Report of the Interim Chief Planning Officer and Development Director.
The Committee considered a report of the Interim Chief Planning Officer and Development Director regarding land bounded by Fleet Street, Salisbury Court, Salisbury Square, Primrose Hill & Whitefriars Street, London EC4Y, - specifically:
a) Demolition of existing buildings, comprising 69-71 Fleet Street, 72-78 Fleet Street (Chronicle House), 80-81 Fleet Street, 8 Salisbury Court, 1 Salisbury Square, 35 Whitefriars Street (Hack and Hop public house), 36-38 Whitefriars Street, and 2-6 Salisbury Square (Fleetbank House); b) Part demolition of 2-7 Salisbury Court (Grade II) and carrying out of works including remodelling at roof level, formation of new façade to south elevation, part new façade to west elevation and new core and part new floors. Part replacement fenestration, new plant and other works associated with change of use to drinking establishment with expanded floor provision (sui generis); c) Erection of three new buildings: 1) A combined court building (Class F1) 2). A police headquarters building (sui generis), and 3). A commercial building including offices, retail and cycle hub (Class E); d) Creation of shared basement for emergency response vehicles, parking, mechanical, electrical and plumbing (MEP), and ancillary functions associated with the three new buildings, with ingress and egress from Whitefriars Street; e) Public realm and highway works, including enlarged Salisbury Square, landscaping access and servicing arrangements, new pedestrian routes, hostile vehicle mitigation (HVM) measures, and bicycle and vehicle parking; f) Dismantling, relocation and reconstruction of Grade II listed Waithman obelisk within Salisbury Square; g) Other associated and ancillary works and structures.
This application has been submitted alongside two other applications for listed building consent (at Agenda items 3a and 3b respectively).
The Town Clerk introduced the item by reporting that, in addition to the Officers’ report and presentation slides, Committee Members had also received a virtual site visit clip of the site, a brochure from the applicant containing a virtual fly-through of the site and three separate, late addendums containing some amendments to the Officer report as well as some late representations. The Town Clerk reported that all of the late addendums had also been published on the City’s public webpages.
The Interim Chief Planning Officer and Development Director introduced the application and began by also making reference to the addendum report and the handling note which had been produced for this application, in line with the Comptroller and City Solicitor’s advice given on the composition of this Special Sub Committee at the outset of the meeting. He went on to explain that it was felt that the fairly lengthy addendum report was necessary in order to clarify some factual discrepancies, incorporate late updates and highlight late representations. However, the principal reason for the addendum was that, as any consent that may be granted was not subject to a Section 106 agreement, a lot of work was needed to nuance the conditions which would carry more weight than would normally be the case.
Members were informed that there were three interrelated applications for consideration today – the major, MasterPlan application and two listed building consents – all of which would be covered during this Officer presentation. Officers went on to provide the Committee with a general overview of the scheme, and Members were shown a site plan of the large site on Fleet Street bounded by Whitefriars Street to the west, Salisbury Court to the east and Primrose Hill to the south. The site was also shown in relation to nearby conservation areas and listed buildings. It was noted that the northern part of the site fell within the Fleet Street Conservation Area, with Whitefriars Conservation Area to the south-west and two listed buildings/structures – 2/3 Salisbury Court and the Waithman Obelisk, nearby. Members were informed that it was proposed that virtually every existing building on this large site be demolished, the only exceptions being the listed building at 2/3 Salisbury Court and Waithmans Obelisk. Officers explained that one of the contentious elements of this scheme is that it would involve the demolition of buildings which make a positive contribution to the Fleet Street Conservation Area. Members were shown images of such buildings which it was reported vary in construction date from the 19th century to the 1960s. This matter was covered in detail within the report with Members aware of the objections raised on these grounds. It was reported that other buildings on the site were of a less exceptional quality dating from the 1960s and 1980s.
A MasterPlan overview was shared with the Committee with Officers highlighting that the intention was to create a new civic quarter in the heart of the legal community, close to the Central Criminal Court, the Royal Courts of Justice, the Middle and Inner inns of Court and the business and property courts. This was therefore considered a pivotal scheme in the middle of London’s legal quarter. It was proposed that a new Courts building would be positioned along the Fleet Street elevation to the north of the site, new Headquarters for the City of London Police and a commercial building to the south and the reinvention of the public house on the north side of the square. Members were shown a sketch from the architect providing an overall impression of the scheme looking south. In the foreground was the proposed court building with the police building sat behind this and the commercial building to the south with Salisbury Square to the east. The Committee were also shown architect sketches of the proposed scheme looking eastwards.
Officers compared the existing ground floor plan of the site with the proposed ground floor plan. It was reported that the current floor plan was rather convoluted and that the proposals for this were much more coherent, featuring three individual buildings, Salisbury Court and two passageways – a northern and southern passageway. The Committee went on to examine proposed floorplans for the Lower Ground Floor and Basement where Officers highlighted that it was proposed that there was a shared servicing arrangement for all three buildings situated to the south of the site. This would consolidate vehicular movement to a single point and thereby liberate the remainder of the site for pedestrian use. There would be off-site consolidation deliberately capped to 80 vehicles per day, including refuse collection and this would be enforced by condition. This would be a reduction in the current servicing demands for the site. No servicing of the three buildings would be permitted between the hours of 07:00-19:00 and there would be a condition around the need for a Delivery Servicing Plan. Members were shown a cross section of the proposed north/south section of the site showing the shared basement straddling all three buildings.
Further images showing the entirety of the scheme in relation to its surroundings were also shared. With regard to the proposed North elevation on Fleet Street, the new Courts building was shown as a very prominent, civic building. The existing east elevation showed the listed building in the foreground with FleetBank House depicted as a rather deadening element in this view. The proposed east elevation showed the court building to the right hand side, with the reinstated and restored listed buildings in the foreground, the commercial building on the left and the Police headquarters (the tallest building on the site) in the centre. The proposed west elevation showed the new pedestrian routes/ north and south passageways.
Officers went on to talk on each proposed new building individually. It was reported that the new Court building would be operated by the Courts and Tribunal Service (HMCTS) as a flagship Court facility aiming to tackle cybercrime, fraud and economic crime. The proposed building would consist of eight storeys and a combined court building comprising crown, civil and magistrates court rooms with a total of 18 courtrooms within the complex. The complex would also include hearing rooms, office areas, waiting rooms and areas for specialist law uses. It was reported that the design of the building was bespoke and accommodated the HMCTS reform programme to facilitate technology with video links and virtual hearings becoming increasingly important over the past year and facilitating more transparency/public and press access. Officers reported that one of the key requirements of the brief was that there should be provision for separate access and circulation routes through the building and into the courtrooms for the judiciary, jurors and the general public. Members were shown indicative plans for each floor of the building. It was highlighted that a roof garden was proposed at seventh floor level with images of the view that users of this facility would enjoy looking eastwards shared. It was reported that the elevation of the building on Fleet Street was considered to represent a very dignified and distinguished civic building with an architectural gravitas befitting of its use. The building would also be very prominent and in the foreground in the view looking eastwards along the processional route for St Pauls. It was recognised that the ground floor plain was a challenge due to the very specific security concerns associated with the court building and indicative illustrative proposals depicted the use of commissioned artwork both on the ground floor elevation of the court building and other opportunities on the façade to help enliven the street frontage. The proposed south elevation of the courts building displayed prominent, vertical projecting bays which would draw the eye towards St Brides in the view looking eastwards. The West elevation depicted the proposed north passageway with St Brides as a main focal point. Views of the Court building looking west also depicted the Lutyens listed building alongside it in the foreground which was also very civic, monumental architectural statement. The Express and Telegraph buildings were depicted opposite – all part of the DNA of the Fleet Street area.
With regard to the proposed Police building at the centre of the site, it was reported that it was proposed that this house the new City of London Police Headquarters which would be state of the art and provide a new technological base fit for 21st century policing and a key public institution for the City. Ground floor plans for this building depicted a welcoming, glazed façade onto Salisbury Square. The building would be bounded on the north side with a north pedestrian passageway and on the south side with a southern passageway. Members were shown images of typical floorplans rising through the building and it was highlighted that, with health and wellbeing now an increasing priority in public service, there was also a proposed roof terrace on the building, intended for the use of serving police officers and other staff within the Police building. The building would be constructed using weathered steel with ceramic spandrels and would sit comfortably alongside the terracotta of the commercial building to the left, the limestone of the Court building and also the warmth of tone of the listed buildings in the foreground. Images of the various elevations of the proposed Police building were shown. It was noted that the west elevation in particular would include a quite innovative solution of an enclosed garden with a concave, stainless steel curved roof which would reflect not only the greenery but also light into this area, thereby enlivening the Whitefriars Street elevation and offering additional light to the custody suites located underneath.
Finally, with regard to the commercial building it was noted that the level changes here were challenging. It was reported that the retail elements would be located on two levels with generous, double height space along Whitefriars Street which could be subdivided. There would also be an entrance to the cycle hub off of the southern passageway and it was highlighted that this scheme was compliant with both long-term and short-term cycle space requirements. It was felt that the cycle hub was a very innovative and creative way to achieve this. The cycle hub, located off of two major cycle highways, would be free of charge for the general public to use and would have dedicated lift access to 169 cycle spaces in a secure and sheltered environment. A cycling promotion plan would also be secured under condition and there would also be a condition to ensure that the signage to this important asset would be prominent in the hope that this would serve as a template for other similar offerings across the City going forward. It was reported that the office building would generate 11,700 square metres of office space which was well designed and flexible floor space capable of sub-division. The floorplates were intended to optimise daylight and natural ventilation – something that was increasingly important. It was noted that an external terrace was proposed at sixth floor level which would be an important element of the post-COVID offering in terms of providing fresh air and breakout space for the occupants of the building. This would also be replicated at the top level of the building (level 9) with a roof garden. Images of the views from the roof garden which would be surrounded by high balustrades were shared with the Committee. In architectural terms, Officers described the commercial building as a very convincing building of decorative terracotta that would serve to reunify the Whitefriars Street frontage and compliment the architectural character of the area.
The vehicular entrance for the entire site would be accessible from the southern part of the site and there would be response vehicle access into the Police building a little to the north.
The Interim Chief Planning Officer and Development Director made further reference to the two listed building applications embedded within this overall application. The first of these related to 2-7 Salisbury Court and Members were shown images of the existing building that had been constructed in 1878 and was a Queen Anne revival style building which was popular at the time. It was noted that the building had been significantly altered with the interior wholescale rebuilt in the 1980s which had severely diminished its significance. It was reported that original drawings of the building at the time of its completion had helped to inform the restoration work now proposed as part of this application. This would involve reinstating the gables, the joinery and all of the other missing architectural elements of the building. The proposed west elevation depicted how the fabric at the back of the building would be reused with original features once again reinstated. It was reported that the building immediately to the south of this, which was a 1960s neo-Georgian building, was proposed to be demolished which would open up the south elevation to be a principal elevation to the listed building. It was reported that the proposed design approach was to wrap around the Queen Anne idiom that appeared on the east elevation into a prominent and principal elevation facing onto the public square. This would be a very scholarly reinterpretation of the Queen Anne appearance of the building which Officers believed would contribute positively to the listed building, given its proposed new setting.
Members were informed that there were also proposals for a new public house to replace the ‘Hack and Hop’ public house currently on site on Whitefriars Street. It was considered that this would be an enhanced public house offer with an almost three-fold increase in terms of floorspace and a much more prominent opening onto a public square and external terrace. Ground floor plan proposals depicted the reinvention of an existing party wall as a principal elevation with doors opening onto an external terrace. The lower ground floor would also be for public house use. The second floor level would be for private hire/private events.
It was reported that Waithmans Obelisk was the second listed building application within this application. Officers highlighted that the Obelisk had had rather a transient life having originally been located at Ludgate Circus, then moved to St Bartholomew Place in the 1950s before being placed in its present location in 1975. The landscaping currently surrounding the Obelisk was instated in the late 1980s and the existing carriageway for vehicles also surrounded this. This application proposed the relocation of the Obelisk to a new context within the new pedestrianised public realm at Salisbury Square, on access to the southern passageway. Images of the relocated Obelisk in the context of the new public house and Salisbury Square were shown.
In terms of public realm, Officers underlined that there was a substantial increase in pedestrian public realm on the site under these proposals. It was reported that, in essence, the public realm offering was at Salisbury Square (a key new civic square) with a north and south passageway. Salisbury Square was currently 31m in length and this would be increased to 43m in length and, with the proposed removal of the road, the pedestrian space here would be increased by 97% and it was felt that this would become an extremely successful civic square in the centre of the legal quarter. The proposed landscaping and planting here was intended to provide a sense of enclosure. The planters would also provide hostile vehicle mitigation measures and the original Salisbury Square building line would be denoted in the paving. Short stay cycle parking spaces would also be offered here. Officers highlighted that there would be a raised table at the Salisbury Court elevation which would be on the same level as Salisbury Square and therefore give the impression of an even more generous public square from this point. The northern passageway to be provided between the Court building and the Police building would be in the region of 5-7 metres wide and therefore a very generous thoroughfare dedicated to public highway. The passageway here would be aligned to focus on St Brides spire looking eastwards. It was felt that this would really anchor the public realm into the wider context. The southern passageway proposed between the commercial building and the Police building was a more challenging passage due to the level changes here. It was proposed to be generously proportioned at between 3.6 and 5.7 metres wide and would incorporate generous tree planting and soft landscaping. Staircases and lifts would take pedestrians up to Salisbury Square. Visuals looking east towards Salisbury Square depicted Waithmans Obelisk as a central focal point in this view.
It was reported that, overall, the pedestrian comfort levels around the site would improve but it was also recognised that there were two pinch points to the north of the site on Fleet Street due to the need for hostile vehicle mitigation (HVM) measures. It was reported that the pedestrian realm offerings had been tested and were considered to be acceptable in terms of both wind and thermo comfort levels. The third element of the public realm offering was the creation of a new permissive path, just to the north of the new public house. This would be a very narrow route (which was not unusual in this part of the City) including steps due to the level change to Primrose Hill and a pedestrianised area to the rear which could be utilised by the public house for external tables and chairs.
Officers then focused on some of the key views that had informed the massing of the scheme beginning with the view of the proposed scheme from Hungerford Bridge where it was reported that the proposal had had to be reduced in height in order to enable the spire of St Brides to still be visible against open sky. The view from Fleet Street along the key processional route which was of national importance depicted the building beginning to emerge. Officers commented further on the very civic nature/scale of the building that was quite characteristic of Fleet Street and also spoke of how it would relate in terms of scale and architecture to the surrounding buildings.
In summary, the Interim Chief Planning Officer and Development Director reported that this was a major unprecedented and unique proposal for a new civic quarter for the City. It was noted that a scheme with such ambition would inevitably give rise to some challenges and that these were set out within the report. In particular, the proposals around the demolition of a number of buildings which made positive contributions to the conservation area were contentious as highlighted by the objections received. However, it was remarked that Fleet Street’s history was such that the rich, finer grain and eclectic townscape had readily absorbed significant new civic buildings with ease whilst continuing to thrive – these included the Royal Courts of Justice to the West, The Express and The Telegraph buildings directly opposite this site and the Lutyen’s Reuters building adjoining the site. Officers stated that, incidentally, all of these buildings were now listed but were considered, at the time, to be major interventions in Fleet Street’s urban fabric replacing older buildings and an older grain but were now a key and established part of the area’s character and defined its uniqueness. In this spirit, it was felt that the distinctive civic architecture proposed in this scheme was of the highest quality and would enrich these characteristics which define Fleet Street. Overall, the scheme offered much enhanced public realm for pedestrians (overall a 42% increase in public space across the site), with a larger Salisbury Square as a refined civic space with a creative reimagining of the public house at the site’s northern end. Most significantly, and to offset some of the harm that had been identified, this scheme would offer state of the art, bespoke facilities for two key public services at a challenging time where public services are appreciated more than ever before. The Courts building would physically deliver the vision to modernise and upgrade the justice system such that it works for everyone – introducing new technology, infrastructure, processes and ways of working in a bespoke building. This would be delivered in a distinguished, refined, civic architectural statement with a degree of gravitas befitting its crucial public use. This was a key, substantial public benefit of the scheme. The police building would provide a state of the art headquarters and technological base for 21st century policing for the City of London Police – a key public institution and a lead policing force in economic and cyber crime as well as law and order in the City. The proposed building was of the highest architectural quality and would provide a sustainable and secure environment as the force seeks to protect society against a range of new and emerging threats – another key, substantial benefit of the scheme. Officers stated that this was not, in their opinion, a transformational scheme seeking to totally reinvent the area in terms of character and identity. These proposals were considered to be more meaningful and enduring, building on the strength, significance, uniqueness and fundamental identity of the Fleet Street area and its surrounding community and economic base. It was considered that these proposals would reenergise and redefine this uniqueness, reinforcing the area’s character as a centre of legal excellence not just for the City but for London. It was considered that they would also be a catalyst for economic growth – a key policy aspiration for the City. On a wider level, this new civic quarter in the heart of London’s legal quarter would reinforce the City’s reputation as a global centre for business and finance by providing the infrastructure necessary to administer justice efficiently and uphold the rule of law. It was felt that, in this sense, the scheme would resonate globally and be of global significance. As such, Officers recommended the scheme for approval.
The Town Clerk reported that there were no registered objectors addressing the meeting today. The Town Clerk went on to introduce four speakers speaking in favour of the application – Mr Paul Wilkinson, City Surveyor, James Thomson, Chair of the City of London Police Authority Board, Mark Stewart, Operations Director, HMCTS and Eric Parry, Eric Parry Architects.
Mr Wilkinson began addressing the meeting by introducing himself as the City Surveyor and therefore the main applicant for this scheme. Mr Wilkinson reported that he was also joined on the call today by various members of the project team who would be happy to respond to any questions of detail that Members might have on the application. Mr Wilkinson highlighted that the Salisbury Square development was one of the City Corporation’s major programmes which, alongside the proposals for the new Museum of London and plans to relocate the historic Markets, would help to secure a positive future for the Square Mile. He added that, given that the City had been known for centuries for its high quality legal services, investing in 21st century Courts alongside a modern day headquarters for the City of London Police was exactly the type of investment that the City Corporation should be making at this time. It was reported that the Salisbury Square scheme was designed by Eric Parry Architects and was of high quality, incorporating exceptional sustainability credentials. It was reported that the benefits of this scheme would be felt widely as businesses reopen and people return to the office and it was felt that it would be the City’s investment in developments such as this that would provide businesses with the confidence to invest for themselves.
James Thomson reported that the City of London Police’s role was as both local police force for the Square Mile where its priority was counter terrorism but also as the national lead force for economic and cyber crime. It was highlighted that the force today was scattered throughout the City in premises that they had outgrown, were at the end of their life and no longer supported their needs today. It was reported that this project, once completed, would represent an accommodation programme that had taken over 20 years and was of critical importance to the City. It was reported that economic crime now accounted for 1 in 3 crimes in the UK and was increasingly of national importance for Ministers, the Treasury, business and the competitiveness of the UK and the City. This proposed 21st century headquarters would support police officers tackling economic and cyber crime and the City police as they kept the City safe from terrorism and policed the City’s other priorities including the night time economy. It was part of the City Corporation’s priorities to make the Square Mile the safest City area in the world and having a purpose built headquarters alongside a new Courts building would ensure that the force was fit for policing the City today and well into the future.
Mr Stewart began by underlining that London was regarded as a global centre for law, legal services and litigation and reported that HMCTS regarded the new City of London Court building as critical in enabling them to deliver the level and quality of courts services expected of them in the 21st century and beyond. Mr Stewart stated that it was fair to say that the Mayors and City and the City of London Magistrates Court had served HMCTS well over the years but that both were now quite simply unable to accommodate the technology, ways of working and accessibility requirements of a modern justice system. Mr Stewart reported that the HMCTS’ capacity for accommodating the needs for modern fraud and economic crime prosecutions in the City was also conspicuously limited. This new combined court would enable HMCTS to make a clear statement about its collective commitment to maintaining the City’s position as a global centre for commerce, justice and legal excellence for many more years to come. Mr Stewart added that he also believed that this building would truly represent an exemplar in the courts estate, enabling the creation of a genuinely hallmark court building which would fully integrate and accommodate the modern technologies and ways of working being delivered under the HMCTS Reform Programme. He stated that the positive impact of this on the public, whether in terms of the level of service, experience or perception, should not be underestimated. It was reported that HMCTS and the City Corporation had a long history of collaboration and shared commitment to the administration of justice and it was hoped that the new Court building would allow this to continue.
Eric Parry stated that whilst others had spoken of the great need for both the Courts building and the new City of London Police headquarters alongside the benefits of co-location which included energy and servicing, he would like to focus on the civic/urban design opportunities and the ambition of the architecture. He reported that the existing situation on site was one that, particularly with Fleetbank House, precluded permeability and a passage. The ambition was therefore to create a MasterPlan with three new buildings, each with a passage between that culminated in the square and enabled the sum to be greater than the addition of the parts. Importantly, the plans would also serve to draw St Brides into the picture of this urban quarter. In terms of the buildings themselves, Mr Parry stated that the Court building in particular had to be seen and understood as one that is designed from the inside out as well as the outside in. Members were shown plans which depicted the opportunities for getting daylight into the four Crown Courts with managed circulation for judiciary and witnesses to the north and for the public to the south. It was highlighted that the north was particularly important in terms of the visibility of this from the street and it was reported that, at the competition stage, the scheme did not incorporate the inflections now visible to the east and west of the building. These made a very important contribution to the presentation of the building on the street and Mr Parry went on to speak further on the design evolution of these from 2018 to now and shared various images of this.
Mr Parry went on to report that his practice have designed several buildings in stone in London where the use of shadow and recess had been very important as they would be here. This building would include picked granite that would be light in colour but could also be honed to a darker hue. Metal work would be used for the windows and window frames. There would be ten panels at the foot of the building facing onto the street which would be the subject of an artwork competition to be judged and shortlisted by an expert panel. Mr Parry reported that the south side of the building was all about consultation with the idea of the stacked oriels reflecting the HMCTS brief, with the public circulation also on the south side. Importantly, a public staircase would rise through the first three levels of the building at the southern perimeter and then retreat to a central location above.
Early design drawings of the proposed new passageway depicted the police building to the right of the Courts building with the background of the listed building, the Lutyens building and Wren’s spire forming a sequential backdrop.
It was noted that the Police building would need to step gingerly over many areas of for instance vehicular movement and the garden which also allows daylight to the basement. Mr Parry explained that the external skeleton of this building would be one of weathered steel which it was hoped would be made fabricated in the UK. Mr Parry commented on the muscularity of this building necessitated by the need to lift and levitate to allow everything to happen underneath it.
With regard to the material of the commercial building, Mr Parry stated that this would be A LIGHT absorbent material with ram pressed terracotta that it was felt would work well with the existing architecture on Whitefriars Street.
The Chair thanked the applicant team for their contributions and invited any questions that Members may have of them.
A Member commented that he had spent much of his working life in the Lutyens building at 85 Fleet Street and therefore knew the area very well. He stated that the architecture of the proposed buildings was admirable in principle but questioned whether Mr Parry felt that this would over bulk this part of Fleet Street, particularly at street level. He noted that, whilst the Lutyens building was of a similar design concept, it was much smaller in scale. Mr Parry responded to state that, in terms of the scaling of the building, he was satisfied that, because of the sculptural quality of the inflections and the emphasis of these, none of the sections were, in their own right, bigger than the Lutyens building in terms of its width. He added that he felt that there was a lot of modulation within the elevation that would work nicely. He highlighted that the emphasis was on a much smaller entrance with a clear set back on the top two floors that mirrored the way that the Lutyens building appeared. Mr Parry reported that, as the building was sat on a curve and would be set back, it would actually show more of the Lutyens building than was the case at present.
Another Member commented that English Heritage were quite critical of this development and welcomed any comments that Mr Parry might have on this, particularly with regard to the concerns expressed on the views of St Brides church. Mr Parry recognised that English Heritage had taken a view on the harm that would be caused to the conservation area by these proposals but noted that they had summarised that this would equate to less than substantial harm which was very important. He stated that he felt that the representations from English Heritage were very measured and reasonable. Mr Tim Cutter, project manager reported that, on the whole, conversations with St Brides had been very positive. He stated that the views of St Brides had been preserved and enhanced in many ways, particularly with the proposed northern passageway which would create a new view of the church. Mr Cutter highlighted that there was an error within the report presented today which described some minor damage of the view of St Brides. With regard to LDMF views, Mr Tavernor commented that the report suggested, in error, that there would be some concealment of St Brides from views 11A1 and 12A1 from the east. However, the proposed scheme was behind St Brides so there would be no impact here.
Mr Robert Tavernor reported that there were currently very limited visibility of St Brides in views along Fleet Street and that, when moving eastwards towards St Pauls, visibility was limited to the very top of the spire that could be seen above the roofline of existing buildings on the site. It was commented that these views were incidental and formed part of a kinetic sequence, they were not key views of St Brides and, from the few parts of Fleet Street where St Brides was visible, these were also not considered to be key views with the Fleet Street Conservation Area appraisal. It was reported that the loss of the top of St Bride’s spire in these incidental views would also be mitigated through the creation of the new north passageway that Mr Parry had already referenced. The proposal had been carefully designed to preserve key views of St Brides from Ludgate Hill looking west along Fleet Street.
Another Member questioned concerns raised by St Brides church who seemed to be unhappy about access during the construction phase of this development. She asked whether the applicant team had any comment on this. In terms of access to things such as funerals and wedding services, Mr Cutter recognised the concerns raised by the church and highlighted that it would be ensured by condition that there was a Construction Management Plan in place for both the demolition works contract and the main works contract. This would include neighbour liaison teams to help inform these plans and ensure that church services were not disrupted.
A Member questioned what efforts had been made in terms of maintaining and refurbishing the existing buildings on site, particularly the façades of those buildings along Fleet Street given that they positively contributed to the conservation area. The Member went on to note that, in terms of the whole life carbon emissions impact of this development, there was reference to a 38% potential reduction and she questioned whether this was realistically achievable and, if so, why it was pitched as an aspiration only and not the final figure. Finally, the Member noted a point raised by a resident objector on the office spaces that are currently empty along Fleet Street and the need therefore for an additional office building in this location. She went on to note that, between 2010-2019, over half of all court buildings in England and Wales had been lost and questioned whether consideration had been given to having further court space as opposed to office space within the building. The Member also questioned the rationale behind having civil courtrooms, crown courtrooms and magistrates courtrooms within the same building and the assessment of conference rooms as there seemed to be a small number of these given the number of hearing rooms being proposed.
With regard to the refurbishment query, Mr Parry reported that there was an extensive alternative options study that the applicant had produced and that he was perfectly convinced that, on balance, it would not have been possible to work with the existing fabric in any optimal way for a variety of reasons. In terms of space allocated for various different uses within the building, Mr Parry reported that this had been a very demanding brief. Mr Stewart of HMCTS reported that the building was intended to replace existing facilities (the Mayors and City and City of London Magistrates Courts capacity) but was also seeking to introduce a much more flexible hearing space. He added that, post reform, on-site staffing numbers would be considerably limited. Whilst there was a notional allocation between Crown, Magistrates and County court rooms, particularly between the civil and magistrates hearing space, there would be a flexibility of use that would be enabled through the use of shared facilities. There would also be a synergy in terms of the way that senior judiciary were used in the space for both crime and civil work. With regard to the office space proposals, Mr Stewart stated that he understood that this was perhaps more to do with the economics of the overall redevelopment scheme. In terms of conference facilities, the brief that had been given to the architects had been around the need for flexibility in terms of hearing space, as already discussed, but also around the need for sufficient ancillary space. Mr Stewart stated that HMCTS were confident that, through the clever design of the building and use of the stacked/protruding window recesses, the potential consultation space in the building had been maximised. He added that senior judiciary had also reviewed the designs and were happy with these and felt that an appropriate balance had been struck in terms of the division of space.
In response to the point on whole life carbon, Daniel Skidmore recognised that this issue and sustainability in general was high on the agenda of many and referenced the City’s own Climate Action Strategy. Mr Skidmore reported that embodied carbon represented approximately 69% of the whole life carbon associated with this project and stated that this was therefore a significant component to focus upon. He added that the 7% noted by the Member reflected decisions that had already been taken and commitments that the applicant felt able to make at this stage of the design (in terms of structural design choices and material selections). The 38% that the applicant hoped to achieve in the longer term reflected where they were in the design process and the fact that the support of contractors and supply chains would also need to be secured to achieve this in what was a very evolving market. Mr Skidmore stated that he had confidence that alternative methods of construction could be explored at these later stages and assured the Committee that the applicant had a very significant commitment to doing all that they possibly could in terms of reducing whole life carbon.
Another Member spoke on the traffic impact of the proposals and sought assurances around how manageable this would be. Alex Keane reported that a detailed Transport Assessment had been undertaken as part of the application and this set out the potential impacts of the scheme. Mr Keane stated that it was worth noting that, at present, there was an existing carpark on site associated with Fleetbank House and limited control over servicing – much of which took place on-street at present. The new scheme would offer very limited on site carparking aside from the operational requirements associated with the City of London Police and, in terms of servicing, would look to consolidate the number of deliveries taking place and also look at the timing of these to ensure that they were outside of peak hours. With regard to operational activity, movements around the Court and Police buildings would be very tightly controlled and managed although noted that it was very difficult to determine when rapid response vehicle movements would occur. That being said, it was reported that a strategy had been worked up with rapid response vehicles to leave the site either northbound or southbound via Whitefriars Street and thereby avoid any particular issues associated with local highways issues caused by background traffic.
Another Member raised a question relating to the servicing plan and the proposed cap of 80 movements per day, seven of which would be on-street. It was noted that the remaining 73 movements would be between 7pm-7am and would work out at 6 movements per hour throughout the night. The Member questioned how many service bays there would be and whether these plans were achievable. Next the Member commented on cycling and stated that she was very pleased to see that the development would offer adequate cycling provision but questioned how this was to be accessed from various different points and whether any assessments had been carried out to ascertain how many bikes could access the proposed lift at any one time. In terms of servicing, Mr Keane confirmed that the applicant had developed a Servicing Strategy based on overnight deliveries following discussions with City of London Highways Officers and in line with policy. It was reported that the servicing yards within the site would be able to accommodate three vehicles at any one time and that, based upon a 20 minute booking system, this equated to approximately 108 ‘slots’ overnight. Members were informed that the applicant had identified around 60 potential vehicles that would need to be serviced within this site on any given night and that there was therefore significant capacity for this. It was reiterated that this would be very carefully controlled and managed with all vehicles arriving via a secure, consolidation centre with times to be adhered to and very clear slots allocated in advance.
In terms of cycle provision and access, Mr Keane confirmed that there would be two options for cyclists to access the cycle parking – either via Whitefriars Street which would allow cyclists to approach either from Fleet Street or Temple Street or via the Southern passageway where much of the cycle parking could be accessed from. Cyclists would be required to use the channels on the stairs here, however, for those coming up from Salisbury Court a number of improvements had been identified whereby two way vehicular access would be restricted for much of the northern part of Dorset Rise and a contraflow cycle lane introduced northbound to provide a better defined route from the Embankment Cycle Superhighway into the site. Each of the lifts proposed for each building would have the ability to accommodate two cycles at any one time which, given the anticipated level of demand and the proposed provisions, was considered sufficient for any potential activity.
Another Member referenced the narrow passageway with stairs and questioned whether this could be made more accessible with the introduction of a sloped walkway here for example. Eric Parry assured the Committee that this had been carefully considered. Ms Helen Allen, the applicants access consultant confirmed that a lift was to be installed in the southern passage alongside the flight of steps and that access would also be facilitated through the north passage. There would therefore be two step-free routes running east-west through the site. It was noted that there were some quite substantial changes in height from Whitefriars Street up to the main Square and it was felt that this was an appropriate response and the applicant stated that they were aware that the City of London were quite specific about the types of lifts that were able to be installed. Members were also informed that the applicant had undertaken a site survey of the area which was currently quite steep and non-accessible in terms of pavement widths and dropped kerbs and it was highlighted that these proposals therefore represented a marked improvement both east-west and north-south.
Another Member noted that, within the Delivery Strategy, it was suggested that court papers would be delivered by cargo bike. She questioned where these would be parked given the size of these. Mr Keane stated that specific parking for cargo bikes had not been identified at the top end of Salisbury Court but he added that it was worth noting that the applicant was going to be investigating the potential use of cargo bikes for deliveries but that the practicalities of this were something that would need to be discussed further with HMCTS in due course. This would be taken forward via both the Travel Plan and Cycling Promotion Plan. Mr Keane reported that the cycle parking within the public realm space would be able to accommodate non-standard bicycles such as cargo bikes. Ms Allen added that such spaces could also be utilised by accessible/adapted bicycles in line with the London Cycling Design Guide.
Another Member noted that the City’s Access Team had commented on the provision of disabled toilets and general accessibility and questioned whether these had been addressed by the applicant. Helen Allen reported that the Access Team were very keen to see a changing places toilet in the Police building but stated that, for security reasons, this would not be possible. There would, however, be one elsewhere on site, within the Court building itself and the applicant were still investigating the best possible location for this.
Seeing no further questions of the applicant, the Chair invited Alderman Ian Luder to address the Committee in support of the application.
Alderman Luder stated that he was speaking both as Alderman of the Ward of Castle Baynard and on behalf of the six Common Councillors of the Ward – that is to say the entire Ward membership with the exception of the two Members who serve on the Planning and Transportation Committee with whom he had not discussed this application at any stage. Alderman Luder went on to state that he was delighted that the City Corporation were making this landmark investment in a state of the art court complex and new headquarters for the City Police. He suggested that the strategic benefits already outlined by the applicant team made this development a vital investment for the Corporation and indeed the UK and would yield huge public benefit. He noted that the important benefits of this scheme to the significant number of workers and residents in and visitors to the Ward should also not be underestimated. He stated that the new combined court would be a landmark building that would not only serve to enhance the area’s reputation as the home of UK legal services and the centre of legal London but would also bring welcome investment to the community that the Alderman represented. In addition, this scheme offered a rare opportunity to significantly improve the public realm by creating new east-west walking routes, opening up centre views of St Brides and creating an enhanced public square which would provide a safe and pleasant environment for residents, workers and visitors to enjoy. The Alderman commented that Fleet Street was a busy but narrow thoroughfare with no scope to widen the pavements given cycle lanes and the need to enable buses to use the road. The new east-west walking routes would create welcome safer, quieter and pollution-free alternatives. The development would also remove what the Alderman described as the ghastly building known as Fleetbank House which was of no architectural or historical merit and destroyed the vista towards St Brides from the west and effectively precluded the east-west pedestrian approach. The development would also bring an activity and air of confidence to the area which would provide a welcome boost for local businesses which had suffered so significantly during the pandemic.
The Alderman went on to report that the City Corporation had liaised closely with St Brides around these plans and added that he had also personally met with the rector. He informed the Committee that the church were supportive of this application and recognised its importance to the area, stating that Members should now have received the latest letter from them outlining this. He added that their understandable concerns had related to the construction phase of the development and reported that they welcomed the proposed consultative arrangements being made contractual with the successful developers and the assurance that, when construction necessitated closure of the Fleet Street route to Salisbury Square, the southern approach at Dorset Rise would be kept open for funeral and wedding services. He reported that the church would also be providing advanced timetables to allow them to work collaboratively with the developers and provide longer lead times for weddings. The Alderman highlighted that there was tremendous support in the area for the development and that he had not had any objections submitted via him with the owners of 8 Salisbury Square now also having indicated their support. The Alderman described these plans as an exciting opportunity to align civic, wider community and commercial needs with first class public realm and he therefore urged the Committee to grant the conditional planning permission proposed.
Seeing no questions of Alderman Luder, the Chair asked that Members now move to any questions of Officers they might have as well as to the debate.
A Member returned to the point that she had made previously around the 38% reduction target on whole life carbon emissions. She noted that a 7% reduction had already been committed to but questioned whether Officers could comment on how far the 38% could be conditioned given that it was a very specific and therefore presumably realistically achievable target. The Interim Chief Planning Officer and Development Director reported that the condition on whole life carbon was a very robust one but was also one that was developed through collaboration and that, as the scheme was designed and developed, potential opportunities were looked at as feasibility testing, structural optimisation of the new building and potential low carbon cement were carried out to ensure that the measures set out within the whole life carbon condition were met. He added that Officers were very confident that the condition was robustly worded and that there was a will on both sides to be able to develop this and ensure that the condition delivers the target stipulated.
A Member noted that the report stated that this development would ‘reinforce the City’s reputation as a global centre for business and finance’ and that it would ‘form part of an established legal cluster focused on the Temples and the Royal Courts of Justice’ and added that, whilst this sounded good, it was not true. He went on to state that this development would house a few Crown Courts, a Magistrates Court and a County Court and had nothing at all to do with the City’s reputation as a global centre for business and finance. The nearby Royal Courts of Justice did but it was highlighted that what went on here was unrelated to these domestically focused new courts. The new courts would not, in any relevant way, form part of the legal quarter with the other nearby courts. The Member went on to state that the report also suggested that these new courts would alleviate the back log in cases caused by the pandemic but stressed that he also felt that this was untrue as, by the time this development (if approved) was completed, the back log would long since have been cleared. The Member stated that he felt that the problem with this report generally was that it read as if it were written by the applicant which it technically had been as, in this case, the City Corporation was to decide a planning application that had been submitted by itself. This gave rise to a fundamental conflict, even with the separation of the individuals involved. The Member highlighted that article 8 d of the City’s Planning Protocol recognised this and provided that ‘particular care must be taken in determining planning applications for the development of land or buildings owned by the City of London Corporation so as to ensure that such an application is not subject to preferential treatment but is subject to the same rigorous evaluation as other applications’. He commented that he found no rigorous evaluation within this report and underlined that it therefore fell to this Committee to discharge its statutory duty to decide this application by applying the relevant planning policies impartially and by having regard only to material planning considerations. The Member stated that, when considering these policies, he found that this application was contrary to almost all of them. This included policies which sought to prevent the loss of retail floor space in a principal shopping centre, the loss of medical uses, the loss of light to residential properties and the loss of office floor space yet this new commercial building would provide less space than the buildings to be demolished and the need for more office space post-COVID was something that only the Corporation and a few developers seemed to believe in. The Member added that, most significantly, this application would be contrary to the policies to preserve the City’s heritage and would entail the demolition of six buildings that make a significant contribution to the Fleet Street Conservation Area, the partial demolition of a listed building, the obliteration of the last remaining traces of medieval alleyways and the impairment of views of St Pauls on the processional way. Consequently, he felt that the application would be contrary to the Development Plan. Whilst the report did concede all of this it did not recommend that this application be refused. Instead, it recommended approval relying upon the ‘public benefits of the development outweighing the harm it would admittedly cause’. The Member noted that this Committee’s decision must therefore turn on the claim of these public benefits and that, if that turn was to be understood as meaning a direct benefit to members of the public, it was, in this case, very meagre. The applauded permeability of the site, (meaning the two east-west passages) merely made a virtue of the two gaps between the proposed buildings and the Member commented that the site was already permeable through the remnants of the medieval alleyways that would be obliterated under these proposals. The Member went on to state that the expansion of Salisbury Square by 25% would destroy the shape of the Square that has endured for 800 years and that none of this, or the token greening on the buildings, could rationally outweigh the demolition of the heritage assets. The Member surmised that the report, perhaps aware of this, relied on an indirect benefit to the public, consisting of the fact that the development includes new court and police facilities. The Member stated that it would undoubtedly be a benefit to the public to have state of the art court and police buildings but added that what was relevant from a planning perspective, which was all that this Committee could properly consider, was whether to have these buildings on this site and the planning policies indicated not. The Member stated that he felt that this development should be sited where it was not necessary to demolish part of a conservation area to accommodate it. He referred to the fact that the City Corporation had already been selling its police buildings and was using temporary accommodation as highlighted within the report but highlighted that this was not a material planning consideration and should therefore be ignored. The Member felt that it must be right that public benefit should not be understood in an indirect sense because, with a little imagination, virtually any building could be described as having a public benefit. If an indirect approach were widely adopted, any planning policy could be trumped and the planning system rendered redundant. The Member said that he felt that this was what had been happening in the City in recent years and that he therefore expected that this Committee would approve this application. He concluded that those who cared about the City’s heritage should not despair as Save Britain’s Heritage had already advocated that this application be called in for decision by the Secretary of State and underlined that he was supportive of this.
Another Member noted that the report pulled no punches in stating that this proposal did not comply with the Development Plan and sought to destroy listed buildings with the consequent effect on the Conservation Area. With this in mind, she stated that she had therefore looked very carefully at the benefits that needed to be weighed against the disbenefits which were also all set out very clearly within the report. The Member reported that she had recently taken the opportunity to walk the streets of the surrounding area and had spent time sitting in Salisbury Square. She stated that she liked the fact that these proposals were for three separate buildings that, whilst very large, were still of a size she felt able to relate to and were of good architectural quality with no gimmicks. The Member added that she felt that the buildings proposed respected the streetscape and would fit well into the surrounding streets. She stated that her overriding feeling about the proposal was one of excitement and she was of the view that the area would be immensely enhanced by this development which she would be happy to approve. The Interim Chief Planning Officer and Development Director clarified that no listed buildings would be demolished under these proposals, only alterations to 7 Salisbury Court. Demolition would, however, affect buildings within the Conservation Area, all of which had a certificate of immunity from listing.
A Member commented that she was struck by the comments from the City’s Access Team which seemed to be buried at the back of this report and highlighted a number of concerns where disabled access would be hindered due to door sizes or steps and had also commented on disabled toilets not being accessible. The Member added that she had also noted that the roof terrace on the court building had a very low balustrade whereas the police and the commercial buildings had very high balustrades. She therefore questioned whether things such as disabled access/provision, health impact and suicide risk had been taken into account in terms of design and why this had not been picked up at an earlier stage by Officers. She questioned whether Officers would ensure that the buildings were fully accessible to disabled users and that the roof terraces mitigated against any suicide risks. The Interim Chief Planning Officer and Development Director assured Members that access was embedded in the development of this scheme from the very outset with paragraph 754 of the report setting out how various access issues had been addressed. He added that the City’s Access Officer was content with the scheme and that the only point of omission was an inability to provide changing facilities within the police building. Aside from this, access was deemed to be acceptable. Similarly, it was reported that suicide prevention had been a key part of the scheme from the outset and that this would be developed further in terms of the landscaping of the roof terraces to minimise any risks.
Another Member reported that he had recently spent time walking around the area and felt that the existing public realm here was not pleasant. He added that he was fully supportive of this application and noted that the report suggested that there would be ground source heat pumps installed using six, 200 meter deep, wells which he felt was more akin to geothermal wells - something that he believed was a first for the City, was highly commendable and a ground breaking way of creating green energy. He added that, if this were a success, he would like to see this approach emulated with future developments.
A Member noted that the issues around destroying City heritage in both the buildings in the Fleet Street Conservation Area and the historic alleyways had already been aired as had the fact that retail space would be lost and two-thirds of office space which was in contravention of the City’s own policy. She went on to note that this development was being presented as ‘landmark’, was developed by the Corporation and should at least meet its own sustainable planning criteria. Instead, the report stated that the complex was only aiming to achieve a BREEAM rating of ‘excellent’ when developers were always asked to aim for ‘outstanding’. She went on to state that the complex failed the London Plan for whole life cycle carbon emissions and that the Corporation, whose own Climate Action Strategy aimed to achieve net carbon emissions for its own operations by 2027, would be making the carbon offsetting contribution to the shortfall against the London Plan targets – something which she believed was totally against the Corporation’s strategy. The Member concluded by stating that the thing that she found most disappointing was the design of the court building which she felt resembled a municipal building from the last century and was a lost opportunity to create a building showing the City’s vision for the modern, transparent, outward-looking legal justice system. She noted that Manchester had led the way on this in 2008 with an international, award-winning Criminal Justice Centre which was a public building where the functions were legible. She commented that the bland building proposed under these plans did nothing to enhance the wonderfully rich and eclectic mix of Fleet Street buildings. She stated that she was saddened to see that the application that the Corporation itself had submitted failed in so many ways to meet the requirements of the London Plan and its own London Plan, showed a total disregard for heritage and showed no vision or leadership in the development of the City. She added that she totally understood the need for new courts and police headquarters but felt that this scheme did not provide what it ought to.
Another Member stated that he understood that the Fleet Street quarter had struggled for some time now to recreate its identity and he felt that, from this holistic perspective, this complex would actually add a lot of value and could act as a cornerstone for this area going forward. With regard to the specifics of the buildings and applications themselves, he reported that he too had read quite a lot of concern around the green and climate aspects of these buildings and that, in discussion with Officers during previous presentations, his understanding had been that the BREEAM ‘excellent’ rating as opposed to ‘outstanding’ was around the operational and technical use of the buildings. He added that, to his mind, this was countered by the operational footprint of the building – for example the heating systems that were being employed and some of the efficiencies around the use of green cement – which all helped in the overall greening/climate impact of this complex. He concluded that he was therefore supportive of this application.
A Member stated that he found it interesting that the report conceded that there would be a major adverse impact on some of the neighbouring residential properties in terms of loss of light but concluded that this loss was acceptable because it would be balanced by an increase in sunlight to Salisbury Square. He stated that, whilst this may be so, no one lived in the Square and therefore failed to see the connection between the two. Despite this, the report not only treated these situations as comparable but used them to recommend the approval of the applications. The Member went on to remind the Committee that an expert consultant had briefed them on the mater of daylight/sunlight and had also recommended the adoption of radiance studies to better understand this complex issue and better assess any loss of light. He stated that he found it very disappointing that Officers had not used this approach in evaluating this City of London Corporation application.
Another Member commented that he had listened very carefully to the debate and broadly supported the objectives of this scheme. Nevertheless, he stated that he was still concerned as to the look and feel of this development on Fleet Street and its bulk. He questioned whether the Interim Chief Planning Officer could talk the Committee through his interpretation of what the Member described as the very bulky, fortress like façade proposed for Fleet Street. The Interim Chief Planning Officer and Development Director commented that whilst this was not ideal, Officers were very mindful of the high-level security advice offered by the courts building in terms of the need for it to be safe and secure and so it had been decided with the applicant team that making the building more eye-catching and incorporating large pieces of artwork on this elevation would lend a level of enlivenment to the frontage. As previously explained by the architect, this would not be at ground floor level only, but also on other levels of the building. In addition, measures required on street for security could also incorporate artwork.
Another Member stated that she was concerned that the fact that a number of buildings that enhanced and were of benefit to the conservation area were to be demolished as part of these plans had been brushed over. She added that the destruction of 1 Salisbury Square simply because it had been rebuilt in 1961 due to bomb damage was also glossed over. The Member went on to state that she also felt that the court building on Fleet Street was very overbearing and deflected from the conservation area. She also felt that it was a shame that the brief here had been condensed and was of the view that, if the key element of the brief – providing a court and police building only – had been focused in on, it could have been accommodated on this site without the proposed demolition of these buildings. The Member concluded by stating that she was disappointed to have seen such an unbalanced presentation from the Chief Planning Officer on this, particularly given that the City Corporation was the applicant.
A Member spoke to state that she found this a very difficult application to decide upon. She felt that it was very important that Fleet Street was given the opportunity to have greater vibrancy but also felt that it was regrettable that these frontages would be lost. She went on to note that there was a lot of reference, particularly from HMCTS, to the brief being tight and she felt that this had not been sufficiently thought through such that the benefits that could have been achieved had not necessarily been attained. She concluded by noting that the backlog of court cases had sat at 40,000 prior to the pandemic and that it would therefore be difficult to suggest that this would not therefore continue long into the future.
The Committee then proceeded to vote on the recommendations before them within this report. The vote was conducted by rollcall led by the Town Clerk with those Members present and eligible to vote asked to also confirm that they had been present for and able to hear the entirety of this item. Members were reminded that they were voting on this and two separate but interrelated applications which featured at agenda items 3a and 3b respectively.
Votes were cast as follows: IN FAVOUR – 12 Votes
OPPOSED – 4 Votes*.
There were two abstentions.
*In accordance with Standing Order No. 38, some of those Members who had voted against the recommendation asked that their names be recorded in the minutes – they were Marianne Fredericks and Graeme Harrower.
RESOLVED – That planning permission be GRANTED for the above proposal in accordance with the details set out in the attached schedule subject to:
(a) The application be referred to the Mayor of London to decide whether to allow the Corporation to grant planning permission as recommended, or to direct refusal, or to determine the application himself (Article 5 (1)(a) of the Town & Country Planning (Mayor of London) Order 2008);
(b) The City as landowner giving a commitment (through a resolution or delegated decision) that it will comply with the planning obligations in connection with the development (and that it will ensure that the obligations are binding on any future purchaser or development partner) and a Unilateral Undertaking being signed in respect of those matters set out in the report, the decision notice not to be issued until the commitment/resolution has been given and a Unilateral Undertaking has been signed.
2. That you agree in principle that the land affected by the proposal which is currently public highway and land over which the public have right of access (comprising areas of Hanging Sword Alley and Hood Court, small areas of Salisbury Square and the land connecting Salisbury Square to Primrose Hill that would be built upon if the development was implemented) may be stopped up to enable the development to proceed and, upon receipt of the formal application, officers be instructed to proceed with arrangements for advertising and making of a Stopping-up Order for the various areas under the delegation arrangements approved by the Court of Common Council.
3. That your Officers be instructed to negotiate the unilateral undertaking.
4. That your Officers be authorised to provide the information required by regulations 29 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017, and to inform the public and the Secretary of State as required by regulation 30 of those regulations.