royal mint court, london ec3 non-technical … mint court, london ec3 non-technical summary (nts)...

Planning Application Addendum

Royal Mint Court, London EC3

Non-Technical Summary (NTS)

June 2016

Royal Mint Court ENVIRONMENTAL STATEMENT: NON-TECHNICAL SUMMARY

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1. Introduction

In February 2016, RMC (LH) Co. Limited (the ‘Applicant’) submitted a full planning and listed building consent application (reference PA/16/00479) (the ‘February 2016 Application’) for a commercial development at Royal Mint Court (the ‘Site’). The Site comprises an area of approximately 2 hectares (ha), as shown on Figures 1 and 2. It is located within the north west of the London Borough of Tower Hamlets (LBTH), close to the boundary with City of London (CoL).

Figure 1: Site Location

The Applicant’s proposals (the ‘Development’) would retain, modify and refurbish various existing buildings

and structures on the Site, whilst also providing new-build elements to the Site. Accordingly, partial demolition

and dismantling would be required. The Development would provide office and retail land uses within four

buildings referred to as the Johnson Smirke Building, the Registry Building, Murray and Dexter House and the

Staff House. The total floorspace provided by the Development would be 80,708 sq.m Gross External Area

(GEA). A gym, plant areas, parking and landscaping areas are also proposed as part of the Development.

An Environmental Impact Assessment (EIA) was undertaken to assess the likely significant environmental

impacts of the Development. The EIA was reported in an Environmental Statement (ES) which was prepared

to accompany the planning application. It was submitted in February 2016 (the ‘February 2016 ES’). The ES

described the methodologies used to carry out the EIA and set out the likely significant environmental impacts

of the Development, taking account of a range of mitigation measures proposed to prevent, reduce or offset

any adverse environmental effects.

Following submission of the February 2016 Application, the Applicant engaged with LBTH and other

consultees, in particular with the Greater London Authority, Historic Royal Palaces, Historic England and the

Georgian Group. In response, a number of revisions and clarifications are proposed to the February 2016

Application. These revisions principally relate to a reduction in height of Murray and Dexter House and

changes to the dormer windows on the Registry Building.

In view of the revised design, further EIA work has been undertaken to ensure that all likely significant

environmental effects of the Development have been identified. This work has been reported in an ES


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Addendum. The February 2016 ES and the ES Addendum therefore form the ES for the purposes of the

Development. This document (the Non-Technical Summary (NTS)) provides a summary of the findings of the

entire EIA in non-technical language. For ease of reading and to avoid referring to multiple documents, this

NTS supersedes and replaces the NTS prepared as part of the February 2016 ES and is submitted alongside

an ES Addendum to reflect the minor design changes and responses to the clarifications made by LBTH.

Figure 2: Site Plan


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2. EIA Methodology

An EIA aims to ensure that the potential likely significant environmental effects of a new development (which

can be beneficial and adverse) are given due consideration in the determination of a planning application. In

accordance with relevant legislative requirements and best practice guidelines the EIA has been undertaken

using established methods and criteria. This involved site visits and surveys, data reviews, consultation with a

number of relevant authorities and specialist assessments undertaken by a team of qualified and experienced

consultants.

The first stage of the EIA process involved undertaking a ‘scoping study’. This study identified the likely

significant environmental issues associated with the Development and therefore the focus of the EIA and

content of the February 2016 ES. The proposed content of the EIA was discussed with LBTH and CoL and it

was considered that the EIA would need to in include an assessment of the following environmental topics: the

environmental effects of the demolition and construction process; socio-economics; noise and vibration; air

quality; transportation and access, ground conditions and contamination; built heritage; townscape and visual

amenity, archaeology; daylight; sunlight and overshadowing and solar glare; the pedestrian wind environment;

and cumulative effects (the effects of the Development combined with the effects of other presently or

reasonably foreseeable schemes).

Each of the environmental assessment topics listed above is reported in the February 2016 ES and the ES

Addendum (where relevant), with a chapter dedicated to each of these issues. Each chapter describes how

the assessment has been undertaken, the current conditions on and adjacent to the Site and the potential

effects of the Development. Each chapter also describes a range of measures that would be incorporated to

avoid, reduce, or offset any identified adverse effects, and / or enhance potential beneficial effects. Such

measures are referred to as ‘mitigation measures’. The resulting effects (known as ‘residual effects’) following

the implementation of mitigation are also described.

3. Site History and Existing Land Uses

Archaeological works undertaken within the Site during the 1980s, prior to the construction of the existing

office development, revealed substantial archaeological remains pertaining to a Black Death cemetery (mid-

14th century) and the Cistercian Abbey of St Mary Grace (mid-14th to mid-16th century). Following the

Reformation, the remaining buildings of the Abbey were used by the Royal Navy as a victualling yard

principally to store tobacco. The Royal Mint moved to the Site in the early 19th century from the Tower of

London.

The Johnson Smirke building was built in 1811 and rebuilt during the 1880s to accommodate the expanding

Royal Mint. The Seaman’s Registry Building (the Registry Building) was designed as staff accommodation for

the Royal Mint and was completed in 1805.

By 1875, the western half of the Site was predominantly occupied by offices, officers’ quarters, a police station

and a courtyard. The north east area of the Site was occupied by a gold and silver refinery, which included a

chimney. The central / eastern area of the Site was occupied by various stores, engine and boiler houses,

forges, grinding and melting rooms and rolling, coining and sizing rooms.

By 1933, a number of the warehouses’ uses had changed, for example they were used as storage, printers

and stables at this time. During World War II, the Site suffered some bomb damage and by the 1960s, little of

the original Royal Mint remained, apart from the Johnson Smirke building, the Registry and the two

gatehouses at the entrance.

In 1976, it was announced that the Royal Mint would move to a new facility in south Wales and the Site was

cleared of much of the buildings housing the machinery for coin making. Following the move of the Royal Mint,

in the 1980s, the Site was extensively redeveloped into offices, including the completion of Murray and Dexter

House in 1987. The Site became known as Royal Mint Court and functioned as a financial centre. Alterations

to the Seaman’s Registry were made at this time, with the Grade II listed façade retained (see Figure 3

below). The façades facing north were demolished, along with the majority of the building within them. The

façade was then extended to the east in the Georgian style of the Grade II listed south and east elevations.


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The overall footprint was enlarged to include the majority of the former large rectangular building that can be

seen to the north.

Figure 3: Existing buildings and structures on Site.

The Site currently comprises vacant buildings that have been used for office space. There are areas of

hardstanding and ornamental planting around the buildings. Although the office space has been vacated, there

are a few staff members occupied with maintaining the Site. As illustrated on Figure 2, the features currently

on-site include:

The Grade II* listed three storey Johnson Smirke Building (Photograph 1 of Figure 4) was formally used for

office space and has been separated into numerous spaces for this use.

The Grade II listed Seaman’s Registry Building (Photograph 2 of Figure 4) comprising four storeys, with a

lower ground floor consisting 10 parking spaces and an electrical substation.

A Security Office is situated at the main entrance which is predominantly single storey with the exception of

the southern part which is two storeys.

Two Grade II listed cast iron lamp stands.

Two Grade II listed gatehouses are at the main entrance to the Site. This is the main pedestrian entrance

to the Site, across the forecourt in front of the Johnson Smirke Building leading onto Tower Bridge

Approach/ Mansell Street. Vehicles can access the Site at the main entrance, but it is primarily for drop-

offs.

Murray House (south) and Dexter House (north) (Photograph 3 of Figure 4) occupy the eastern area of the

Site. For the purposes of this application this building is referred to as Murray and Dexter House as both

‘Houses’ are joined above ground by a central glass atrium. The lower ground floor (basement) contains a

former gym, pub and storage areas. The gym basement extends beyond the ground floor footprint, and is

overlain by the central courtyard area. This area of basement is irregularly-shaped to avoid the

archaeological remains of the Cistercian Abbey.

A servicing road runs to the east of Murray and Dexter House at a lower level and has 35 parking spaces

along it. Access to this road can be gained from East Smithfield. An exit then runs from this road onto

Royal Mint Street which is a one-way system.


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A central courtyard area (Photograph 4 of Figure 4) with seating is located between Johnson Smirke and

Murray and Dexter House.

A fenced-off grassed area is present to the west of the Johnson Smirke building.

There are a number of trees along the west and south-west perimeters of the Site, and an area of

ornamental planting is located to the south-west of the Site.

A listed perimeter wall surrounds the majority of the west, north and south of the Site.

The main pedestrian entrance to the Site is located to the west of the Site. The pedestrian-only entrances onto

Royal Mint Street, East Smithfield and Cartwright Street are currently closed to general public access. The

subway that runs from the Site beneath East Smithfield to Tower Bridge Approach is also closed.

1. Johnson Smirke Building 2. The Seaman’s Registry Building

3. Murray and Dexter House 4. Central Courtyard

Figure 4: Photographs of the Existing Site


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There are a variety of features surrounding the Site (as shown in Figure 5) including:

Approximately 20m to the north of the Site, off Royal Mint Street, is the cleared Royal Mint Street

development site where planning permission is sought for a mixed-use development;

Extensive cycle infrastructure including Transport for London’s (TfL’s) Cycle Superhighway 3 running

immediately to the north of the Site and further works planned for completion in summer 2016;

An office building containing a Telephone Exchange is located off Royal Mint Street to the east of the

Seaman’s Registry. This building does not form part of the Development (see Figure 2);

Residential properties located on Cartwright Street to the east and in St Katherine Docks to the south.

DreamMaker Children’s Nursery and Mosaique Hair Salon are also located to the east of the Site on

Cartwright Street and there are a variety of other businesses housed in proximity to the Site including the

London School of Business and Finance and Societe Generale investment bank;

The Tower of London World Heritage Site, Scheduled Ancient Monument and listed buildings from Grade I

to Grade II is approximately 100m south west of the Site;

The River Thames is approximately 290m to the south of the Site, with Tower Bridge (Grade I listed)

crossing the river into the London Borough of Southwark;

Local transport infrastructure to the Site includes Tower Hill Station (District and Circle London

Underground Lines), Tower Gateway Station, Fenchurch Street National Rail Station serving out of London

to Essex and Tower Millennium Pier for riverboat services.


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Figure 5: Location of Potentially Sensitive Receptors


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4 Alternatives and Design Evolution

In line with the EIA Regulations, the ES provides a description of the main alternatives to the Development, considered by the Applicant. These include:

The ‘No Development’ alternative;

Alternative sites;

Alternative uses; and

Alternative designs.

No development at the Site was not considered to be a viable option by the Applicant. Without redevelopment,

the Site would likely remain underused and the buildings would undergo further deterioration which would

result in increasing maintenance costs of the vacant buildings and Site structures. In addition, there would be

continued vacancy of employment space in a central London location well serviced by public transportation.

These factors would mean that regional and local planning objectives would not be met in relation to the Site.

Furthermore, local socio-economic benefits of regeneration, in terms of retail provision, employment and other

commercial opportunities would not be achieved, and aspirations to integrate the Site better within the wider

area would not be realised.

The Site is already in the Applicant’s ownership and since the existing buildings are vacant, it is considered

necessary to redevelop the land to ensure the Site is utilised. Consequently, the Applicant’s objectives for the

Development specifically relate to the Site and its specific opportunities and constraints. Accordingly, no

alternative locations have been considered for the Development.

The existing buildings on-Site are in a poor condition with dated internal finishes and cladding. Mechanical and

electrical systems and lifts are now at the end of their economic lives. In addition, the toilets are underprovided

and don’t comply with current regulations. The buildings are therefore in need of upgrading and re-imaging in

order to be suitable for use.

The Development enables these improvements to be made. The provision of high quality office uses and retail

space is therefore considered appropriate for the Site and would accord with strategic development planning

policy. Alternative uses would therefore not be supported and have not been explored further.

Several alternative designs were considered by the Applicant. Each design option was based around outlined

principles of the redevelopment including:

Utilise the building form and heritage of the Grade II* Johnson Smirke Building as the centrepiece to the

new public realm;

Increase permeability: open up and connect the Site to the rich surrounding context of the Tower of

London, St Katharine Docks, City of London and residents to the east of the Site on Cartwright Street and

beyond;

Develop an office led mixed-use response to enliven the public realm;

Rework the Registry Building to provide new offices with an ‘active’ ground floor;

Provide a landscaping scheme in response to the history of the Site;

Sustainably develop new office buildings reusing much of the existing structure of the buildings on-Site,

including the retention of existing basement slabs and most of the existing foundations.

Each of the options was tested against a series of townscape views to review the balance between the new

elements of the Development and the relationship to the existing retained façades and structures. As such,

several alternative designs that revised the bulk and mass of the Development, as well as the elevation

treatment were considered.


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5 The Proposed Development

The full planning application and application for listed building consent (where relevant) seeks consent for the

partial demolition of the existing buildings and other structures on the Site and part redevelopment and

refurbishment and construction of a new building an employment-led mixed use development of up to

81,000m2 of office, retail, restaurant and gym space.

Design Changes between February 2016 ES Submission and June 2016 ES Addendum

As set out previously, following submission of the February 2016 ES, minor design changes have been made

as a result of consultation with the Greater London Authority (GLA), Historic Royal Palaces (HRP), Historic

England and the Georgian Group, as follows:

A 3.34m reduction in height of Murray and Dexter House. The reduction in height has been achieved by

reducing the floor to floor heights for the 6th and 7th floors. These floors have also been ‘cutback’ in places

to reduce the visibility of Murray and Dexter House from the south west of the Site. The office floor areas

have been maintained by reducing the size of internal ‘voids’;

The movement of one of the proposed boiler flues on Murray and Dexter House, so it is hidden from views

to the south west of the Site;

Retention of the railings between the entrance porticos;

Changes to the dormer windows on the Seaman’s Registry; and

Rainwater collection features, present on the roof of Murray and Dexter House for the February 2016

application, would now be located in the basement.

These changes have been included in the Development description set out in the following paragraphs.

The Development does not involve the entire demolition of the existing buildings on the Site. Figure 6

indicates the existing building outlines with the proposed outlines, including the new and retained / modified

elements.

The Johnson Smirke Building

In relation to the Grade II* listed Johnson Smirke Building, some external alterations would be required to the

rear façade at the lower ground and ground floor level to create a new external seating area at the lower

ground floor and to improve the access to the rear courtyard by reinstating two access bridges. This would link

the retail units at the lower ground and ground floor level with the public realm to the east. Office units would

be provided from first to third floor levels.

The height of the Johnson Smirke Building would not alter and the maximum height of the building would be

remain as approximately 34.26m AOD to the top of the highest chimney. The roof structure would be rebuilt,

with the original chimneys moved forward by approximately 0.5m. Alterations are proposed to the third floor

rear façade to create the improved roof terrace area.

Internal listed features, including the stairs between the ground and first floor and the clock tower would be

retained and refurbished as part of the Development.

The Seaman’s Registry Building

The demolition activities proposed at the Seaman’s Registry Building involve the removal of the 1980s

extension behind the Grade II listed façade. The existing 1980s extension and mansard roof of the Seaman’s

Registry Building behind the retained façade would be replaced. Minimal modifications are proposed to the

Grade II listed façade on the south and west of the Seaman’s Registry Building. These modifications relate to

replacing an existing window with a door at the ground floor level, which is in accordance with the original

design. The existing ramp and steps at the ground floor to the south of the building would be removed (these


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Figure 6: Existing and Proposed Building Outlines

are assumed to be a 1980s addition). Four new entrances are proposed from Mansell Street through the listed

curtilage wall of the Site.

The maximum height of the Registry Building would be 34.165m AOD (including roof plant above the

mansard) from the ground to the fourth floor, an increase of 1.965m from the existing building.

Useable office space would be introduced from the first to the fourth floors, with retail / office uses at ground

level. A replacement UK Power Network (UKPN) substation would be situated within the north-east corner of

the Seaman’s Registry Building.

Murray and Dexter House

The main demolition works at the Site would be at Murray and Dexter House, including the demolition of the

west facing three structural bays of the building, the floors, the northern, western and southern façades and

the roof. Full recladding of the building’s exterior is also proposed. Changes to the massing of this building are

shown on Figure 5.1 which shows how both Dexter House to the north and Murray House to the South would

be ‘pulled back’ from the Johnson Smirke Building. Overall, the maximum height would alter from +44.95m

AOD as existing, to +45.56 m AOD as proposed.

Murray and Dexter House would include office floorspace from the ground to the seventh floor. The lower

ground floor of Murray and Dexter House extends under the rear courtyard and would contain a gym plant

rooms, storage and parking areas.


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The Staff House

The Staff House is an entirely new structure and is in the same location as a building which was in this

location and demolished in the 1940s. Three storeys of flexible floorspace are proposed with the building

extending to a proposed maximum height of 32.765 m AOD.

The Gatehouses and Security Office

The two Grade II listed gatehouses (porticos) positioned at the entrance to the Site would be retained and

refurbished. The Security Office, which is at the western end of the Grade II listed Seaman’s Registry Building

would also be retained and refurbished.

Transport and Access

Vehicular access to the Site would be minimised where possible. A taxi route and drop-off would be provided

at the main entrance from Tower Bridge Approach / Mansell Street (A1210). This entrance would be limited to

drop-off only.

Car parking would be within the lower ground floor of the Development, which would be accessed via the

lower level service road at the eastern edge of the Site (behind Murray and Dexter House). The entrance to

the lower level service road would be via East Smithfield. A total of 25 parking spaces, seven of which would

be designated for people who are disabled.

On the Site, there would be a total of 943 cycle spaces. Long-stay cycle parking for staff would be provided in

the form of double stacking racks and facilities including showers, lockers and changing areas would be

provided adjacent to the cycle parking areas. Visitor cycle parking would also be provided. Access to the cycle

parking facilities within Murray and Dexter House and the Seaman’s Registry Building would be via lifts from

the ground floor levels.

The Development seeks to enhance the permeability of the Site by creating new pedestrian routes,

encouraging visitors to access the Development and respond to increased movement patterns to and from

Tower Hill and Tower Gateway Stations. The main entrance to the Site would remain the same as the existing

entrance, from Tower Bridge Approach / Mansell Street (A1210). The entrances from Royal Mint Street and

East Smithfield would also be improved to enhance the north-south permeability of the Site. In addition, there

would be four new access points through the perimeter wall of the proposed retail units within the Seaman’s

Registry. Pedestrian access from Cartwright Street would include reopening and enhancing the route to allow

step-free access from the east through the Site. A new graded route would therefore be provided in place of

the stepped route which would aim to encourage existing residents to the east to access the Site. The entry to

the existing pedestrian subway under East Smithfield to St Katharine Docks, Tower Hill Station and the Tower

of London would be upgraded as part of the Development. A new external lift would be provided in addition to

the existing stepped access. The entrance to the pedestrian subway would be located at the south-west

corner the Staff House (at Ground Floor Level).

Landscaping and Ecological Enhancement

The Development would provide a total of approximately 730m2 of soft landscaping (planting) and

approximately 6,500 m2 of hard landscaping (walkways, vehicular routes) (refer to Figure 7). It is proposed to

remove the existing railings at the main entrance of the Site in order to improve access and permeability. The

design of the front lawn would be sculptured with raised ‘lipped’ seating areas and water features. The existing

two mature London Plane trees at the entrance of the Site would also retained. The majority of the Site would

be repaved using materials appropriate to the Site. The design of the rear courtyard area between the

Johnson Smirke Building and Murray and Dexter House includes informal seating areas and tree groves,

grouped in clusters. Glass paving would be incorporated into the stone paving of the rear courtyard used in

order to view the archaeological remains of the Cistercian Abbey. A walled garden to the west of the Registry

Building is proposed which would be accessed from the proposed retail units at the ground floor. Roof

terraces, are proposed on Murray and Dexter House. A roof terrace with planting features is also proposed on

the Johnson Smirke Building. Planting would comprise native species to provide habitats for bats, birds and

invertebrates.


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Figure 7: Overall Landscape Plan

Sustainability

To reduce carbon dioxide (CO2) emissions from the Development, consideration has been given to a range of

energy technologies and energy conservation measures have been incorporated within the Development

including a Combined Heat and Power (CHP) led heating system and photovoltaic panels (PV). PV panels

would be provided at on the roof of Murray and Dexter House (530m2 in total).

The Development would provide a number of features in order to accord with the principles of sustainable

design including a target BREEAM Rating of ‘Excellent’; the use of green/ sustainable building materials,

minimising waste generation during construction and operation by promoting recycling; creation of

construction and long-term employment; the provision of suitable ‘access for all’ including the mobility

impaired; the provision of extensive facilities for cyclists; the provision of water efficient fittings and

incorporation of energy efficient measures to reduce water and energy consumption; the provision of low and

zero carbon and energy technologies, and; improvement of biodiversity.

6 Development Programme, Demolition, Refurbishment and Construction

The current expectation is that the demolition, modification, refurbishment and construction (‘the Works’) for the Development would span approximately 30 months, with the Development anticipated to be completed in the early 2019. The following sequence of the Works phases would take place:

Pre-commencement surveys;

Service diversions;

Site enablement;

Demolition and dismantling;

Piling and substructure;

Superstructure (refurbished and new build elements of the Development);


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External works;

Mechanical, Electrical and Plant (MEP) and Building Works; and,

Fit out.

Site enabling works would include works to the archaeological remains situated under the Site. It is evident

that parts of the remains would require repair or stabilisation to ensure their survival. The specification would

be agreed with LBTH’s Archaeological Advisor (Greater London Archaeological Advisory Service (GLAAS)).

The archaeological remains would be protected for the duration of the works, so that they remain in optimal

condition for exposure in their final condition. It is envisaged that protection would consist of wrapping the

remains in sheeting and / or geotextiles as the initial layer of protection and would then be buried in clean

silica sand. Where necessary, additional support in the form of timber shoring (sheet plywood) would be

provided. Archaeological remains enabling works can be carried out at any time prior to the start on-Site of the

main contractor, as a separate enabling works package, to avoid any unnecessary interface with the main

works.

Figure 8: Demolition Plan

As identified within Figure 8, the Development does not involve the entire demolition of the existing buildings

on the Site. Therefore, the demolition and dismantling works are incorporated into an integrated construction

sequence where the buildings would be carefully stripped-out, including any removal of asbestos, as needed.

Care would be given to protect and temporarily support the retained elements of the existing buildings and

dismantle elements as needed.

In order to control and manage the potential environmental impacts typically associated with the Works, a site-

specific Outline Construction Environmental Management Plan (CEMP) has been developed and would be

implemented throughout the duration of the works. This would specify a range of measures to manage the

environmental impacts that could arise and would provide, for example, details of controls in relation to noise

and vibration, dust and the safeguarding of the retained façades and structures of the Development.


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The CEMP would be prepared in line with relevant legislative and best practice guidelines including LBTH’s

‘Code of Construction Practice’. The CEMP would be agreed with the LBTH and contractors would be required

to implement the CEMP, ensuring that monitoring and auditing is undertaken where this has been specified.

CEMPs are an established method of managing environmental effects resulting from demolition and

construction works and they are successfully adopted for other major schemes in urban areas.

7 Socio-Economics

It is estimated that the Development would generate approximately 222 full time equivalent (FTE) jobs during

the demolition, refurbishment and construction period. In addition, an annual spend of approximately £300,000

is anticipated from the construction workers, much of which would be spent in the local area, and would further

benefit the economy.

Once completed, the net direct employment generation from the Development (taking into account leakage

and displacement effects) would be 3,569 FTE jobs. However, the Development would not just generate direct

employment. Employment would also be generated from indirect and induced effects. These jobs would be

generated both directly from the Development and indirectly as a result of supply chain effects to local

businesses. The Development is predicted to generate a total net employment of 6,067 new FTE jobs. Jobs

generated both directly and indirectly are expected to bring in over £216 million into the Greater London

economy annually.

The proposed mix and layout of land uses and publicly accessible open spaces would result in increased

activity levels within the Site throughout the day thereby reducing the opportunity for crime and improving

perceptions of safety and wellbeing. This would contribute towards a safer environment for pedestrians and

visitors to the Site.

8 Noise and Vibration

A review of potential noise and vibration effects has been undertaken as part of a wider for the Development.

To provide baseline data, a detailed survey has been undertaken to establish the existing noise and vibration

climate on and off-Site. Noise monitoring was carried out in a number of locations and included: short-term

attended measurements carried out during the day and at night; and unattended noise measurements lasting

from several days up to a week.

An assessment of potential noise and vibration effects has been undertaken and it has been found that without

appropriate mitigation measures the following adverse effects could occur:

Potential temporary effects on local residents, businesses, and users of the nursery as a result of noise and

vibration from construction / demolition works;

Potential permanent effects on archaeological remains and retained features of heritage importance due to

vibration from nearby demolition and construction works;

Potential long-term effects on local residents, businesses and users of the nursery as a result of delivery

and servicing activities generated by the Development; and

Potential long-term effects on the new office users as a result of noise from existing transportation sources

(roads and the local railway).

A number of mitigation measures have been proposed to minimise the potential adverse effects identified

above, including (but not limited to) the following:

Best practicable means noise and vibration control techniques would be utilised during construction e.g.

noise and vibration monitoring, use of noise barriers etc.;

Implementation of a construction noise management plan (as part of the Construction Environmental

Management Plan (CEMP)) throughout the works. The final CEMP would be agreed with LBTH;

A ‘consent to work agreement’ would be prepared to allow LBTH to review the contractor’s proposals in

advance to control and minimise noise and vibration effects;


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Future items of fixed plant and equipment would be selected, installed, mitigated and maintained to meet

the specific plant noise limits, in line with LBTH’s requirements;

Appropriate building envelope and ventilation system design is implemented at the Development.

Through the use of appropriate mitigation measures it has been concluded that effects in relation to noise and

vibration would be reduced. With the completed Development, there would be some slight adverse effects

noticed by occupants of Cartwright Street in relation to the movement of service vehicles. However, there

would be no significant effects as a result of traffic noise, plant noise or from existing vibration sources.

9 Air Quality

The construction works have the potential to create dust. During construction it would therefore be necessary

to apply a package of mitigation measures to minimise dust emission. With these measures in place, it is

expected that any effects would be insignificant.

The operational effects of increased traffic emissions arising from the additional traffic on local roads, due to

the Development, have been assessed. On account of the existing poor air quality around the Site, the

Development would have an insignificant effect on roadside air quality, although along Royal Mint Street the

effects would be slightly worse. However, the actual change in concentrations along Royal Mint Street would

be very small: less than 1% of the air quality objectives set by the government for Nitrogen Dioxide (NO2) and

Particulate Matter (PM10 and PM25) pollutants. Therefore, the effect of air quality off Royal Mint Street would

also be insignificant.

The operational effects of the energy plant to be installed within the Development have also been assessed.

The assessment has demonstrated that the impacts of the CHP, boiler and humidifier plant emissions would

be insignificant and a statistical model has been used to demonstrate that the backup diesel generators would

not lead to any exceedences of the air quality objectives.

The Development would be air quality neutral in terms of transport emissions, but without mitigation it would

not be air quality neutral in terms of building emissions. Appropriate mitigation would be provided for the

standby diesel generators at the detailed design stage to ensure that the Development can become air quality

neutral.

Taking into account all of the above, the overall air quality impacts are deemed to be not significant.

10 Ground Conditions and Contamination

A ground conditions and contamination assessment has been undertaken to establish the likely contamination

risks posed to human health (including future users of the Site and construction and maintenance workers)

controlled waters (including the groundwater contained within the underlying aquifers) and property (including

on-Site and off-Site structures, foundations and services). The assessment used a range of information

sources including a review of historical maps, geological maps, and information provided by the Environment

Agency and other organisations.

A desk-based study of the potential for soil and groundwater contamination at the Site has been assessed

based on previous historical activities that have taken place over the last 750 to 800 years. The only previous

ground investigations at the Site took place in 1971 and 1986 and while no contamination testing of the soils

and groundwater was undertaken as part of those investigations, the borehole logs did not describe any

ground contamination to be present. In 1987 some contamination was identified during demolition works and

although no chemical testing results are available, high levels of some contaminants were reported in the

north eastern section of the Site.

Made Ground present on-Site would be a likely source of ground contamination, however due to the presence

of a basement beneath the current on-Site buildings, it is expected that much of the Made Ground was

removed in areas of the Site. Residual areas of potentially contaminated Made Ground are therefore reduced

but remain in areas outside the basement extent.


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During the Works, any existing contamination on the Site could be exposed and disturbed, potentially resulting

in harm to human health and the underlying aquifers. However, all Works would be undertaken in accordance

with measures set out in the CEMP.

The future supplementary ground investigation would further assess potential risks and provide additional

information of the ground conditions at the Site. Additional mitigation and / or vapour protection may be

required if solvents or gases are encountered.

11 Built Heritage

Analysis has been carried out of the heritage significance of the buildings on the Site and of other heritage

assets including the nearby Tower of London World Heritage Site and its constituent heritage assets (the

Tower of London scheduled ancient monument and listed buildings), and the contribution of the Site to the

Tower Conservation Area.

A detailed assessment of the effects of the proposed Development in regard to the effect on these heritage

assets has been undertaken. This included a desk based assessment of published sources of information on

the historic built environment in the area, in the form of statutory information and studies, histories and

research; physical inspection and fieldwork on the Site and the surrounding area, and consultation with LBTH,

Historic England and Historic Royal Palaces.

There would be adverse effects during the demolition and construction phases of the Development, although

these would be mitigated by the visual protection of the Site by hoarding, management of construction traffic,

and other measures contained within the CEMP to be secured through planning conditions and implemented

by the contractor.

Overall, once the Development is complete, it was found that the proposals made in regards to the retention,

alteration or removal of buildings and structures on the Site would be beneficial within specific local area but

affecting heritage assets of a national heritage significance. The Grade II* listed Johnson Smirke Building and

the Grade II listed façade of the Seaman’s Registry would be retained and incorporated into the proposals, in

addition to the refurbished entrance lodges and cast iron lamp stands. The siting and proposed architectural

design aims to ensure the new elements of the scheme respect these listed elements. Similarly, the design of

the proposed Development aims to preserve and enhance the character and appearance of the Conservation

Area, the setting of the World Heritage Site and its constituent heritage assets, and the setting of nearby listed

buildings.

12 Archaeology

A detailed desk based archaeological impact assessment has been undertaken in order to determine the

potential for important archaeological assets to exist at the Site. The assessment has included the analysis of

relevant data including historical records, maps and geological information, together with several site visits.

The Site lies within a designated Area of Archaeological Importance, as defined by LBTH. It was

archaeologically excavated during the later 1980s, when substantial Medieval, Post Medieval and Modern

remains were identified. The Site is considered to have a generally low archaeological potential for the

prehistoric, Roman and Anglo-Saxon periods.

The Site became one of two designated emergency burial grounds for the Black Death epidemic in London of

1348-50 AD. Following the creation of the cemetery, the Cistercian Abbey of St Mary Graces was founded by

Henry II at the Site, which lasted from c.1350 until the Dissolution of the Monasteries.

Past development on the Site is considered likely to have removed archaeological assets formerly present,

under the existing buildings. However, it is estimated that of the estimated total of circa 2,400 burials present,

circa 2,000 are known to remain within the western part of the Site. In addition, in situ remains of the Abbey

buildings remain beneath the central / eastern and southwestern parts of the Site. Figure 9 illustrates the

areas of known, potential, recorded and removed archaeology.


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The Site also has a known archaeological potential for the Post Medieval and Modern periods, relating to its

use as a Victualling Yard, warehousing and subsequently as the Royal Mint.

In the absence of mitigation, intrusive ground works (e.g. piling) would have the potential to destroy

archaeological assets within the footprint of the demolition and construction works. The greatest unmitigated

effect would occur in the areas of highest archaeological asset potential (i.e. areas of the remains of the

Cistercian Abbey and Black Death Burial Ground).

With the protection of the in situ remains along with recording and the preservation of the known and potential

archaeological resource within the Site during the demolition and construction process, all effects would be

mitigated to a likely insignificant level. Preservation of the in situ Medieval remains, together with

enhancement of their setting, provision of further interpretation and access, and the adoption of a long-term

management strategy would lead to a significant beneficial effect.

Figure 9: Area of known, potential, recorded, and removed archaeology


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13 Daylight, Sunlight, Overshadowing and Solar Glare

An assessment of the likely significant effects on daylight and sunlight amenity, and on overshadowing to the

existing surrounding residential properties and amenity spaces, was undertaken.

The main methods of assessment included the Vertical Sky Component (VSC), No Sky Contour and Average

Daylight Factor (ADF) for daylight analysis, the Annual Probable Sunlight Hours (APSH) for sunlight analysis,

permanent shadow analysis for overshadowing of amenity areas, and the Sunlight Availability analysis for

solar glare; all using a 3D computer software model.

The level of likely effect to daylight and sunlight availability on surrounding properties and overshadowing to

surrounding amenity spaces would vary throughout the demolition, refurbishment and construction works,

depending on the level of obstruction, but would be limited as most of the buildings are being retained within

the Development.

Overall the daylight analysis shows that the neighbouring residential properties adjacent to the east and south

of the Site would experience either insignificant or an adverse effect within some of the properties on levels of

daylight when measured against specific daylight guidelines. On the whole, there would be no significant effect

on levels of sunlight within these properties although some adverse effects would be noticed in a few

properties off Cartwright Street, in St Mary Graces Court.

With regard to the shadows cast by the Development, whilst there would be some modest reductions to the

amenity areas immediately adjacent to the development site the Development would not have any significant

effects on surrounding amenity areas in terms of overshadowing. The likely effects are considered to be

acceptable and appropriate. This is on account of the urban context and planning policy aspirations of the Site

and the wider area.

The solar glare analysis illustrates that the development would have the potential to generate some highly

localised temporary instances of glare but these would be limited and by no means unduly excessive given the

Site’s urban context. This would not be detrimental to safe movement of pedestrians and vehicular users on

the pavements and roads surrounding the Development.

14 Wind

A desk based assessment of the likely wind conditions as a result of the Development and the acceptability of

these in terms of pedestrian comfort and safety has been undertaken.

The existing Site is expected to experience conditions acceptable for its intended use due to the low-medium

rise nature of the existing buildings and its surroundings.

As the Development involves reconstruction and refurbishment of the existing buildings on Site and the

construction of a five storey building, wind conditions around the Development are expected to be similar to

that of the baseline. Due to the limited change in massing of buildings, demolition and construction works are

not expected to significantly affect the wind microclimate of the Site.

Thoroughfare locations are expected to be acceptable for their intended use as the occasional exceedances of

strong winds are anticipated to be infrequent.

The majority of entrances of the Development are expected to observe acceptable conditions except at the

entrance to the gym of Murray and Dexter House. This entrance would require mitigation to lower wind

speeds.

Ground level amenity spaces are generally acceptable for their intended use during the summer season;

however the large amenity space located centrally between Murray and Dexter House and the Johnson

Smirke building would require mitigation in the form of landscaping to achieve acceptable wind conditions.

Terrace level amenity spaces would not require mitigation measures to reduce the effect of the prevailing

south-westerly winds because these would be used weather permitting.


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15 Transport and Access

During the demolition and construction works there would be a short-term increase in traffic flow, particularly

heavy goods vehicles (HGVs), associated with general plant and materials deliveries and the removal of waste

from the Site. The construction traffic routes would be agreed in advance with LBTH and other relevant

authorities (e.g. TfL). On-Site logistic plans would be operated to ensure free flow of vehicles to avoid

unnecessary congestion at access points on public highways. Deliveries are planned and co-ordinated in line

with the detailed construction programme reducing vehicle movements and ensuring maximum efficiency

during the construction process. It is anticipated that construction flows would generally take place out of peak

highway hours when traffic levels on the local highway network are lower.

To effectively manage this traffic, management measures are set out within a CEMP. This would include

measures such as the use of agreed appropriate routes to and from the Site for construction vehicles (see

Figure 10) and restrictions on the largest vehicles arriving and departing from the Site during off-peak times of

the day. Appropriate signage would be implemented around the Site as well as communication to inform local

residents of activities.

Figure 10: Proposed Route to and from the Site during the Works

Once the Development is completed and occupied, it is predicted to result in increases in traffic flows on the

local road network. It is proposed to retain 25 car parking spaces, seven of which would be designated for

people who are disabled. The proposed level of car parking represents a 45% reduction in the amount of car

parking from the existing 45 car parking spaces available on Site. Electric Vehicle Charging Points (EVCPs)

would be provided in accordance with standards in the London Plan (March 2015). No changes are proposed

to the existing vehicular access points, however, it is proposed that car use within the Site is restricted to

private hire taxis/private car set-down/ pick-up in a limited area. This is to ensure that the public realm within

the Site provides an attractive environment for pedestrians. The existing taxi rank which accommodates three

licenced taxis at the entrance to the Site on East Smithfield would be retained.

There are a number of existing pedestrian access points around the perimeter of the Site would be retained

and improved to make the Site more welcoming to the public. A new pedestrian access point would be created

from Royal Mint Street, which would create a new high quality north-south route through the Site to the A1203

East Smithfield. The proposed route would be beneficial in improving local pedestrian connectivity. It is

proposed to modify the exiting subway access at the point it meets the Development to provide an accessible

lift. This would complete the step-free route between the Site and Tower Hill station.


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At present servicing takes place from a number of places around the Site. The servicing strategy for the

Proposed Development is that all servicing would now take place from the existing service road to the east of

the Site, with additional loading bays created to accommodate a greater number of vehicles. This would

contribute to improving the public realm on the Site by concentrating service vehicle movements in one area.

The Development is predicted to generate additional walking and cycle trips on the local network surrounding

the Site. However, as outlined above, the Development provides new pedestrian routes through the Site and

enhances the Site’s permeability and connectivity for pedestrians and cyclists. The pedestrian environment

within the Site would be of high quality with the provision of an attractive open space, well-maintained and

legible pathways, lighting and animated ground floor uses, thus providing natural surveillance. Long-stay and

short-stay cycle parking for employees and visitors respectively would be provided in accordance with the

London Plan (March 2015) standards. A total of 780 long stay cycle parking spaces and 163 short term cycle

parking spaces would be provided. Cycle parking would be provided at various locations within the Site. It is

proposed that cyclists would gain access to the Site from any of the Site access points, where cyclists will then

be required to dismount and then push their bicycle to the appropriate long-stay or short-stay cycle parking

area. This is to ensure that the public realm remains a safe, high quality space for both pedestrians and

cyclists.

A Framework Travel Plan has been developed in support of the planning application. This sets out a

framework for the delivery of new transport initiatives and measures for users that travel to and from the

Development on a regular basis. The aim of the Plan is to reduce reliance on private car use and to encourage

travel by more sustainable modes of transport.

16 Townscape and Visual Impact Assessment

The townscape and visual impact assessment was undertaken to assess the potential impacts of the EIA

Development on the character of the townscape, the townscape setting of heritage assets and the composition

and character of views. The Development is located within The Tower Conservation Area and a number of

listed buildings are present on Site. The local townscape character is dominated by the Grade I listed Tower of

London which is also a World Heritage Site.

During preparation and construction works for the Development, plant and construction equipment would be

visible from the surrounding local area and therefore have a temporary but adverse effect on the townscape

character and visual amenity of the area. Adherence to standards and procedures set out in the CEMP, such

as hoarding, would manage such impacts.

15 viewpoints were assessed in relation to the potential visual effects for the February 2016 ES submission.

For each of the identified views, accurate visual representation images (AVRs) of the view 'as existing', 'as

proposed' and ‘as proposed with cumulative schemes’ were produced to aid in the assessment. An extra

viewpoint was added for the April 2016 ES Addendum and some original views re-assessed to reflect the

design changes. One view of the Development is shown in Figures 11 and 12.

The assessment concludes that the Development has been designed to provide urban design benefits and to

contribute positively to the distinctive character of the Site and its boundary, as well as the varied townscape

character of the townscape character areas that adjoin the Site; that the Development would result in a

significant improvement to the Site in terms of architectural quality; and that the Development would enhance

the quality of open spaces on Site, opening it up to the surrounding area and to the public.

There would be significant effects on 10 of the 16 views studied – in the other cases, either the effect would be

insignificant, or the Development would not be seen at all and therefore there would be no effect. In the 10

views where there are significant effects, these effects are, as a result of the positive qualities noted above,

either beneficial or neutral in qualitative terms; there are no adverse effects.

Due to the modest increase in scale of the Development in comparison to other proposed schemes nearby

which are seen in the same views, the effect of the Development in some of the views assessed was reduced

when the cumulative condition was considered. Informed by the views analysis, the effect of the Development

on five local townscape character areas was assessed which was found to be beneficial.


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There would be an enhanced outlook from the remainder of The Tower Conservation Area towards the Site (in

cases where the Development is visible). The overall effect is limited due to the modest increase in scale of

the Development and the size and townscape character of the Conservation Area.

Figure 11: Existing view of the Site from Tower Bridge Approach

Figure 12: Proposed view of the Site from Tower Bridge Approach


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17 Cumulative Effects

Two types of cumulative effects have been assessed in relation to the Development:

The combination of individual environmental effects arising from the Works of the Development. For

example, noise, dust and visual intrusion; and

The combination of effects resulting from the completed Development and other present or reasonably

foreseeable schemes.

During the demolition and construction period, there would be some temporary combined impacts

predominantly associated with noise, vibration, dust, accidental pollution events and visual effects. However,

the Site-specific CEMP would ameliorate these construction related cumulative impacts as far as practically

possible.

A total of 30 ‘other’ schemes have been considered cumulatively with the Development at the Site (see Figure

13 below). These schemes were selected on the basis that they had valid planning permission, were within

1km of the Site and had a floorspace uplift of greater than 10.000m2 gross external area. Schemes within 1km

with an uplift of less than the criteria above, but which introduced sensitive receptors near to the Site were also

considered. The exception to this is the proposed scheme to the north of Royal Mint Street on account of its

proximity to the Site where the EIA has considered both the consented scheme and the scheme yet to be

determined by LBTH.

The cumulative effects of the Development in conjunction with these schemes were generally found to be

insignificant. However, it was concluded that there would be:

Temporary and long-term beneficial socio-economic effects as a result of employment creation, increased

local expenditure, provision of additional open spaces for the local communities, provide an improvement in

community safety and crime prevention;

Temporary adverse effects as a result of cumulative noise and vibration effects from the use of construction

site plant and machinery;

Temporary adverse effects on heritage assets as a result of construction activities including construction

infrastructure e.g. scaffolding and tower cranes;

At most, temporary beneficial effects on the daylight and sunlight received by neighbouring properties

during the demolition phase;

Some highly localised long-term adverse effects on some properties in St Mary Graces Court, Cartwright

Street and the Royal Mint Street development;

Long-term beneficial effects in regard to townscape, visual amenity and above ground heritage assets; and,

Long-term beneficial effects on pedestrian and cyclist movement in and around the Site.


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Figure 13: Location of Cumulative Schemes


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If you would like to receive further copies of this Non-Technical Summary or would like to purchase a copy of the Environmental Statement and the Environmental Statement Addendum, please contact:

Waterman Infrastructure & Environment Ltd

Pickfords Wharf

Clink Street

London

SE1 9DG

Tel: 0207 928 7888

Email: [email protected]

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