherever possible, defined and structured as transparently as possible using the criteria listed below:

• The sensitivity of the receptor (low, medium or high);

• The magnitude of the potential impact (unknown, neutral, small, medium or high);

• The likelihood of the effect occurring (unlikely, likely or certain);

• The duration of the effect (short, medium or long term);

• The geographical extent of the impacts (local, borough, regional, national or international); and

• The reversibility of the effect (reversible or irreversible).

The significance of residual effects has been evaluated with reference to definitive standards, accepted/published criteria and legislation, where available. Where it has not been possible to


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quantify potential impacts and residual effects, qualitative assessments have been carried out, based on expert knowledge and professional judgement.

In order to provide a consistent approach to the presentation of the significance of residual effects, the following terminology has been used throughout the 2014 ES and ES Addendum to describe the type/nature of residual effect:

• Adverse - detrimental or negative effect to an environmental resource or receptor;

• Neutral - an effect that on balance, is neither beneficial nor adverse to an environmental resource or receptor; and

• Beneficial - advantageous or positive effect to an environmental resource or receptor.

Where adverse of beneficial effects have been identified, they have been classified according to the following scale:

• Negligible - imperceptible effect;

• Minor - slight, very short or highly localised effect;

• Moderate - limited effect (by magnitude, duration, reversibility, value and sensitivity of receptor) which may be considered significant; and

• Major - considerable effect (by magnitude, duration, reversibility, value and sensitivity of receptor) which may be more than of a local significance or lead to a breach of a recognised environmental threshold, policy, legislation or standard).

Where relevant and possible, effects have also been assigned a geographic scale; for example, local, borough or regional.

Effects have been predicted as either 'significant' or 'not significant'. Significant effects are considered material to the planning decision process. Based on the above, residual effects of moderate and major scale may be considered significant.

In addition, ES Addendum Volumes 2 and 3 provide qualitative comparison text (with the exception of daylight, sunlight and overshadowing where updated quantitative modelling has been undertaken) for the Amended Proposed Development vs the Consented Development as requested by WCC.


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3. CONSULTATION AND SCOPING

3.1 EIA Scoping and Consultation

Scoping is the term used in the EIA Regulations whereby an Applicant can request a formal opinion from the local planning authority on the content of the ES and the extent of the information to be considered in the assessments. The purpose of scoping is to focus the EIA on the environmental issues and potential impacts which need the most thorough attention, to identify those which are unlikely to need detailed study and to provide a means to discuss methods of impact assessment so as to reach agreement on the most appropriate response.

An EIA Scoping Report was submitted to WCC on 6 June 2014 in support of a formal request for an EIA Scoping Opinion under Regulation 13 of the 2011 EIA Regulations. The EIA Scoping Report is provided in Technical Appendix 2.1, 2014 ES Volume 4C which set out a description of the Consented Development, the potential key environmental impacts and likely effects to be considered as part of the 2014 EIA, as well as the proposed scope of and methodology to be followed within each technical assessment of the 2014 ES.

WCC’s formal EIA Scoping Opinion was issued on 10 July 2014 and confirmed the key issues which needed to be assessed in the 2014 EIA as:

• Socio Economics;

• Heritage, Townscape and Visual;

• Archaeology;

• Transport and Access;

• Air Quality;

• Noise and Vibration;

• Ground Conditions and Contamination;

• Water Resources, Hydrology and Flood Risk;

• Ecology;

• Daylight, Sunlight and Overshadowing; and

• Wind.

The need for an updated, formal EIA Scoping Process for this S73 Application was not considered necessary due to the minor material nature of the proposed amendments and the similar nature of the Amended Proposed Development to the Consented Development. Furthermore, there have been no material changes to policy, assessment guidance or sensitive receptors. Accordingly, there would be no change to the EIA scope previously agreed in the 2014 EIA Scoping Process and different consultation comments are unlikely to have been raised by new formal consultations. However, it is noted that the format and scope of the ES Addendum was agreed in consultations with WCC.

Wide ranging pre-application consultation was undertaken in 2014 with the following stakeholders over the course of several months to review the emerging development proposals:

• WCC;

• GLA;

• TfL;

• Amenity Societies; and

• Local Groups and Residents.


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Proposals were initially presented and discussed with WCC from the end of 2013 through 2014, to discuss a range of design issues. The design of the Consented Development responded to the comments received during the consultation process, particularly in relation to building scale and heights, management of construction processes, and public access to the listed Riding School.

Extensive consultation with the local community was also undertaken as part of the pre-application process. Public exhibitions were held in June 2014, with a follow-up exhibition and presentation held between July 2014 which provided a platform to share information on the emerging scheme proposals and to solicit response and feedback from interested and affected parties, the local community, local businesses and community representatives.

In respect of the Amended Proposed Development, the following WCC, stakeholder and community consultations have been undertaken in 2016:

• Multiple pre-application meetings with WCC;

• Multiple individual briefing meetings with identified key amenity groups, ward councillors and representatives of the resident’s association representing the nearby St John’s Wood community;

• Three days of door-to-door survey work with residents in properties immediately adjacent to the Main Site;

• A two day public exhibition for the wider community, including adjoining neighbouring properties and residents of the wider St John’s Wood Community; and

• Follow-up meetings were arranged and copies of exhibition boards were posted or emailed to those unable to attend the exhibition.


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4. ALTERNATIVES AND DESIGN EVOLUTION

In accordance with the EIA Regulations and Best Practice Guidance, the 2014 ES and 2016 ES Addendum include a discussion of the alternative development options and various constraints and opportunities which influenced the ultimate design of the Consented Development and the Amended Proposed Development now under consideration.

The 2014 ES and 2016 ES Addendum has considered the ‘Do Nothing’ alternative, as well as alternative sites, land uses, layouts and façade treatments. The 'Do Nothing' scenario is a hypothetical alternative conventionally considered, albeit briefly, in EIA as a basis for comparing the development proposal under consideration.

The Amended Proposed Development is as a result of proposed amendments to the Consented Development and therefore it is appropriate to provide a brief summary of the alternatives considered for the Consented Development as below.

4.1 Main Site

The aim of the development proposals for the Main Site was to achieve the following vision: “To create… a superlative residential destination orientated to a family lifestyle rooted in the unique environment of St John’s Wood”.

The Consented Development at the Main Site was required to provide a high quality residential scheme in response to increasing local demand for residential development within the CoW and in accordance with local and regional policy aspirations

The principle of redevelopment on the Main Site has been established by virtue of local policy and in particular by the Main Site being identified as a Strategic Housing Site within WCC policy. Furthermore, the Main Site previously benefitted from planning permissions granted in 2011 (08/10114/FULL) for a residential led development, together with Listed Building Consent (08/10115/LBC) and Conservation Area Consent (08/10116/CAC). However these permissions were never implemented and expired in May 2016.

4.1.1 Pre-2015 Consent Alternative Sites and Land Uses

In regard to the Main Site, no alternative sites were considered by the Applicant for the following reasons:

• The Main Site is owned by the Applicant as opposed to alternative sites which are the property of a third party;

• The Main Site is specifically identified in WCC’s City Plan as a strategic housing site which would contribute to the meeting WCC’s housing needs;

• The Applicant is seeking to optimise Main Site's potential in line with the NPPF; and

• The Main Site would provide a key development opportunity to contribute to the regeneration of an underutilised Site, and to provide greater and more varied housing, retail and ancillary leisure opportunities.

The proposed land uses were informed by prevailing planning policy and were therefore substantially in accordance the City Plan, in which WCC identified the preferred uses for the Main Site for ‘Residential with Community Uses’.

4.1.2 Pre-2015 Consent Alternative Layout and Built Form

An extensive selection of alternative site layout; built form and massing; façade and balcony options were considered throughout the design of evolution of the Consented Development at the


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Main Site. The alternatives were explored in the context of the Main Site’s environmental constraints and opportunities, as well as in consultation with WCC, GLA and the local community.

The iterative nature of the EIA assisted in adoption of key considerations to minimise impacts on the local community and wider context.

Following a review of the 2011 Consent, it was decided to pursue a revised masterplan for the Main Site, though the Consented Scheme established a number of key attributes that have been considered as part of the design evolution and site layout for the Consented Development at the Main Site as follows:

• Building heights were established along Ordnance Hill;

• Buildings were set out around an internal access road;

• A major open space was located on Queen’s Terrace;

• The height of the scheme rose towards Queen’s Terrace; and

• The listed Riding School was used as a swimming pool.

The key strategy for the revised Masterplan at the Main Site was to create a new setting for the listed Riding School. A selection of the layout alternatives considered for the Main Site is shown in Figure 4.

Figure 4: Pre-2015 Consent Site Layout Options for the Main Site

Due to the Main Site’s location predominantly within the St John’s Wood Conservation Area, the selection of façade treatments was informed by an analysis of the surrounding properties. Various locations for balconies were considered, to respond to internal layouts, views out and sunlight and daylight. The preferred locations for balconies were next to living rooms and kitchens, and master bedrooms on larger apartments. They were also located to provide views out over the Garden and Linear Square, or where they would enjoy good access to sunlight.


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4.2 Pre-2015 Consent Preferred Option

The main characteristics of the preferred option of the Consented Development for the Main Site comprised: improved permeability and accessibility; integration of the Main Site with the wider urban context; improved landscaping and public realm; high quality architectural, amenity and landscape design; and appropriate building height and innovative massing.

The preferred option also responded to comments received during the consultation process, particularly in relation the form of the new mansard roof along Queen’s Terrace, and daylight/sunlight impacts to existing properties surrounding the Main Site.

4.3 Post-2015 Alternatives and Design Evolution

Following the grant of the 2015 full planning and listed building permission for the Main Site, the normal period of design refinement and technical development was undertaken. This resulted in the development of a series of refinements to the design of the Consented Development.

In respect of design options various building typologies, façade and landscape alternatives were explored. Consultations were undertaken with WCC and the resulting preferred option has been taken forward for purposes of the 2016 S73 Application.

More detailed information on ground conditions at the Main Site has informed the basement construction options considered. The information indicated that the soil on-site is less compressed when compared to the average across Central London, mainly due to the minimal development which has previously taken place on the Main site. The result of which is increased soil movement findings, with further modelling predicting a higher than normal ground movement.

In respect of Blocks 1 - 6, an alternative layout was considered for Block 4 which proposed an apartment typology to replace the six detached houses typology and a three houses typology to replace the four terrace houses in Block 4.

Through discussion with WCC a number of design changes were made which included a reduction in the footprint of the amended blocks from the southern boundary, widening the Block 4 apartment block and amending the design to be more in keeping with the design of the Consented Development and aligning the materials of Block 3 to be the same as the Consented Development, a mixture of brick and stone.

In respect of Blocks 1 - 6, a number of alternative facade treatment options were considered, how-ever following consultation these were changed in order to better align with that of the Consented Development.

In respect of the basement construction, the following options were considered:

• Blue sky construction: This comprises the insertion of perimeter piles followed by an open excavation, with the perimeter piles supported by soil bunds;

• Full top-down construction: This comprises the installation of concrete slabs and mechanical extraction of the soil material underneath; and

• Hybrid construction: This comprises a combination of the top-down and blue sky construction methods in which concrete slabs are installed on the ground floor and followed by excavation underneath (top down). Steel work is installed which spans between the top down slab and the perimeter piles, acting as braces, allowing excavation from the ground, whilst minimising movement along the perimeter.

The Hybrid construction method was selected as the preferred option for the Amended Proposed Development.


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4.4 Do Nothing Scenario

In the event that the Amended Proposed Development do not proceed, the ‘do nothing scenario’ would comprise the implementation of the 2015 Consented Development.

4.5 Summary

The preferred option for the Consented Development responded to the existing conditions and environmental constraints, delivering a number of environmental advantages, as well as responding to the aspirations of local and regional policy.

The Amended Proposed Development now under consideration, represents an extension of the pre-2015 Consent design evolution process and builds upon the Consented Development. Due to the nature of the proposed amendments, no divergent site layout and built form alternatives were considered; however, the draft proposals were subject to extensive discussions with WCC in seeking the most appropriate design solution.


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5. DESCRIPTION OF PROPOSED DEVELOPMENT

The description of the Amended Proposed Development for the Main Site on the 2016 S73 Application form is:

“Variation of Condition 1 of planning permission dated 2 April 2015 (14/08070/FULL) for demolition of existing Barracks buildings (except for the listed Riding School) and redevelopment for residential use (Class C3) to provide a total of 163 units including 59 affordable units. Use of the listed Riding School as private ancillary leisure facility with internal and external alterations. Provision of Class A1/A3 retail units and Class D1 at ground level at 1 - 7 Queen's Terrace, redevelopment behind the retained front facade and the erection of a mansard roof extension, creation of landscaped areas and reconfigured vehicular and pedestrian access together with associated works including the provision of parking, circulation space, servicing and plant areas. (Application is accompanied by an Environmental Impact Assessment (EIA)) 2.Use of the listed Riding School as a private ancillary leisure facility, associated internal and external alterations, new side extension and the excavation of a lower ground floor beneath the Riding School, namely to allow changes to list of approved plans to allow increase in residential units from 163 units to 171 units with associated change in unit mix, amend Block 4 from houses to apartment building (retention of three villas on Avenue), reduce basement excavation, refinement to façade treatments across all blocks with changes to massing of Blocks 7 & 8, update to residential layout and landscape masterplan and associated works. (Application under S.73) (Application is accompanied by an Environmental Impact Assessment (EIA))”

The description of the Amended Proposed Development on the S19 Listed Building Application form is:

“Use of the listed Riding School as a private ancillary leisure facility and associated internal and external alterations.”

In summary the Amended Proposed Development at the Main Site would comprise the following key elements:

• Demolition of all of the existing buildings within the Main Site with the exception of the listed Riding School and south-western façade of 1-7 Queen’s Terrace;

• Erection of ten blocks which vary in height from three storeys to seven storeys and re-use of listed Riding School to provide 171 residential units (including 59 affordable units), private ancillary leisure use (3,600 m2 GEA); community use (100 m2); and retail use (500 m2 GEA);

• Provision of 203 car parking spaces within a site wide, three level basement; and

• Landscaping and access arrangements.

5.1 Land Uses and Layout

A summary of the floorspace for the Amended Proposed Development at the Main Site is presented in Table 1.

Table 1: Main Site – Amended Proposed Development Schedule of Floorspace

Land Use Type and Use Class Number of Units GEA (m2)

Residential (C3) 171 57,900

Ancillary Leisure Facility - 3,600

Retail (A1/A3) - 500

Community (D1) 100


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Table 1: Main Site – Amended Proposed Development Schedule of Floorspace

Land Use Type and Use Class Number of Units GEA (m2)

Ancillary Space Below Ground (plant, storage, car parking and refuse)

8,800

Total 70,900

The design and layout of the Amended Proposed Development at the Main Site has developed around the creation of a Garden Square at the centre of the Main Site and augmented by a number of secondary open spaces to the north, east and south.

Edges and spaces are framed by ten residential blocks to create four distinct areas, as shown in Figure 5 and listed below:

• Listed Riding School;

• Linear Square;

• Ordnance Hill; and

• Queen’s Terrace.

Figure 5: Main Site Amended Proposed Development Layout

The three level basement would accommodate residential car and bicycle parking spaces, water storage tanks, servicing / plant space, ancillary leisure uses and store rooms.

Lower Ground level predominantly comprise residential car parking spaces and ancillary leisure uses (Spa and Health Club) below the listed Riding School. This level would also provide access routes for services and deliveries, as well as plant and tank facilities at the north-eastern corner of the Main Site.

The majority of the proposed car parking spaces (including residents, visitors and services) would be provided within the Lower Ground 1 level, together with the majority of secure residential cycle


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storage to be accessed by a dedicated cycle lift located at the rear of Block 5 to the north of the Main Site, as well as an automated car stacking system for the affordable housing units in Blocks 9 and 10.

In addition, the general refuse store and the majority of the plant (including the Combined Heat and Power (CHP) plant, boilers and thermal stores, chilled water plant, fire sprinkler tank and ventilation plant) would be located at this level.

Lower Ground 2 level would extend only below the villas at Block 4 and would be used for residential use.

The proposed non-residential uses at the Main Site would comprise ancillary leisure facilities, and A1/A3 retail spaces, as well as an element of D1 use on Queens Terrace. The following ancillary leisure uses would be located within the listed Riding School and comprise:

• spa facilities and a health club at lower ground floor level;

• residents’ lobby at ground floor level, which would serve as the main reception point for visitors, providing a concierge desk with associated storage and back-of house space, and a fixed bar; and

• residents’ club lounge and meeting space at mezzanine level.

The A1 / A3 retail units would be located at the Ground level of Block 9, where the existing units along 1-7 Queen’s Terrace are currently located. A D1 use would also be provided on Queens Terrace. The proposed retail units could include a range of uses such as a post office, hairdressers, coffee shops and restaurants. The D1 use could include a dentist or doctor’s surgery.

A total of 171 residential units would be provided within ten blocks comprising a series of apartments (private and affordable), villas and townhouses as follows:

• Blocks 1-3 and 5-6: private apartments;

• Block 4: villas and apartments;

• Block 7 and 8: townhouses; and

• Blocks 9 and 10: affordable (intermediate) apartments.

The unit and tenure mix of the Amended Proposed Development at the Main Site is set out in Table 2:

Table 2: Main Site Amended Proposed Development Residential Unit and Tenure Mix

Units Tenure

Market Intermediate

Studio 5 20

1 Bed 2 23

2 Bed 22 16

3 Bed (including duplex) 27 0

4 Bed (including duplex) 37 0

5 Bed 4 0

6 Bed 1 0

Townhouse (4 Bed) 6 0

Junior Villa (5 Bed) 5 0

Villa (6 Bed) 3 0

Total 112 59


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A selection of representative floorplans is provided in Figures 8 – 13 and show the distribution of land uses across the Main Site. At roof level, servicing plant, PV panels and green roofs would be delivered.

5.2 Building Heights and Massing

The height, scale and massing of the Amended Proposed Development at the Main Site have been designed to respond to the massing of the surrounding area. As such, the ten Blocks vary in height from three storeys above ground (i.e. the townhouses at Block 8 along Ordnance Hill at 59.95 mAOD) to seven storeys (i.e. the apartments at Block 10 along Queen’s Terrace at 74.201 mAOD).

The basement would be at maximum, three levels deep with the basement finished floor levels between 37.350 – 44.960 mAOD.

5.3 Building Appearance

The material palette and façade detailing of the proposed blocks have been designed to respond to the Main Site’s surrounding context. As such the façade would predominantly comprise the following: brick, stone, anodised metal (aluminium) and glazing.

5.4 Access, Car Parking and Cycle Arrangements

The Amended Proposed Development provides cycle and pedestrian connections to the immediate and wider surroundings, to enhance the Main Site’s permeability and accessibility. A public pedestrian route would be provided along a Pedestrian Access Way across the northern section of the Site, past the listed Riding School.

Three vehicular accesses to the Main Site would be provided:

• The northern vehicular access from Ordnance Hill (located between Blocks 5 and 7) would provide an entrance to the main underground car park, as well as to the drop-off area located within the Riding School Square and to the private Controlled Parking Zone (CPZ) parking;

• The southern vehicular access from Ordnance Hill (located between Blocks 7 and 8) would provide a one-way circulating road for drop-offs (at the Linear Square), as well as access to private CPZ parking; and

• The northern vehicular access from Queen’s Terrace (located between Blocks 9 and 10) would provide access to the affordable residential car park via an automated car lift.

Car parking would be provided for residents, visitors, management and servicing, distributed across the Main Site over three levels: Ground level, Lower Ground level and Lower Ground 1 level including an automated car stacking system for the affordable housing units in Blocks 9 and 10. A summary of the car parking provision is set out in Table 3.

Table 3: Main Site Amended Proposed Development Car Parking Provision

Use Number of Spaces

Market Resident 156

Affordable Residential 20

Visitor 18

Management 4

Servicing 5

Total 203

A total of 416 cycle spaces would be provided on the Main Site; 329 cycle parking spaces would be provided for the residential units on-site, within the Lower Ground 1 level underground car park,


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shared between communal cycle racks and garage spaces. A total of 75 cycle parking spaces would be provided for the affordable units in a communal storage facility at Ground level near the lift and stairs in Blocks 9 and 10. Four additional cycle parking spaces would be provided at Ground level accessible by all visitors, in line with the London Plan requirement for one visitor space per 40 residential units.

With respect to the cycle parking spaces for the proposed retail units at Block 9, six spaces (in the form of three Sheffield stands) are already provided for the existing retail units on the corner of Queen’s Grove and Queen’s Terrace.

5.5 Servicing and Waste Management

All blocks would be serviced from street level, with access from either the existing highways or from within the Main Site. A further drop-off area at Ground level for larger vehicles would be provided via the southern access point off Ordnance Hill. This drop-off area would be located in the area fronting the villas to the south-east of the Main Site.

A site management team would operate the Main Site, and would be located in the listed Riding School and offices at the Lower Ground level. Furthermore, a security room would be located at Lower Ground level, close to the listed Riding School and ancillary leisure areas.

Waste arising from the residential and commercial elements would be stored within dedicated waste stores, before being transferred to bin stores located in general refuse storage area on the Lower Ground 1 Level, and transferred to a store at the base of Block 10, where waste would be collected by WCC. General garden waste would be disposed of by gardening contractors, whilst garden waste from private gardens would be disposed as organic waste.

An Operational Management Plan, and a Delivery and Servicing Management Plan would be prepared and implemented at the Main Site to ensure that effective day-to-day operation of the Amended Proposed Development.


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Figure 6: Amended Proposed Development Main Site - Lower Ground 1 Level General Arrangement


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Figure 7: Amended Proposed Development Main Site - Lower Ground Level General Arrangement


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Figure 8: Amended Proposed Development Main Site - Ground Level General Arrangement


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Figure 9: Amended Proposed Development Main Site – First Floor Level General Arrangement


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Figure 10: Amended Proposed Development Main Site – Fourth Floor Level General Arrangement


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Figure 11: Amended Proposed Development Main Site – Sixth Floor Level General Arrangement


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5.6 Landscaping and Public Realm

Particular emphasis has been placed on the delivery of high quality landscape and public realm within the Amended Proposed Development at the Main Site, shown in Figure 12.

Figure 12: Amended Proposed Development Landscape Masterplan

The principal landscaped spaces within the Amended Proposed Development at the Main Site would be as follows:

• The Garden: This space would be located at the centre of the Main Site, to the south of the listed Riding School. It would provide the key setting for the listed Riding School and newly introduced blocks. In addition it would provide a private communal space for residents;

• The Square: This space, located to the north-east of the listed Riding School will act as the principle hub for residents of the Main Site. The landscape will emphasise the significance of the listed Riding School whilst grounding it within its new setting as part of the Amended Proposed Development;

• Pedestrian Access Way: This east-west aligned publicly accessible space would be located along the northern extent of the Main Site, connecting Ordnance Hill and Queen’s Terrace. The route would connect the two sides of the Amended Proposed Development, providing entrances to the Garden Square and the listed Riding School for on-site residents;

• Ordnance Hill Landscape: This area, located along the north-eastern boundary of the Main Site, would comprise the front gardens of the townhouses and would be defined by low walls and piers along the edge of the street, with planting comprising hedges, features trees and shrubs set behind the walls;

• The Avenue: The Avenue layout would act as the primary arrival space for Blocks 3, 4 and 6. It would be comprised of a series of piazza spaces located at the main core entrances to the apartment buildings, providing focal points and high quality landscaping; and

• Sanctuary Garden: This space would be located to the north of the listed Riding School and would comprise a small private garden that leads out from the listed Riding School.


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Dedicated children and young person’s playspace would be provided within the Garden Square, comprising:

• Doorstep playable space – a contemporary maze created by low mounded domes of beech around a feature climbing tree, located on the south-western extent of the Square;

• Multi-functional play space – a large open lawn at the centre of the Square to allow for informal play and family activities; and

• Incidental play space – informal path and planting at the north-eastern extent of the Square.

In addition, there is an aspiration by the Applicant to provide public realm enhancements along Queen’s Terrace to increase permeability through the area, with shared entrances accessible through garden spaces. Such public realm enhancements would be the subject of a separate planning application.

The existing Main Site has been defined as land of low ecological value; it is anticipated that the proposed landscaping plan will improve the biodiversity at the Main Site.

5.7 Resource Use, Emissions, Residues and Sustainability

A Sustainability and Energy Statement was prepared for the Consented Development at the Main Site in line with best practice guidance to reduce the energy consumption and CO2 emissions. The proposed amendments do not alter the Sustainability and Energy Strategy for the Amended Proposed Development and therefore this strategy for the Consented Development remains valid.

The Statement includes an energy strategy for the Consented Development which was developed in line with the Energy Hierarchy of ‘Be Lean’, ‘Be Clean’, and ‘Be Green’ to reduce energy use within the development. As such, passive design, energy efficient equipment, and low and zero carbon (LZC) technologies would be incorporated into the Amended Proposed Development at the Main Site. The overall predicted reduction in CO2 emissions against a Building Regulations 2013 Part L compliant scheme would be a minimum of 35 % against Building regulations Part L 2013 which represents an annual saving of approximately 355 tonnes of CO2,

Whilst it is noted that the CfSH has been abolished, the Applicant’s own sustainability aspirations reflect the CfSH targets. The Amended Proposed Development aims to achieve a minimum Level 4 rating under the CfSH for all residential units (in addition to eight units at the Main Site targeting a higher Level 5 rating) as more fully set out in the Sustainability and Energy Statement prepared to accompany the 2014 Application. Accordingly, water consumption levels would be limited to 105 and 80 litres/person/day, respectively. Water minimisation measures would comprise: the use of low water fixtures and fittings; water metering; rainwater harvesting; grey water harvesting; and a leak detection system.

Surface water runoff from the Amended Proposed Development would be attenuated through the provisions of green roofs, public open space and rainwater harvesting tanks.

The Amended Proposed Development at the Main Site would generate approximately 268 m3 of waste per week. Adequate dedicated storage space for recyclables and non-recyclables would be provided.

5.8 Demolition and Construction Environmental Management

The Amended Proposed Development’s indicative development programme is based on the assumption that development works would commence during Q2 of 2017 For the purpose of the EIA, the development works are anticipated to be undertaken over a 65 month period, with completion targeted for 2022.

Demolition and construction works have the potential to cause temporary adverse environmental impacts from noise, emissions to air, traffic movements, waste generation and accidental spills


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that could affect surface water runoff, soils and ground water. Likewise, the works have the potential to create construction employment, make contributions to the local economy, assist in understanding archaeological resources at the Main Site and remediate ground contamination.

The ES has established the potential broad environmental impacts associated with the works and a framework has been developed for the management of these impacts to ensure that no significant effects arise.

The framework would form the basis for a Demolition Method Statement (DMS); and a Construction Environmental Management Plan (CEMP) to be implemented during demolition and construction works. It is noted that the implementation of the CEMP was secured by means of a planning condition for the Consented Development. Accordingly, a CEMP accompanies the 2016 S73 Application and has been prepared in accordance with standard best practice and regulatory requirements, as well as WCC's Code of Construction Practice (CoCP). The CEMP defines relevant policies, legislative requirements, thresholds/limits, procedures, roles and responsibilities for the implementation of environmental and management controls throughout the duration of the works. The CEMP for the Main Site will be discussed and agreed with WCC in advance of works commencing on-site.

In addition, as required by WCC’s CoCP and the Construction (Design and Management) Regulations 2015, a Site Environment Management Plan (SEMP) would also be submitted prior to a start on site. This would also be developed with input from the Main Contractor. The SEMP would also incorporate a Construction Traffic Management Plan (CTMP), Construction Logistics Plan (CLP), as well as a Construction Site Waste Management Plan (CSWMP).


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6. SUMMARY OF POTENTIAL IMPACTS AND LIKELY EF-FECTS

The ES Addendum presents an up-to-date assessment of the Amended Proposed Development. It does so by reference to the 2014 ES. The technical assessments therefore include consideration of whether any new or materially different significant effects will arise as a result of the Amended Proposed Development relative to the corresponding effects identified in the 2014 ES for the 2015 Consented Development.

Since the preparation of the 2014 ES and the 2015 Consent, there has been no material change to the baseline information presented in the 2014 ES; and the assessments have been undertaken on this basis. Wherever this is not the case, it is specifically highlighted in the summaries provided in this section.

This section summarises the technical assessments that have been undertaken as part of the EIA in 2014 and 2016 and their key findings. The assessments have considered and, where relevant, follow best practice methodologies defined in relevant guidance; and where guidance is not defined, prudent professional judgement has been applied. Where there have been changes in assessment methodologies since 2014, these have been highlighted.

6.1 Socio Economics

This assessment considers the potential direct socio-economic impacts related to employment levels created by the Amended Proposed Development at the Main Site, the potential indirect impacts to the local economy and the potential impacts associated with the new residential population on-site, including any impact on local social and community infrastructure.

6.1.1 Baseline

The Main Site is located within the Abbey Road Ward. According to the 2011 Census the population for the ward was 11,250 residents, which has increased from 8,670 in 2001. These residents accounted for 5 % of the population of Westminster in 2001 and 2011.

There are four primary schools (i.e. ages four to ten or eleven years), and an infant (i.e. ages four to seven years) and a junior school (i.e. ages seven or eight to ten or eleven years) within 1 km of the Main Site. Within these schools there are 96 surplus places.

The secondary school closest (100 m) to the north-west of Main Site is the Quintin Kynaston School located within the CoW. Currently the secondary schools within the CoW and the London Borough of Camden (LBC) (considered due to the Main Site’s close proximity to the borough boundary) have a surplus capacity of 1,047 places.

The nearest GP surgery to the Main Site is St John’s Wood Medical Practice, 300 m to the south-west in WCC. There are five GP surgeries within 1 km of the Main Site. The surgeries have, on average, a number of patients per GP of 1,600; the recommended average list size is 1,800 patients per GP according to local guidance.

The largest open spaces within 800 m of the Main Site are Primrose Hill, Regent’s Park and St. John’s Wood Church Gardens. The nearest public sports facility is the Swiss Cottage Leisure Centre, which is located within 700 m to the north-east of the Site in LBC, and has a swimming pool, fitness centre, sports call, climbing wall, squash courts, soft play zone and an outdoor seven a side pitch.


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6.1.2 Demolition and Construction

During the demolition and construction stage, the following potential impacts would arise:

• Displacement/loss of employment on-site;

• Displacement/ loss of residential units on-site; and

• Creation of direct construction employment.

The construction of the Amended Proposed Development at the Main Site is estimated to generate 560 full time construction jobs. Construction employment is relatively mobile and therefore it is not particularly relevant to assess the potential impacts at the local level. However, when assessed at the regional level, the likely direct and indirect effects of the construction works on employment would be Negligible.

6.1.3 Completed Development

The Amended Proposed Development at the Main Site is expected to generate potential direct and indirect socio economic impacts. These include;

• Delivery of new housing;

• Increased local residential population;

• Creation of new employment on-site;

• Potential increased demand for education facilities;

• Potential increased demand for healthcare facilities;

• Potential increased demand for playspace and open space;

• Increased spending by new residents and employees; and

• Potential impacts on crime and security on-site.

The Main Site mostly comprises the now vacant St John’s Wood Royal Horse Artillery Barracks, which moved off the Main Site in 2012. There are three retail units within the redline boundary along Queen’s Terrace of which one is occupied with four existing employees assumed. The Amended Proposed Development at the Main Site includes retail and ancillary leisure floorspace which would generate employment during the operational phase. It is estimated that the Amended Proposed Development at the Main Site would result in a net increase of 61 jobs on-site. Therefore, the direct effect of the Amended Proposed Development at the Main Site in terms of employment would be permanent Moderate Beneficial at the local level, Minor Beneficial at borough level, and Negligible at the regional level.

The Amended Proposed Development at the Main Site would make a positive contribution towards WCC’s housing targets by delivering 171 new residential units. Therefore, the direct effect of the Amended Proposed Development at the Main Site in terms of its contribution to meeting housing targets would be permanent Moderate Beneficial at the local and borough level, and Negligible at the regional level.

The population of the Amended Proposed Development at the Main Site would likely be around 300 residents of which it is estimated there would be 11 primary school aged children and six secondary school aged children. There is sufficient capacity available locally within existing education and healthcare facilities to meet any potential increase in demand arising from the Amended Proposed Development. Therefore, the likely direct effect of the Amended Proposed Development on demand for education and healthcare facilities would be Negligible at all spatial levels.

The Amended Proposed Development would result in demand for 420 m2 of playable space. This will be met through provision on-site within the open spaces, playspaces and private gardens which will be delivered. On-site provision will be made for 680 m2 of dedicated playspace.


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Therefore, the likely direct effect of the Amended Proposed Development at the Main Site would be permanent Moderate Beneficial at site level due to the provision of open space for future residents and Negligible at all spatial levels.

6.1.4 Summary

The conclusions of the 2016 EIA in so far as the likely significant socio-economic effects of the Amended Proposed Development, remain unchanged from that previously concluded in the 2014 ES for the Consented Proposed Development.

6.2 Archaeology

This assessment considers the potential impacts and likely effects on the historic environment (buried heritage assets/archaeology) of the Amended Proposed Development at the Main Site.

6.2.1 Baseline

No assets of Very High importance (‘significance’), that would warrant preservation in their existing position and state, have been identified within the Main Site.

The Main Site is considered to have:

• a high potential for footings of the early-19th century St John’s Wood Barracks buildings;

• a high potential for footings of the late 19th to early 20th century barracks buildings; and

• a high potential for footings of mid-19th century terrace houses.


During the demolition and construction works, there would be potential for the works to directly impact any surviving buried heritage remains on the Main Site. Since the 2014 ES, the understanding of the archaeological potential and significance of the Main Site has increased, with two phases of archaeological excavations undertaken. These identified truncated remains of late 19th century building footings as shown on historic Ordnance Survey mapping, but also identified a high level of disturbance across the Main Site.

As a result of this disturbance, and the severely fragmented condition of the remains found, the excavation and evaluation of the Main Site was concluded early, and the significance of potential remains on the Main Site is now assessed as Very Low. Consultation with GLAAS confirmed that no further work in mitigation was necessary. Therefore, the residual effects are considered to be Negligible.


An assessment of impacts during the Completed Development stage has been scoped out on the basis that once the Amended Proposed Development at the Main Site has been completed; no further ground disturbance would occur and consequently there would be no impact upon buried heritage assets during this stage.

6.2.4 Summary

The conclusions of the 2016 EIA in so far as the likely significant archaeological effects of the Amended Proposed Development, remain unchanged from that previously concluded in the 2014 ES for the Consented Proposed Development.

6.3 Transport and Access

This assessment considers the potential transport and accessibility impacts of the Amended Proposed Development on various means of transport at the Main Site and within the surrounding


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area, as well as the predicted associated effects on sensitive receptors both during construction and with the completed development in place.

6.3.1 Baseline

The Main Site is well served by a range of transport modes (buses, underground and overground rail) and benefits from ‘moderate to good’ existing public transport accessibility as defined by TfL’s Public Transport Accessibility Level methodology.

The Main Site is situated in an area well suited for pedestrians with signal controlled pedestrian crossing facilities provided at all the nearby main junctions. Additionally, all streets surrounding the Main Site are well lit and have good quality footways. There are a number of cycle routes in close proximity to the Main Site.

The Main Site is surrounded by Queen’s Grove to the north, Ordnance Hill to the East and Queen’s Terrace to the west. The latter connects Queen’s Grove with the A41 Finchley Rd, which is located further to the west of the Site and forms part of the TfL Road Network.

The Applicant’s transport consultants have confirmed that the baseline traffic flows as reported in 2014 remain valid. In addition, there have not been material changes on the local highway network. On this basis, the baseline conditions described in the 2014 ES and the surveys undertaken in 2013 for the 2014 EIA, remain valid.


Transportation and access related impacts that have the potential to arise during the demolition and construction stage would comprise the following:

• temporary increases in Heavy Goods Vehicle (HGV) movements on the highway network in the vicinity of the Main Site;

• introduction of construction workers to the Main Site;

• temporary relocation or removal of parking bays; and

• temporary closure of footways.

The Amended Proposed Development at the Main Site would have a maximum of 116 construction vehicles travelling to and from the Main Site. Traffic routes have been identified that enable safe access to the Main Site, which would require minor temporary modifications to accommodate the size of these vehicles. The Amended Proposed Development’s access routing now allows for the following routes:

• Inbound and outbound via Ordinance Hill during the demolition phase; and

• Inbound via Queens Terrace and outbound via Ordinance Hill during the construction phase.

The volume of construction vehicles predicted, split across the various route proposed and taking into consideration mitigation measures that would be adopted during the course of the development programme, means that the residual effect on surrounding roads would be temporary Moderate Adverse. Due to the temporary nature of these effects, they are not considered to be significant.


The Amended Proposed Development would have the potential for the following broad impacts:

• Increased people trips travelling to and from the Main Site and an associated demand on pedestrian, cycle, public transport facilities and the local road network; and

• New access points into the Amended Proposed Development including a new pedestrian route.


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The public transport assessment has found that the impact of the Amended Proposed Development at the Main Site on the public transport network would be Negligible.

The assessment of the local road network has demonstrated that the additional development traffic would have very little effect on overall operational performance. The Amended Proposed Development at the Main Site is therefore expected to have a Negligible effect on the operation of the A41 corridor and local road network.

The Amended Proposed Development at the Main Site would deliver 203 car parking spaces, 176 of which would be for use by the residents, 18 for visitors and 9 for management/service vehicles. A car club space is also proposed on Queen’s Terrace. This will be available to all residents of the Amended Proposed Development as well as existing residents in the area. The implementation of a parking management strategy proposed together with the on-site parking proposed as part of the design will negate the need for residents or their visitors to park on-street. Therefore, the residual effect on on-street parking would be Negligible.

The Amended Proposed Development at the Main Site would provide on-site cycle parking for residents and visitors in accordance with WCC minimum parking standards. This provision, in combination with the low level of additional demand on the cycle facilities would be Negligible.

The Amended Proposed Development at the Main Site would provide a new pedestrian route through the Main Site, connecting Ordnance Hill with Queen’s Terrace, to provide pedestrian permeability through the Site and increase connectivity between the Amended Proposed Development and surrounding area. This is considered to be a Major Beneficial effect to the area.

6.3.4 Summary

The conclusions of the 2016 EIA in so far as the likely significant transport and access effects of the Amended Proposed Development, remain unchanged from that previously concluded in the 2014 ES for the Consented Proposed Development.

6.4 Air Quality

This assessment predicts and evaluates the potential impacts of the Amended Proposed Development on air quality, arising from the demolition and construction works and upon completion of the Amended Proposed Development, including emissions arising from the proposed Energy Centres and traffic flows at the Main Site.

6.4.1 Baseline

Air quality on the Main Site would be expected to meet all relevant air quality objectives at the external façade locations of the proposed residential units. Whilst historical diffusion tube monitoring indicates a slight exceedance of the annual mean NO2 objective on Queen’s Grove at roadside locations, the nearest proposed residential unit is considered to be set back sufficiently from the roadside to ensure compliance with the objective. More recent updated WCC monitoring data indicate that NO2 concentrations at the Swiss Cottage monitoring site have reported an improvement in air quality with reductions in NO2 concentrations reported from 2010 for both the long term and short term objectives.

A review of adjacent land uses has identified existing residential, schools and hospital receptors immediately adjacent to the Main Site on all sides which are considered sensitive receptors to air quality.

The Applicant’s transport consultants have confirmed that the baseline traffic flows as reported in 2014 remain valid. In addition, there have not been any changes to the sources of air quality emissions affecting the Main Site.


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In the absence of mitigation, there are two potential significant sources of emissions that could affect air quality during demolition and construction works:

• coarse and fine dust from construction activities including excavation, earthmoving, materials storage and movement of construction vehicles; and

• construction plant, both mobile and stationary (e.g. cranes and generators), which emit a mixture of exhaust gases.

The control of dust emissions from a construction site relies upon good site management and mitigation techniques to reduce emissions of dust and limit dispersion. These measures would be detailed within the Main Site’s CEMP/SEMP, to ensure compliance with the CoW CoCP.

Subject to the implementation of suitable mitigation measures, the potential for significant dust effects on air quality to arise during the demolition and construction stage would be at worst, temporary Slight Adverse.

For the Amended Proposed Development the peak demolition and construction traffic flows would remain at 116 peak trips per day as assessed in 2014.


Operational impacts on local air quality will primarily arise from exhaust emissions associated with vehicle movements generated as a result of the Amended Proposed Development. Air emissions can arise from on-site energy generating plant associated with electricity, heating, hot water and cooling systems, with the significance of emissions depending on the choice of plant.

Using the EPUK and IAQM Guidance, the predictive modelling indicates that operational impacts from traffic and Energy Centre emissions associated with the Amended Proposed Development at the Main Site would have a Moderate Adverse effect on annual mean NO2 concentrations at one off-site receptor, Slight Adverse effect at three off-site receptors with a Negligible effect at all other receptors close to the Amended Proposed Development.

A Negligible effect is predicted on PM10 and PM2.5 concentrations.

At on-site receptors, the combined impact of emissions from traffic and the Energy Centre associated with the Amended Proposed Development at the Main Site would result in a Moderate Adverse effect at four on-site receptors on annual mean NO2 concentrations at ground level receptors where there is relevant exposure, Slight Adverse effect at seven on-site receptors and Negligible effects at two on-site receptors.

Negligible effects are predicted on PM10 and PM2.5 concentrations at on-site receptors at the Main Site.

Concentrations have been predicted at the highest elevations within the Amended Proposed Development to demonstrate that the stacks for the boilers and Combined Heat and Power (CHP) that are located within the Energy Centre have been sized appropriately to allow adequate dispersion of polluting gases. This has shown that the residual effect of the Amended Proposed Development is considered to be Negligible at elevated receptors.

In line with the Mayor’s Sustainable Design and Construction SPG, an assessment has been undertaken to demonstrate whether the Amended Proposed Development at the Main Site would be classed as ‘Air Quality Neutral’. The assessment concludes that the predicted total emissions arising from the Amended Proposed Development at the Main Site are within the emissions benchmark for transport and building services. It can therefore be concluded that the Amended Proposed Development at the Main Site can be considered to be ‘Air Quality Neutral’.


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6.4.4 Summary

The residual effects identified in the 2014 ES remain valid and unchanged for the majority of sensitive receptors as a result of the Amended Proposed Development. Where there has been a change in residual effects this is due to the amended assessment guidance and not as a result of the Amended Proposed Development now under consideration. None of the effects are considered to be significant.

6.5 Noise and Vibration

This assessment considers the potential noise and vibration impacts of existing conditions on the Amended Proposed Development at the Main Site and the potential impacts generated by the Amended Proposed Development at the Main Site on surrounding residential properties, during both the construction and operation/occupation of the Amended Proposed Development.

6.5.1 Baseline

The existing noise climate at the Main Site is dominated by road traffic, with the highest road traffic noise levels on Ordnance Hill and Finchley Road which experience noise levels above 65 dB.

The existing groundborne noise and vibration conditions at the Main Site are dominated by the train movements along the London Underground Jubilee Line tracks that pass underneath the north-west corner of the Site.

The Applicant’s transport consultants have confirmed that the baseline traffic flows as reported in 2014 remain valid. In addition, there have not been any changes to the noise sources affecting the Main Site. On this basis, the baseline conditions described in the 2014 ES and the noise surveys undertaken in 2013 for the 2014 EIA, remain valid.


Demolition and construction activities have the potential to create noise and vibration upon nearby sensitive receptors, particularly the residential occupants surrounding the Main Site. Noise activities are likely to include demolition, breaking and piling as well as general site activities.

Noise predictions were undertaken to provide an estimate of the noise emissions from the Main Site during the demolition and construction works at the nearest sensitive receptors.

The CEMP/SEMP for the Amended Proposed Development would provide best practicable means and control measures to reduce the potential for significant demolition and construction noise. With the proposed mitigation measures incorporated into the demolition and construction design process, noise levels are predicted to result in temporary Minor Adverse to Moderate Adverse residual effects. The effects would only be temporary and not throughout the full construction period.

Construction works vibration is considered to have temporary Minor Adverse to Moderate Adverse effects during the piling works depending on the techniques adopted.

For other construction activities, the impact is expected to have a Negligible to Minor Adverse effect. In terms of cosmetic damage, construction vibration is expected to have a Negligible effect.

For the Amended Proposed Development the peak demolition and construction traffic flows would remain at 116 peak trips per day as assessed in 2014.

The assessment concludes that demolition and construction traffic flows would have a temporary Negligible to Moderate Adverse effect on road traffic noise. Due to the temporary nature of these effects, they are not considered to be significant.


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Following the incorporation of appropriate façade treatment, as well as specification of a ventilation system and building services plant, the residual effects of the surrounding noise environment upon the residential spaces is considered to be of Negligible significance.

Furthermore, the external noise levels would be suitable for external amenity areas such as gardens, balconies and patios. On this basis, the Amended Proposed Development would have Negligible residual effects.

The residual vibration and groundborne noise effects upon new and existing residents on-site would be Negligible.

The assessment concludes that the Amended Proposed Development at the Main Site would generate additional road traffic which is expected to have a Negligible effect on the surrounding residential receptors.

Building services plant would be designed and installed to have a rating level 5 dB(A) below the background noise level. There are no significant operational vibration sources associated with the completed development. Accordingly, the residual effects associated with noise and vibration from building services plant is considered to be of Minor Adverse significance.

6.5.4 Summary

The residual effects identified in the 2014 ES remain valid and unchanged for the majority of potential impacts as a result of the Amended Proposed Development. Where there has been a change in residual effects at particular receptors during demolition and construction, this is due to the amended access routing, although these effects would be temporary in nature and are not considered significant.

6.6 Ground Conditions and Contamination

This assessment considers the geological and hydrogeological setting of the Main Site, the potential for ground contamination associated with past and current uses, as well as the potential risks arising during redevelopment.

6.6.1 Baseline

The potential for contamination to exist at the Main Site and in the surrounding area is considered to be moderate given the previous use as a Barracks. Since the 2015 Consent, soil sampling has been undertaken within the Sanctuary Garden in May 2015. This identified elevated levels of lead within all three soil samples and marginally elevated levels of arsenic from one location. The concentration of arsenic was not considered to be significant and could be addressed through the proposed remediation for the elevated concentrations of lead.


During demolition and construction works the following potential impacts could arise:

• Asbestos Containing Materials (ACMs) within existing buildings could present a potential health risk to demolition contractors;

• Contaminated dust emissions, ground gases and/or odours generated during earthworks could present a potential health risk to demolition and construction workers, off-site residents, commercial users and other members of the public;

• Direct contact with potentially contaminated soils and groundwater during the redevelopment works which could present a potential health risk to demolition and construction workers;

• Oil and fuel spills which could contaminate soil, groundwater and surface water;


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• Infiltration of polluted runoff or disturbance of ground contamination (known or unexpected) which could affect controlled waters;

• Leaching of contaminants into the drainage network;

• Piling and ground disturbance which could create a pathway for any contaminants at the surface (if present) into the underlying ground and affect controlled waters; and

• Excavation of Made Ground could remove contaminated material within the Made Ground.

In light of the proposed mitigation measures that would be implemented as part of the Amended Proposed Development at the Main Site (site investigation and remediation; piling risk assessment; safe working practices; Asbestos Refurbishment and Demolition; demolition, excavation and piling provisions, etc.), the predicted residual effects on human health and other sensitive receptors would be temporary Negligible Adverse.

The Amended Proposed Development at the Main Site would represent an opportunity to remove or remediate known contaminated soils and potentially unidentified contaminated soils, resulting in Minor Beneficial effects. The potential for contact with contaminated soils would be avoided through the provisions outlined within the Remediation Strategy Addendum for the Sanctuary Garden, submitted to WCC, which would comprise a capping scheme to provide a clean layer of soil between site users and the underlying soil.


In the absence of mitigation, the following potential direct and indirect impacts could occur following the completion of the Amended Proposed Development:

• Future site users and residents may come into contact with residual contaminants in areas of soft landscaping;

• Ground gas emissions could present a potential health risk to future site users, on-site residents and off-site residents at the Main Site;

• Contamination of the drainage system from surface water runoff from hard standing areas and basement car parking areas;

• Piling and foundations could create pathways through which contaminants could continue to migrate;

• Contamination of the drainage system could continue to occur from contaminated groundwater infiltration; and

• Neighbouring land could be affected if contaminant migration pathways are created by the Amended Proposed Development at the Main Site.

Once completed the Amended Proposed Development at the Main Site would not introduce potential contamination sources or create contaminant-pathway-receptor pollution linkages on-site. The Main Site's drainage strategy would ensure that there is no adverse impact to the drainage system and would include the installation of an oil-water interceptor.

Accordingly, the residual effects from the completed development are considered to be Negligible to Minor Beneficial in areas of landscaping where clean topsoil would be imported.

6.6.4 Summary

The conclusions of the 2016 EIA in so far as the likely significant ground conditions effects of the Amended Proposed Development, remain unchanged from that previously concluded in the 2014 ES for the Consented Proposed Development.


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6.7 Water Resources, Hydrology and Flood Risk

This assessment considers the potential impacts of the Amended Proposed Development at the Main Site on surface water quality and hydrology.

6.7.1 Baseline

The closest surface water feature to the Main Site is the Paddington Branch of the Grand Union Canal (GUC), located approximately 700 m to the south-east. The Paddington Branch of the GUC is currently designated as being of Moderate Ecological Quality.

There are no licensed fresh surface water abstractions within the study area.

The Main Site is located in Flood Zone 1 (low probability) representing an annual probability of flooding from rivers or the sea less than 1 in 1,000 (0.1%).


During the demolition and construction works at the Main Site, the following potential impacts could arise:

• Risk of surface water pollution from silt-laden runoff from the construction site and stockpiles;

• Risk of surface water pollution from accidental spills of fuels and chemicals and other wastes during general construction activity;

• Potential impacts from excavated material that is contaminated, mobilisation of contaminants during piling and de-watering of excavations which could affect surface water quality; and

• Increase in water use during demolition and construction activity.

During the Amended Proposed Development’s demolition and construction works at the Main Site, management controls to minimise the risk of accidents, ensure safe handling and storage of potentially hazardous materials and prevent pollution would be implemented as part of a CEMP/SEMP to ensure that residual, temporary drainage and water quality effects are significantly reduced. The mitigation measures to be set out in the CEMP/SEMP would ensure that pollution pathways are not created and residual, temporary effects are significantly reduced. The residual effect of demolition and construction on water resource receptors would be Negligible.

Subject to the implementation of mitigation measures to prevent environmental impacts from water consumption and wastewater flows during the demolition and construction works, effects of the Amended Proposed Development at the Main Site would be temporary Minor Adverse.

The Amended Proposed Development would manage surface water runoff using SuDS measures to ensure runoff rates no greater than 50 % of the existing pre-development rates. This represents a beneficial impact in comparison with the existing drainage situation. Discharges would be to Thames Water sewers, which are low sensitivity and the magnitude of the impact would be small. The residual effect of surface water drainage would be Negligible.


The Completed Development stage at the Main Site would have the potential to give rise to the following impacts:

• Flood risk impacts related to surface water runoff volumes, if unattenuated;

• Impacts on surface water quality from routine operations;

• Increase in potable water demand to supply the new occupants of the Amended Proposed Development including residents with private swimming pools, as well as within the ancillary residential spaces;


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• Increase in water demand associated with the irrigation strategy of soft landscaping areas; and

• Impacts related to the increase in discharge volumes of effluent to foul sewer.

To reduce the risk of surface water contamination by hydrocarbons, once the Amended Proposed Development is complete, oil interceptors would be incorporated as appropriate within the drainage systems of any access roads, car parking and delivery areas. The residual effects on surface water quality would be Negligible.

The Amended Proposed Development would increase the number of occupants using the Main Site, and would therefore increase water demand and foul drainage requirements. It is proposed that these increases would be offset by the adoption of a variety of water-saving measures in order for the Amended Proposed Development to meet sustainability standards including a minimum CfSH Level 4. Although the CfSH scheme has been abolished, the 2016 Amended Proposed Development would deliver the Consented water consumption standards.

The residual effect of the Amended Proposed Development at the Main Site on water supply is considered to be Negligible. Foul discharges would be to Thames Water sewers, which are low sensitivity and the magnitude of the impact would be small. The residual effect of surface water runoff would therefore also be Negligible.

6.7.4 Summary

The conclusions of the 2016 EIA in so far as the likely significant water resources, hydrology and flood risk effects of the Amended Proposed Development, remain unchanged from that previously concluded in the 2014 ES for the Consented Proposed Development.

6.8 Ecology

This assessment considers the potential impacts of the Amended Proposed Development on ecological and nature conservation receptors at the Main Site and within the surrounding area. The Main Site is not subject to any statutory ecological designation. Two Local Nature Reserves and 19 non-statutory designated sites are present within 2 km of the Site.

An Extended Phase I Habitat Survey was undertaken in February 2014; the existing habitats on the Main Site are shown in Figure 13. The survey is considered to remain valid.


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Figure 13: Existing Site Habitats

The Main Site comprises a range of habitats including buildings, hardstanding, bare ground, individual trees, introduced shrub and amenity grassland, which are all common to urban environments and therefore only of site value.

Surveys in 2014 identified a common pipistrelle bat roost within the Officers’ Mess (B1) building, and a low to moderate level of bat activity was recorded. Some of the buildings, trees and introduced shrubs have a potential to support a small number of common nesting and foraging bird species. The Main Site also provides habitat for small numbers of widely occurring invertebrate species.

As a result of works undertaken to discharge pre-commencement planning conditions and enabling works ornamental planting and areas of tall ruderal vegetation (of limited ecological importance) have been cleared, trees at the Sanctuary Gardens have been trimmed, vegetation and trees (with a stem diameter of less than 75 mm) within the Main Site have been removed in consultation with WCC; and bat boxes have been erected on trees within the Sanctuary Garden as part of the bat licence mitigation.


The following direct impacts could arise from the demolition and construction of the Amended Proposed Development at the Main Site:

• Loss and/or disturbance of the existing habitats on-site (including amenity grassland, tall ruderal vegetation, scattered trees and ornamental planting habitats);

• Damage to existing trees to be retained within the development;

• Temporary loss of bat, invertebrate and bird foraging habitat and bat commuting habitat until the new landscape planting has established;


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• Disturbance of fauna (common and widespread species) during demolition and construction works;

• Loss of suitable bird nesting opportunities as a result of removal of vegetation;

• Reduced breeding opportunities for hole nesting bird species such as house sparrow and starling as a result of demolition of the majority of the buildings on the Main Site;

• Temporary habitat creation for black redstart due to a temporary abundance of bare ground and rubble following demolition that is suitable for foraging and breeding individuals. Subsequent construction activities could then lead to the disturbance of any individual or breeding black redstarts which have been introduced; and

• Loss of suitable bat roosting habitat as a result of the demolition of the majority of buildings on the Main Site, including a known roost in the Officers’ Mess (B1).

The demolition and construction works would result in the loss of trees, amenity grassland, and introduced shrub habitat. Though new soft landscaping and tree planting is proposed within the Amended Proposed Development at the Main Site, this would take time to establish. Accordingly, the construction and demolition works are likely to result in a temporary Negative residual impact to habitats and species, significant at the site level only.

Following the implementation of demolition and construction mitigation No Significant residual effects to designated sites or protected species are considered likely.


The Amended Proposed Development would have the potential to give rise to the following impacts at the Completed Development stage:

• Disturbance (such as human activity, lighting and vehicle movement) to St John’s Wood Church Grounds LNR;

• Creation of new habitats on-site; and

• Disturbance to foraging and commuting bats as a result of artificial lighting levels.

Upon completion, the Amended Proposed Development at the Main Site would deliver a range of biodiversity benefits including large areas of landscaping, the introduction of native and beneficial species, and the installation of bird and bat boxes, some of which have already been installed. In the long-term, the creation of habitats within the Amended Proposed Development at the Main Site, once complete, would result in a permanent Positive residual impact to species and habitats.

Furthermore, an appropriate lighting strategy would be developed and implemented to avoid light spill onto potential bat habitats. Therefore, the Amended Proposed Development at the Main Site would have No significant residual impacts in relation to the disturbance of species.

The Amended Proposed Development at the Main Site would have No Significant residual impacts on designated sites.

6.8.3 Summary

The conclusions of the 2016 EIA in so far as the likely significant ecological effects of the Amended Proposed Development, remain unchanged from that previously concluded in the 2014 ES for the Consented Proposed Development.


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6.9 Daylight, Sunlight and Overshadowing

This assessment considers the potential impacts of the Amended Proposed Development at the Main Site on:

• daylight and sunlight availability at adjacent existing residential properties;

• daylight and sunlight availability to residential properties proposed on the Site; and

• amenity areas and public open space proposed within the Main Site and surrounding the Main Site.

6.9.1 Baseline

The Main Site is currently occupied by the former St John’s Wood barracks and has a number of low level buildings on-site. A total of 51 residential properties that surround the Main Site were identified and assessed.


The potential impacts of the demolition of the existing buildings and structures on the Main Site would lead to a temporary improvement in daylight, sunlight and overshadowing to the closest surrounding properties and open spaces.

The construction of the new buildings on the Main Site would have a gradual impact upon the levels of daylight, sunlight and overshadowing as the massing of the proposed buildings increases over time until the Amended Proposed Development is completed. Therefore, the impacts would gradually increase to the same level as the impacts of those discussed in the Completed Development section below.


The following potential impacts could occur following the completion of the Amended Proposed Development at the Main Site:

• a direct impact on daylight to neighbouring residential receptors;

• a direct impact on sunlight availability to neighbouring residential receptors; and

• a direct impact on the degree of overshadowing to private amenity space.

The result of considerable design development with the Architect has ensured that the Amended Proposed Development would be as responsive as possible to the daylight and sunlight availability to neighbouring residential buildings when related to their baseline condition. The residual effects on 93 % of the windows and rooms assessed within the surrounding residential receptors would be Negligible with respect to daylight and (97%) of the windows assessed within the surrounding residential receptors would be Negligible for sunlight. This is considered a high level of compliance for an urban location, with the following exceptions:

• Minor Adverse effects to 40, 42 and 49 Ordnance Hill, 14a Norfolk Way, 14 Norfolk Road, 7 Acacia Place, 8 Acacia Gardens, 25-28 Queen’s Terrace, 2 - 9, Walpole Mews, the rear of 59 Ordnance Hill and Ordinance Hill – Rosetti House in respect of daylight;

• Minor to Moderate Adverse effects to 1b Queen’s Grove and 1 - 24 Barton’s Way in respect of daylight (although additional assessment has shown that it is the design of this building itself with large overhanging balconies which significantly impairs the daylight availability to these properties); and

• Minor Adverse effects to 40 and 42 Ordnance Hill, 15 Norfolk Road, 1 – 9 Walpole Mews and 1b Queen’s Grove in respect of sunlight.


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There are four separate amenity spaces surrounding the Main Site that have been considered for sun hours on ground assessment. All the amenity spaces surrounding the Site would retain 2 hours of direct sunlight to well over 50 % of area and therefore the impact is considered Negligible.

There is only a small increase in overshadowing from the existing position or where there is increase in overshadowing it is only of a small duration affecting a small proportion of the surrounding amenity areas. Therefore the transient overshadowing impact is considered Minor Adverse the surrounding areas of amenity.

6.9.4 Summary

The residual effects identified in the 2014 ES remain valid and unchanged for the majority of potential impacts as a result of the Amended Proposed Development. However, more windows and rooms have been assessed for daylight and sunlight, in comparison to the analysis with the 2014 ES, due to the updated model used for this ES to account for further research undertaken in respect of the surrounding sensitive receptors.

6.10 Wind

This assessment considers the potential impacts of wind upon pedestrian comfort and pedestrian safety (of the general public passing the Main Site, as well as future occupants of the Amended Proposed Development) and strong wind occurrences.

6.10.1 Baseline

The Main Site is currently occupied by existing low-rise buildings, ranging from 1 to 4-storeys with open spaces between the buildings and is sheltered in all directions by surrounding buildings. The local wind environment is unlikely to be affected by significant building-induced accelerations, and the wind conditions around the existing Main Site are therefore classified as suitable for a mix of standing and sitting during the windiest season.


Typically, demolition of existing buildings will create temporary open space within a site which will permit wind to blow into the site. This would typically increase exposure to the wind within the site and it is usually neighbouring, off-site buildings to the north-east which would be most affected because they would be more directly exposed to prevailing south-westerly winds.

After existing buildings on the Main Site are cleared, there would be potential for wind to blow into the open construction site (though it is noted that the south-west façade at 1-7 Queen’s Terrace and the 10 m wall along the south-east boundary will be retained and afford some shelter). However, the potential impact of these demolition works, with the inclusion of additional hoarding through the Main Site, is considered to be Negligible due to the type of activity undertaken during the works. As construction progresses on the Amended Proposed Development at the Main Site, conditions would transition towards those in the Completed Development configuration.


Potential impacts on the local wind microclimate following the introduction of the Amended Pro-posed Development could include:

• a change in the general conditions around the perimeter of the Amended Proposed Development at the Main Site due to the new building form and height; and

• a mismatch between the local wind environment and the desired wind environment at newly created amenity space, building entrances or pedestrian thoroughfares.


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During the windiest season, the predicted wind conditions within and around the Amended Proposed Development at the Main Site would be suitable for standing/entrance use and sitting at the majority of receptors, with leisure walking at corners and access routes from the south-western elevation. All building entrance receptors (and drop-off areas) would experience conditions which are suitable for standing/entrance use or sitting during the windiest season. This represents Negligible, Minor Beneficial and Moderate Beneficial effects for leisure walking, standing and sitting respectively, at all locations.

The amenity spaces in The Square, The Garden Square and The Avenue are sheltered from the wind and expected to have a wind microclimate suitable for sitting in the summer. This implies a Negligible residual effect.

6.10.4 Summary

The conclusions of the 2016 EIA in so far as the likely significant wind effects of the Amended Proposed Development, remain unchanged from that previously concluded in the 2014 ES for the Consented Proposed Development.

6.11 Heritage, Townscape and Visual Assessment

This assessment considers the potential for the Amended Proposed Development at the Main Site to affect the townscape character and visual amenity of the existing Main Site, its existing and future surroundings, as well as the capacity of identified existing and future sensitive receptors to accommodate the likely change.

6.11.1 Baseline

The entire Main Site, with the exception of Jubilee Buildings, forms part of the St John’s Wood Conservation Area (CA). The CA contains dwellings of varied size in an arcadian setting. There are a number of listed buildings surrounding the Main Site. The listed Grade II Riding School building is located adjacent to the north-eastern boundary within the Main Site.

The area considered and which surrounds the Main Site is predominantly residential with a leafy suburban character made up of single detached and semi-detached dwellings, apartments and mansion blocks, wide tree-lined streets, generous gardens, and terraces of three to four storey houses.

This is in contrast to the character of the Main Site which can be described as ‘former military’ which has little merit in either plan form or individual buildings. There is a large open space for parades and exercises and a large interior space provided by the listed Riding School. Other buildings and spaces are pragmatically arranged for purely functional purposes. The Main Site is unused while the buildings are in a well maintained state.


During the demolition and construction process, the most significant impacts would be associated with the presence of tower cranes and construction plant. However, townscape effects during the Demolition and Construction stage are not considered to be significant, owing to their short duration in comparison to the expected lifetime of the Amended Proposed Development and have, therefore, not been considered further in the assessment.


The Amended Proposed Development at the Main Site would have an effect on the CA within which it is located which would be Major Beneficial in character, in terms of adding good quality architecture and providing urban design benefits within the overall form and scale which is consistent with the existing character of the CA.


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Proposed changes to the Riding School (Grade II listed) are dealt with in the S19 Application which accompanies the 2016 S73 Application. The Amended Proposed Development would enhance the setting of the listed Riding School by removing the stables, which currently hide it from more open views, and improved public realm and landscaping. The effect would be Moderate in scale and Beneficial in character.

The changes which would affect the Grade II listed homes in Queen’s Grove are principally at the rear of the terrace. Most would be shielded by the listed Riding School which would remain. There would be a small effect on No.1 Queen’s Grove by virtue of the additional dormered roof to be added to Queen’s Terrace. The effect would be Minor in scale and Beneficial in character.

The listed buildings on Norfolk Road would not be affected by the Amended Proposed Development. The view from the listed buildings towards the Main Site would be enhanced by removing the military complex and replacing it with domestic architecture in harmony with its surroundings. The effect would be Moderate in scale and Beneficial in character.

The Amended Proposed Development includes the demolition of the Officers’ Mess. Although not of sufficient special interest to have been statutorily listed, the Officers’ Mess located on-site is considered by WCC to contribute to the character and appearance of the conservation area. The Amended Proposed Development would also impact 1 – 7 Queen’s Terrace (which is considered to make a positive contribution to the character and appearance of the conservation area) by the refurbishment of the retail units and the additional floor within a new visible roof. The effect on these non-designated heritage assets as a result of the Amended Proposed Development would be Minor in scale and Neutral in character.

In a range of views, the Amended Proposed Development would appear as a visible continuation of urban form of high architectural quality, introducing a mix of styles and use of materials and increasing the sense of place. The residual effect of these views would range from no effect to Major and Beneficial. The Amended Proposed Development would improve the setting of the existing terrace and enhance the character and appearance of Ordnance Hill and the conservation area as a whole. Figures 14 - 16 illustrates this conclusion.

Figure 14: Amended Proposed Development as seen from Queen’s Terrace looking North-west (Summer View)


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Figure 15: Amended Proposed Development as seen from Ordnance Hill at Rossetti Mews looking South-east (Summer View)

Figure 16: Amended Proposed Development as seen from Finchley Road looking North towards Queen’s Terrace (Summer view)

6.11.4 Summary

The conclusions of the 2016 EIA in so far as the likely significant heritage, townscape and visual effects of the Amended Proposed Development, remain unchanged from that previously concluded in the 2014 ES for the Consented Proposed Development.


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6.12 Cumulative Effects

This assessment considers the potential cumulative impacts and likely effects associated with the Amended Proposed Development. Two types of cumulative impacts and effects are considered:

• Intra-Project Effects (Type 1) - Combined effects of different types of impact, for example impact interactions arising from noise, dust and visual impacts during construction of the Amended Proposed Development on a particular sensitive receptors. These are also known as ‘impact interactions’; and

• Inter-Project Effects (Type 2) - Combined effects generated from the Amended Proposed Development together with other planned developments. These other developments may generate their own individually insignificant effects, but when considered together the effects could amount to a significant cumulative effect, for example, combined transport impacts from two or more (proposed) developments. These are referred to as ‘in-combination’ impacts.

6.12.1 Intra-Project Effects

Whilst there is the potential, in the absence of mitigation, for some impact interactions to take place during the different phases of demolition and construction works, this will generally be restricted to the period when works are occurring close to the receptor. Even then, not all receptors will experience impact interactions during this time. The majority of interactions arise from activities such as noise and vibration from construction plant and vehicles, general demolition works, dust from plant and vehicles, the visual impact of the works and passing HGVs.

A CEMP/SEMP will be implemented during the demolition and construction works. This will provide the mechanism to minimise impacts of demolition and construction works ‘at source’ in order to reduce the potential effects on internal and external surrounding receptors. Overall, it is considered that any interaction of effects that occurs will generally be Minor Adverse and temporary and short-term in nature, albeit there may be some peaks of Moderate Adverse effects when works are occurring immediately adjacent to properties.

6.12.2 Inter-Project Effects

The development proposals for the Main Site propose the part on-site and part off-site provision of affordable housing.

Informal consultations with WCC in 2014 identified a preliminary list of seven schemes for consideration in relation to the Main Site, namely:

• Land at Rear of Grove Hall, Court Hall Road;

• Quintin Kynaston School;

• American School in London, 1 Waverley Place;

• 36-44 Lodge Road;

• Warner Stand, Lords Cricket Ground;

• 1 Queen’s Grove And 12-22 Finchley Road; and

• 100 Avenue Road London.

A review has been undertaken for this S73 Application which identified an additional four schemes for consideration, namely;

• The Compton (St John's Wood Delivery Office), 30 Lodge Road;

• Dora House, 60 St. John’s Wood;

• Wellington Building, 28-32 Wellington Road; and

• Tavern Stand & Allen Stand, Lords Cricket Ground St John's Wood Road.


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The cumulative assessment concludes that the cumulative effects during the demolition and construction stage for the Amended Proposed Development at the Main Site would be as follows:

• Temporary Negligible at a regional level with regard to construction related employment and indirect spending;

• None with regard to buried heritage assets;

• Moderate Adverse with regard to transport and access (including capacity, severance, delay, amenity and fear and intimidation), and Negligible for cycle facilities and capacity, and public transport networks;

• Temporary Slight Adverse on air quality;

• Temporary Moderate Adverse with regard to noise and vibration effects on nearby sensitive receptors;

• None with regard to ground conditions;

• Negligible with regard to surface water management and water resources;

• None with regard to ecology and biodiversity at local level only;

• None with regard to daylight, sunlight and overshadowing;

• None with regard to wind microclimate.

The cumulative assessment concluded that the cumulative effects during the Completed Development stage for the Amended Proposed Development at the Main Site would be:

• Moderate Beneficial at local and borough level with regard to provision of housing;

• None with regard to archaeology;

• Slight Adverse on air quality with regard to road traffic emissions;

• None on air quality with regard to energy centre emissions;

• Negligible with regard to noise and vibration from building services plant;

• Negligible with regard to noise and vibration from road traffic emissions;

• Minor Beneficial with regard to ground conditions;

• Negligible to Beneficial on surface water management and water resources;

• Beneficial on flood risk;

• Beneficial on ecology and biodiversity at a local level only;

• None with regard to daylight, sunlight and overshadowing;

• None with regard to wind microclimate.

ST. JOHN’S WOOD SQUARE PROJECT S73 SBMISSION · 2018-07-20 · THE ST JOHN’S WOOD PROJECT...

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