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Strategic Policy S8: Design
The City Corporation will promote innovative, sustainable and inclusive high quality buildings, streets and spaces. Design solutions should make effective use of limited land and contribute towards vibrancy, inclusion, wellbeing and a greener, net zero carbon City, through development that:
Sustainable design
1. Takes a ‘retrofit first’ approach, prioritising the retention and retrofit of existing buildings, informed by an appraisal of the development options;
2. Seeks opportunities to refurbish existing buildings, improving their environmental performance;
3. Minimises whole life-cycle carbon and contributes towards a net zero carbon City;
4. Delivers world class sustainable buildings that are adaptable and informed by circular economy principles and that treat materials as a resource;
5. Embeds climate resilience into design and contributes to the resilience of the Square Mile; and
6. Seeks opportunities to contribute to the wider sustainability of the City and (where relevant) neighbouring boroughs, especially where development would result in substantial carbon emissions.
Form and Layout
7. Optimises site capacity, informed by the character of the area and its potential for growth;
8. Delivers buildings and spaces that have the right scale, massing, built form and layout, with due regard to the existing and emerging urban structure, building types, form and proportions identified in the Character Areas Study;
9. Optimises pedestrian movement by maximising permeability, providing external and where feasible internal pedestrian routes which are inclusive, welcoming, convenient, comfortable and attractive, enhancing the City’s characteristic network of accessible buildings, streets, courts and alleys; and
10. Is pedestrian-focused, reducing conflict between pedestrian and vehicular traffic, creating a safe and attractive public realm, prioritising pedestrians and cyclists, whilst mitigating the impact of building servicing;
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Experience
11. Provides an appropriate mix of uses that contribute to the creation of a vibrant City;
12. Places people at the heart of design, creating buildings and spaces with a strong sense of belonging;
13. Optimises microclimatic conditions, addressing solar glare, daylight and sunlight, wind conditions and thermal comfort and delivers improvements in air quality, open space and views;
14. Delivers street level building frontages which are active, public-facing, usable, permeable, interesting, well-detailed and appropriately lit, delivering suitable levels of passive surveillance;
15. Optimises the amount and connectivity of green infrastructure and, biodiversity and public amenity space and urban greening, and provides these in ways that are integral to the architecture and site design;
16. Delivers inclusive buildings, streets and spaces that meet the access needs of all the City’s communities irrespective of background or circumstance;
17. Delivers publicly accessible space within the development by maximising the amount of accessible, inclusive and free to enter open spaces, roof terraces, cultural offers and other spaces, including in tall buildings and along the river and around City landmarks;
18. Supports health and wellbeing within the City’s communities; and
19. Is informed by early and meaningful stakeholder engagement, proportionate to the scale and type of development proposed.
Quality and character
20. Delivers high quality design, which is visually interesting, wellproportioned and well-detailed and conserves and enhances the townscape character and appearance of the City, and its historic environment, and takes into account cross boundary impacts of the neighbouring boroughs;
21. Incorporates sustainability measures and other plant and building services into a coherent architectural design;
22. Considers lighting as an integral part of the design process, ensuring that internal and external lighting provides the right light in the right place at the right time;
23. Incorporates signage of an appropriate siting, size, form, appearance and illumination within the building’s architecture;
24. Incorporates necessary security and safety measures as an integral part of the design; and
25. Ensures that the building design concept is maintained from permission through to completion of a project.
Reason for the policy
9.1.0 As a world leading financial and professional services centre, with many important heritage assets and high quality buildings, the City requires world leading design in all aspects of the built environment, including the sustainability of new and refurbished buildings. Business occupiers are seeking buildings that are designed with high sustainability, accessibility and inclusion, and wellness credentials, and for these to be reflected in the appearance, functioning and design of buildings and their relationship to the wider context.
9.1.1 The built environment is a major contributor to carbon emissions. Development should not only seek to minimise emissions but also find opportunities to improve wider sustainability. Retrofitting existing buildings will in many cases result in lower whole lifecycle carbon emissions (in total, and per square metre) than demolishing and redeveloping sites, and helps to minimise the use of materials. As our climate changes, development must play a role in helping to make the City more resilient to extreme weather conditions and the impact of changing climatic conditions.
9.1.2 Development has a significant role to play in enhancing the public life of the Square Mile and making it more welcoming for everyone through delivering inclusive and accessible public spaces, vibrancy, destinations, experiences and leisure opportunities as an integral part of new development.
How the policy works
9.1.3 The design approach to each site in the City will be unique and there is a need to consider a broad range of factors through an iterative design process. While sites won’t share a singular route through the design process, this City Plan places significant importance on achieving sustainable development through a ‘retrofit first’ approach. An understanding of the potential for retaining and retrofitting existing buildings should therefore be the starting point for appraising site options, alongside a robust analysis of the whole lifecycle carbon of different development approaches.
9.1.4 Options appraisals should also be informed by the potential for wider environmental benefits before considering the many wider design and planning matters set out in this policy and other policies throughout the Plan, and using this work to inform the design of the proposed scheme.
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Policy DE1: Sustainable Design
1. Development proposals should follow a retrofit first approach, thoroughly exploring the potential for retaining and retrofitting existing buildings as the starting point for appraising site options.
2. All major development must undertake an assessment of the options for the site, in line with the City Corporation’s Carbon Options Guidance Planning Advice Note, and should use this process to establish the most sustainable and suitable approach for the site.
3. Development proposals should minimise whole life-cycle carbon emissions. Major developments must submit a whole life-cycle carbon assessment.
4. Where new buildings are the most sustainable and suitable approach, they should deliver exemplar low carbon development and the highest environmental sustainability quality, driving forward best practice beyond standard approaches and contributing to wider sustainability improvements in the area.
5. Innovative design, materials, construction, and technologies should be used to deliver highest standards of environmental sustainability.
6. Applicants must ensure that measures to improve environmental performance and mitigate and adapt to climate change have been integrated into the design.
Circular economy design approaches
7. Development should be designed to incorporate circular economy principles throughout the life cycle of the building through:
a. Flexible building design to accommodate evolving working and living patterns, reducing the need for redevelopment;
b. Floorspace adaptability to maximise the lifespan of buildings;
c. Reuse, refurbishment and retention of existing buildings, structures and materials to reduce reliance on virgin resources;
d. Designing for disassembly, reuse and recycling of deconstruction materials;
e. Maximum use of recycled materials in development and off-site construction methods to reduce wastage; and
f. Designs which enable durability, modularity, sharing of goods and services and reuse of supplies and equipment, minimising waste during the building’s operational phase.
Sustainability standards
8. Proposals for major development will be required to:
a. Achieve a minimum BREEAM rating of “excellent” and aim for “outstanding” against the current, relevant BREEAM criteria at the time of application, obtaining maximum credits for the City’s priorities (energy, water, materials, waste and pollution). Climate resilience credit should be achieved for the waste category;
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b. Commit to achieving a minimum NABERS UK rating of 5 stars;
c. Demonstrate that London Plan guidance on carbon emissions and air quality requirements have been met on site. In exceptional circumstances, where standards cannot be met on site, carbon offsetting will be required to account for the shortfall. This will be secured through a S106 agreement with offsetting contributions ring fenced for carbon reduction projects;
d. Retain existing buildings and structures where feasible to reduce embodied carbon emissions and waste;
e. Demonstrate climate resilience in building and landscape design;
f. Incorporate collective infrastructure such as heating and cooling networks, smart grids and collective renewable energy storage (for example batteries) wherever possible, to contribute to a net zero carbon, zero-waste, climate resilient City; and
g. Prioritise the objectives of the City of London Local Area Energy Plan (LAEP) to create or link into local energy networks and waste heat sources, and include opportunities for heat and cooling transfer to/from nearby developments.

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Reason for the policy
9.2.0 The factors driving sustainable development are increasing, impacting both global and local businesses as well as workers, residents and visitors. The pace and prestigious nature of development in the City presents opportunities to incorporate innovative design in both new and existing buildings to provide positive environmental outcomes for the City’s priorities:
X Energy, carbon emissions and air pollutants – reducing emissions and moving to a net zero carbon City by 2040, in line with the requirements of the City Corporation’s Climate Action Strategy;
X Water – reducing water use in an area of serious water stress;
X Pollution – reducing exposure to poor air quality;
X Materials – retaining embodied carbon in existing buildings and materials, and improving resource efficiency.
9.2.1 Social and environmental responsibility is high on the agenda for many City businesses and their workforce and a working environment that supports these goals is essential for the City’s future.
9.2.2 The City of London Climate Action Strategy provides evidence for the trajectory to a net zero carbon City by 2040. The role of collective infrastructures such as smart grids, battery storage, heating and cooling networks and hydrogen infrastructure are essential elements in the delivery of the net zero carbon City, where decarbonised electricity that does not contribute to future

local levels of pollution, is the main energy source. Heating and cooling networks will increasingly exploit low carbon energy from waste heat and heat pump technologies rather than fossil fuels and contribute to reductions in primary energy demand, carbon emissions and nitrous oxides. Therefore, connection to these networks is expected wherever feasible. This will also reduce the need for roof top installations such as boiler flues, cooling towers and plant rooms.
9.2.3 As new developments are large consumers of resources and materials, the possibility of sensitively refurbishing or retrofitting buildings should be considered in preference to demolition. Proposals for substantial demolition and reconstruction should have regard to the whole-life carbon impact, resource and energy use, when compared to the existing building, and must justify why redevelopment and new build is the most sustainable and suitable approach. All development should ensure the reduction, reuse or recycling of resources and materials, and minimise energy use and emissions that contribute to climate change.
9.2.4 The application of sustainability standards through this Plan will contribute to the achievement of the objectives of the City’s Climate Action Strategy, however, guidance in the area of sustainable development is rapidly evolving and applicants should use the most up to date guidance to inform their planning proposals.
9.2.5 The circular economy is an alternative to the typical ‘linear’ way of treating resources. By finding ways of remanufacturing, reusing or recycling materials and keeping them in use for longer, waste can be reduced. The circular economy emphasises design for
durability and modularity, making better use of under-used assets through sharing and offering products as a service. Circular economy principles can be applied to buildings and the development cycle, reducing the demand for new materials, and to the operational phase of a building’s life to minimise annual waste arisings.
How the policy works
9.2.6 The approach to retention and/or redevelopment, built form, whole life-cycle carbon and circular economy for the development should be shaped on the basis of the insights derived from the carbon options assessment. Applicants should work collaboratively through the carbon options process to establish the most sustainable and suitable approach for the site. Applicants should demonstrate that they have taken into account principles of sustainable design and that measures to improve environmental performance and mitigate and adapt to climate change have been integrated into the design.
9.2.7 The requirement for the highest feasible and viable sustainability standards applies to all development in the City, including major new development, extensions to existing buildings, major refurbishments and minor development. Refurbishments of existing buildings are subject to this policy where proposed works constitute development.
9.2.8 Sustainability Statements should be used to provide comprehensive evidence of the sustainability of each development.
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9.2.9 For major development the following information should be provided:
X A BREEAM pre-assessment or design stage assessment including a summary of the credits to be targeted in each category. Planning conditions will be used to require submission of a post construction BREEAM certificate to demonstrate implementation of the approved designs, achievement of the City’s priority credits and identify any performance gaps between design and completed development.
X An energy assessment in line with the Mayor of London’s Energy Planning Guidance.
X An options appraisal following the City Corporation’s Carbon Options Guidance Planning Advice Note to develop a low carbon solution that optimises social, economic and environmental sustainability benefits.
X An air quality assessment to meet the requirements of the London Plan demonstrating that the development will not result in deterioration in air quality, in line with the City of London Air Quality SPD.
X Details of the proposed adaptation and resilience measures to make the building resilient to the climate and weather patterns it will encounter during its lifespan.
X Details of collective infrastructure which has been incorporated to address environmental challenges.

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X Whole life cycle (WLC) carbon assessments in line with the London Plan Guidance and City Corporation’s Carbon Options Guidance Planning Advice Note, fully exploring opportunities to minimise embodied and operational carbon emissions.
Extensions
X If a development proposal includes an extension greater than 25% of the existing floorspace or consists of a distinct structure greater than 1,000sq.m, the extension on its own should be treated as a major development and assessed accordingly, including consideration of London Plan carbon emission targets, carbon options appraisal and BREEAM requirements.
For minor development
X Although minor development may provide more limited opportunities for the incorporation of sustainability features it is important that sustainability is considered at the design stage for all projects. For most minor development inclusion of sustainability information in the Design and Access Statement will suffice.
Circular design approaches
EIA development
9.2.10 For development that requires an Environmental Impact Assessment (EIA) the Environmental Statement should demonstrate how circular economy principles have been incorporated into the development, fully addressing how Construction, Demolition and Excavation (CD&E) waste will be
minimised, deconstruction materials will be reused or recycled and the waste arisings during the operational phase of the development will be minimised and managed. This should include consideration of on-site facilities to reduce the need for waste vehicle movements such as on-site composting or anaerobic digestion, or waste consolidation.
9.2.11 A Circular Economy Statement and the WLC carbon assessment following the London Plan guidance should be submitted for all EIA development.
Major development
9.2.12 For all other Major development proposals, the Sustainability Statement should provide evidence of the application of circular economy principles and the adherence to the waste hierarchy. This could include reuse of existing buildings and structures, provision of Site Waste Management Strategies for the construction phase and Zero Waste Plans for the operational stage of the development. Major development should aim to achieve maximum BREEAM credits for Waste.
9.2.13 A Circular Economy Statement following the London Plan guidance should be submitted for all Major development.
All other development
9.2.14 For all other development, the Design and Access statement should demonstrate how waste minimisation and the circular economy have been considered in the design of the development.
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Policy DE2: Design Quality
1. Development should be of an exemplar standard of design, aesthetics and architectural detail and should enhance the townscape and public realm. Development that would adversely affect the character, appearance or amenities of the buildings or area will be resisted.
2. The design of new development must ensure that:
a. The layout, form, scale, massing and appearance of schemes are appropriate in relation to their surroundings and have due regard to the scale, height, building lines, character, historic interest and significance, urban grain and materials of the locality and relate well to the character of the area;
b. The site layout takes account of established and potential pedestrian desire lines enhancing pedestrian permeability;
c. Buildings and public spaces are inclusive and accessible for everyone;
d. The architecture and urban design function well, are visually attractive with high quality detailing, finishes and materials, and enrich the overall quality of the area for the long term;
e. Elevations have active, engaging and welcoming street frontages;
f. The development incorporates high quality landscape design and maximises opportunities for greening, biodiversity and public realm improvements;
g. Innovative design approaches are used to create high quality buildings that meet high sustainability standards, and integrate well with the surroundings;
h. It is constructed using appropriate, high quality, low carbon, sustainable and durable materials;
i. It avoids unacceptable wind, loss of daylight and sunlight and thermal comfort impacts at street level or intrusive solar glare impacts on the surrounding townscape and public realm;
j. The proposed uses and activities are accommodated within the curtilage of the development and do not rely on use of the public realm, including the use of public highway;
k. The plant and building services equipment are fully screened from view and integrated into the design of the building such that there are no adverse impacts on amenity in surrounding areas;
l. The form, profile and appearance of the roofscape adds visual interest and complements the building.
3. Applicants will be encouraged to undertake meaningful developer-led engagement before submitting their planning application in line with the City Corporation’s Developer Engagement Guidance;
4. Applicants will be required to provide digital 3D visualisations of their developments in an open source or other format compatible with the City Corporation’s 3D digital modelling technology. These visualisations should be used to inform pre-application and post application consultation with local communities and stakeholders.
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5. Applicants will be required to ensure the quality of the approved development is not materially diminished between permission and completion as a result of changes to the permitted to scheme.
Reason for the policy
9.3.0 Buildings and spaces around buildings affect us all – they are where we live, work and spend our leisure time; they shape our experiences as we spend time in them and move around them. Therefore central to delivering the right kind of growth, it is important to ensure that buildings are of high quality design;
9.3.1 Given the exceptional quality of the City’s built environment, it’s essential for new developments to capture and enhance the qualities and characteristics that make it a special place; The network of routes and spaces, the scale, form, architectural expression and detailed design of buildings, together with the use of particular building materials, and the contribution of these elements to the composition of street blocks are all characteristic of, and combine to produce, the close-knit and intricate townscape of the City. It is important that new buildings and alterations respect and reinforce this general character. The City has dynamic, striking and internationally acclaimed architecture as well as more contextual buildings appropriate to their townscape setting.
How the policy works
9.3.2 This policy expects applicants to approach the design of new buildings, extensions or modifications to existing buildings in an interesting, innovative and appropriate manner. Whilst no particular architectural style is encouraged, the expectation is that every scheme should be of the highest quality meeting the requirements set out in this policy and should be based
on a sound understanding of the site and its context. A series of key characteristic features have been identified in the City’s Character Areas Study, which should be applied to understand the underlying character of the different areas of the City. In assessing development proposals, careful consideration will be given to the scale, form, massing, appearance and those distinctive features that contribute to the area’s unique identity and local character.
9.3.3 Good design is a key aspect for creating places, buildings or spaces that work well for everyone, look good, last long and can adapt to the changing needs of future generations. Making the right choices at all levels of the design process is therefore very important. The development proposals will be required to clearly articulate the design evolution from the conceptual stage to the final product. This narrative should be set out in the Design and Access Statement and should address the key design aspects outlined in the National Design Guidance:
X the layout
X the form
X the scale of buildings
X their appearance
X landscape
X materials
X their detailing
9.3.4 Wind conditions and solar glare may have an adverse effect on the surrounding townscape and the quality and use of the public realm. Assessments will need to be carried out on the impact of proposed development on wind conditions, thermal comfort and solar glare. Any adverse impacts should be minimised and unavoidable impacts will need to be mitigated. Appropriate measures to achieve this should be integrated into the design of the development. The City Corporation has published guidelines for developers on wind microclimate studies required to support planning applications. Further guidance is available on solar glare, solar convergence and daylight and sunlight impacts of development.
9.3.5 The design and implementation of building extensions and alterations, such as entrances and windows, are important because they have a cumulative effect on the overall character and appearance of the City. Extensions or alterations should be considered in relation to the architectural character of the building, designed to minimise their impact and integrated into the design of the building. Alterations and extensions should achieve a successful design relationship with their surroundings, taking full account of the local context and the setting of the building.
9.3.6 In most buildings, the ground floor elevation has the most effect on public amenity, so its design should be given particular attention to ensure that it is legible, visually attractive and provides active frontages. Blank frontages and ventilation louvres should be avoided. Ventilation louvres, where necessary, should be located away from busy streets.
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9.3.7 Plant should be located below ground. Where this is not feasible, it should be satisfactorily integrated into the form and design of the roof. It should be enclosed and covered where it would otherwise harm the appearance of the building, the general scene, or views from other buildings. Intake points should be located away from existing and potential pollution sources (e.g. busy roads and combustion flues). All combustion flues should terminate above the roof height of the tallest building in the development to ensure maximum dispersion of pollutants.
9.3.8 Servicing entrances can have a detrimental impact on the appearance of the building and its immediate setting and can harm otherwise attractive pedestrian routes. The City Corporation expects innovative design solutions for servicing entrances and adjacent areas to minimise their visual impact and to enable them to be integrated into the design of the building. Design solutions must respect the sensitive nature of listed buildings and conservation areas.
9.3.9 Ventilation or extraction systems should be routed internally, and extensive or unsightly external ducting will not normally be permitted. Provision must be made within the building for services and ducting to and from all uses. Ventilation systems in new build premises for extracting and dispersing any emissions and cooking smells must be discharged at roof level and designed, installed, operated and maintained in accordance with manufacturer’s specification in order to prevent smells and emissions adversely affecting neighbours. For changes of use, developers and/or occupiers should investigate the potential
to vent emissions to the roof. Developers should provide suitable rooftop ventilation, where appropriate. Where it can be demonstrated that venting of such emissions to the roof is not practical, venting to an adjacent footway will only be acceptable where the extraction system is of the highest specification for odour abatement and there is no adverse impact on neighbours by virtue of smells or other emissions. Other ventilation louvres should not be sited by adjoining footways.
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Policy DE3: Public Realm
The City Corporation will work in partnership with developers, Transport for London and Business Improvement Districts (BIDs), and other key stakeholders to design and implement schemes for the enhancement of streets and spaces and the creation of new spaces including public squares, parks, open spaces, viewing galleries, rooftops, forecourts, streets, courts, alleyways, routes and spaces between buildings.
Public Realm Design
Public realm schemes, must have regard to:
1. The need to provide high quality, inclusive, welcoming, well designed, safe, and functional public realm that takes into account how people will use the space;
2. The wellbeing of users ensuring appropriate shade and shelter, provision of areas with access to direct sunlight and taking into consideration microclimatic conditions including temperature, wind, exposure to noise, air pollution to create places that encourage people to dwell and spend time;
3. The predominant use and function of the space and adjacent spaces;
4. The use of sustainable natural and high quality materials, avoiding an excessive range whilst harmonising the proposals with the surroundings and the materials used throughout the City;
5. The need to increase the provision of green infrastructure, including tree planting, urban greening, soft landscaping and the delivery of net gains in biodiversity, and to link up existing habitats, green spaces and routes to provide green corridors;
6. The City’s heritage, identifying, and retaining, and better revealing features that contribute positively to the character, cultural and leisure experience and appearance of the City;
7. The need to integrate high quality public art as part of the public realm design;
8. The provision of sustainable drainage, where feasible, coordinating the design with adjacent buildings to facilitate rainwater management;
9. The need to improve pedestrian amenity, ensuring that streets and walkways remain uncluttered and encourage walking, cycling and wheeling;
10. The promotion of active travel, delivering interventions which improve the design of streets and spaces for pedestrians and cyclists in line with the Healthy Streets Approach;
11. The sensitive co-ordination of lighting with the overall design of the scheme;
12. The need to provide public amenities including seating and free water drinking fountains.
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Inclusive and Accessible Public Realm
The public realm should be welcoming, inclusive and accessible to all; it should be free to use and access.
Development proposals should:
1. Provide inclusive and accessible public realm that meets the existing and future needs of all user groups;
2. Ensure public spaces are open, welcoming, inclusive, free to use, and fully publicly accessible and that appropriate management and operational arrangements are in place. Where the development creates new public realm or affects the use of existing public ream, it should be ensured that public access to the space is maximised and the rules governing the space are minimised to those required for its safe management, in accordance with the Mayor of London’s Public London Charter. A Management Plan should be provided setting out how the space will be used and managed at different times of the day and different days of the week.
3. Ensure public spaces are free to use and access and align with the principles contained in the Mayor’s Public London Charter; any restrictions to public access will only be allowed in exceptional circumstances, subject to a legal agreement and should be the minimum necessary, appropriate and reasonable.

Reason for the policy
9.4.0 The City of London is a dense urban environment, with a limited amount of public realm. Most streets and public spaces accommodate a high level of pedestrian footfall and perform a variety of functions above and beyond accommodating the movement of people. The City’s streets and public spaces are where public life takes place, where workers, residents and visitors experience the City as a whole. Given the limited amount of space available at ground floor level in the City, public realm proposals must make effective use of the constrained land resource and be of the highest design quality, maximising benefits for the public.
9.4.1 To attract a greater and more diverse range of people to the city at different times of the day and on different days of the week, the design of the public realm must cater for a wide variety of requirements. The management and curation of the public realm influences how it is used and its appeals to different user groups. Management and maintenance of public space should be limited to minimise rules governing public spaces to avoid management regimes being implemented that set unnecessary rules for how people should behave. Whether publicly or privately owned, public realm should be open, free to use, welcoming and offer the highest level of public access. These spaces should only have rules restricting the behaviour of the public that are essential for safe management of the space.
9.4.2 High quality natural materials are characteristic of the City of London and add greatly to the character and identity of streets, courts and spaces. Wherever possible, the City Corporation will retain these surface materials and will carry out repairs to match and extend their use. Elsewhere, the City Corporation will encourage a limited palette of materials, providing continuity in the streetscape, and ease of access through the City.
How the policy works
9.4.3 The City Corporation will actively promote schemes for the enhancement of the public realm in accordance with the Healthy Streets Approach, the Mayor of London’s Public London Charter, the Mayor of London’s Streetscape Guidance, the City of London Public Realm SPD, the City of London Public Realm Toolkit, the City of London Transport Strategy and the Climate Action Strategy.
9.4.4 Developers will be required to demonstrate that public realm enhancements will improve the function and appearance of the space. An assessment will be required to demonstrate how the development will function in terms of the use of the public space, pedestrian desire lines, and potential congestion or conflict, and what public realm enhancements will be required to deliver a functional, inclusive, accessible, safe and attractive public space.
9.4.5 Public realm design should follow best practice place-making principles, by creating site layouts that positively respond to the context and microclimatic conditions, and using materials that harmonise spaces. Development proposals that deliver new or improved high quality public space will be encouraged
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and the provision of outdoor public space at ground level will be prioritised. There will be a particular focus on creating new routes and spaces that link the public realm network, connect key destinations in the City, and provide attractive walking and cycling routes and public spaces. These spaces should encourage people to dwell and spend time, and provide amenity for people’s health and well-being.
9.4.6 The provision of tree planting will be encouraged to improve climate resilience, provide shade and visual amenity. It should be ensured that tree planting is feasible with below ground constraints.
9.4.7 A draft public realm management plan must be provided at the pre-application stage, outlining how the public realm will be designed and managed in accordance with the London Plan and the Public London Charter principles. Public realm management plans will be secured through s106 agreements. These plans should ensure that the design, and management regime that govern public spaces maximises public accessibility and supports the requirements of this policy. It should demonstrate how the public space will operate and be managed at different times of the day, and at different times of the week.
9.4.8 Through site analysis and public engagement, developers should identify existing uses and users of public space and develop proposals that support and encourage the existing and future use of the space, while seeking to ensure public spaces are inclusive and accessible for all.
9.4.9 Further information on design requirements for the public realm is available in the City Public Realm SPD, the City Public Realm Technical Manual, Conservation Area Character Summaries and Management Strategies, where appropriate, the Mayor of London’s Streetscape Guidance and the Public London Charter.
9.4.10 The City Corporation will undertake public realm enhancement works through specifically targeted projects or in association with general street maintenance and vehicle, cycle and pedestrian traffic management schemes. The City Corporation will use s106 planning obligations, s278 highways contributions, the Community Infrastructure Levy and funding from external sources to deliver enhancement works.
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Policy DE4: Terraces and Elevated Public Spaces
1. Roof terraces will be encouraged where:
a. The roof terrace is visually integrated into the overall design of the building when seen from both street level and elevated viewpoints;
b. There would be no immediate overlooking of residential premises, unacceptable disturbance from noise or other significantly adverse impacts on residential amenity. Where there is a potential for a significantly adverse impact, the use of an extensive green roof and a restriction on access should be considered as an alternative;
c. Historic or locally distinctive roof forms, features or structures can be retained and enhanced;
d. There would be no adverse impact on protected views;
e. The design and layout of the terrace optimises the potential for urban greening;
f. Emissions from combustion plant will not affect users of the terrace.
2. Where roof terraces and elevated public spaces are proposed, safety and security risks must be addressed at the design stage and space for security checks and any hostile vehicle mitigation incorporated into the development, where required.
3. Requiring all tall buildings or major developments to provide free to enter, publicly accessible elevated spaces, which may include roof gardens, terraces, public viewing galleries, or other retail or leisure facilities to create attractive destinations for people to enjoy the City’s spectacular skyline and views.

Reason for the policy
9.5.0 Roof gardens and terraces are becoming increasingly common in the City, in response to demand from developers and occupiers. Public and private roof gardens and terraces present an opportunity for additional amenity space, urban greenery and the creation of new viewpoints of the City and the surrounding areas, thereby reinforcing London’s cultural and historic attractions.
How the policy works
9.5.1 The City Corporation encourages proposals for roof gardens and terraces where they are sympathetic to existing roof forms and features, particularly those of historic interest or which are otherwise locally distinctive and where they do not impact adversely on residential amenity. There should be no impact on strategic or locally protected views.
9.5.2 Where roof terraces and gardens are publicly accessible, entrances should not result in safety or security concerns, create congestion or adversely impact on the environmental quality at street level. Security implications should be considered at the design stage of the development, including making provision for security checks within the development and hostile vehicle mitigation, where required. Opening hours may be managed by condition or agreement, particularly where there are residential premises nearby. Roof terraces should not significantly increase noise levels or result in unacceptable light spillage in areas with residents or other sensitive uses. Appropriate safety features should be included to reduce the potential for suicide or falling
from buildings. The City Corporation has adopted a Planning Advice Note on Preventing Suicides in High Rise Buildings and Structures to advise developers on best practice to reduce the potential for suicides from tall buildings. The positioning of combustion flues should be carefully considered so as to not expose users of the roof terrace to pollution emissions from combustion plant.
9.5.3 Public access to tall buildings within the City is important in creating an inclusive city. Tall buildings should provide publicly accessible, step-free areas that are free to enter and inclusively designed. These may include public viewing galleries at upper levels or other forms of open space provision and may provide retail, leisure or educational facilities to enhance their attraction, where this would not undermine the inclusivity of the space.
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Policy DE5: Shopfronts
Shopfronts should be of a high standard of design and appearance to create an attractive and welcoming retail and leisure experience on City streets. Inappropriate designs and alterations will be resisted. Shopfront proposals should:
1. Help to create active frontages, designed in ways that facilitate the visual and physical permeability of the building;
2. Respect the quality and architectural contribution of any existing shopfront;
3. Maintain the relationship between the shopfront, any fascia, the building and its context;
4. Use materials which are sympathetic to the wider context and are of high quality;
5. Ensure that signage is in appropriate locations and in proportion to the shopfront;
6. Take into account the impact of louvres, plant and access to refuse storage;
7. Consider the potential to use awnings and canopies to provide shade and mitigate against adverse climate impacts. Where they are provided, they should not harm the appearance of the shopfront, obstruct architectural features or views and should be in compliance with highway requirements;
8. Avoid external shutters and contain alternative security measures, where required;
9. Avoid opaque windows and provide retail displays which encourage browsing and passive surveillance;
10. Ensure that the design is inclusive incorporating level entrances and adequate door widths; and

11. Ensure that internal shop lighting does not create inappropriate light spillage into the public realm.
Reason for the policy
9.6.0 Shopfronts are important elements in the townscape and can contribute significantly to the street scene. The design of a shopfront should recognise this and be appropriate to, or enhance, the building and its location. It should respect the design of the building and not obscure, or result in damage to, existing architectural features.
9.6.1 Existing shopfronts should be retained where they contribute to the appearance or special interest of a building or the street scene, particularly in listed buildings or conservation areas, or those that are of design or historic significance in their own right or as part of a group. Any modifications necessary should be sympathetic to the original design.
How the policy works
9.6.2 New shopfront proposals should relate to the upper floors of the building and surrounding buildings, providing consistency with neighbouring premises, where appropriate. New shopfronts should utilise high quality materials and finishes. The City Corporation will seek a reduction in fascias of excessive dimensions (height, width and depth) that are out of proportion or scale with the shopfront or have a detrimental visual effect on the building or the street scene.
9.6.3 Modification to shopfronts and shopfront designs to incorporate louvres, plant or refuse accommodation should be undertaken in a manner sympathetic to the design and character of the building where they cannot be accommodated in less sensitive elevations.
The use of awnings and canopies should be considered to address climate impacts, where appropriate, and should be integrated into the shopfront design in relation to size, location and materials.
9.6.4 Fully openable shopfronts and large serving openings may be refused where they create a void at ground floor level that could harm the appearance of buildings and create potential amenity issues.
9.6.5 Required security measures should be internal to limit their visual impact on shopfronts and deliver an active frontage. External security shutters are not normally acceptable, except where they are a characteristic of historic shopfronts. Internal shutters should be perforated to enable visibility into the shop and passive surveillance. To enliven frontages and enable passive surveillance, all retail frontages should provide good visibility and glazing should not be blanked out. The installation of security glass and steel reinforced frontages will be considered in the context of the impact on the appearance and historic significance of the shopfront.
Retail entrances – including alterations to existing buildings –should be designed with level entrances and doorways that enable inclusive access by all. Where alterations would have an impact on heritage assets, all feasible options should be explored to provide the highest levels of inclusion.
Design 9
Policy DE6: Advertisements
1. Advertising must be of a high standard of design, restrained in amount and in keeping with the character of the City.
2. Excessive or obtrusive advertising, inappropriate illuminated signs and the display of advertisements above ground floor level will be resisted.
3. Advertising flags and banners may be appropriate to support cultural institutions.
4. High quality temporary advertising associated with one-off events may be appropriate, where it would contribute to the vibrancy of the Square Mile and make a positive contribution to amenity and public safety.
Reason for the policy
9.7.0 To protect and enhance the character of the City’s streets, the City Corporation considers that advertising material should be restrained in quantity and form. Poor quality advertisements harm the street scene and the unique character of the City of London. The City Corporation will exercise advertisement control having regard to visual amenity and public safety and will seek improvements to the design of advertisements, where necessary.
How the policy works
9.7.1 Advertising hoardings and advertisements on street furniture will not normally be permitted as these detract from the character of the City. The display of advertisements on construction site hoardings will be resisted unless directly related to the development site. Construction hoardings may, however, provide an opportunity to add interest to the street scene by including images and information about the development under construction. Artificial greening on hoardings should be avoided. Further guidance is contained in the City Corporation’s Hoardings Advice Note and in the City of London’s Considerate Contractor Scheme Code of Conduct.
9.7.2 The design of advertising material should respect its locality and use appropriate materials of high quality. Advertisements should be appropriate to the frontage served and should not include static or moving projection of images beyond the frontage, such as laser projections and projections on building façades, to protect visual amenity and public safety. Illumination of advertisements should be discreet and incorporate LEDs to reduce the overall bulk and energy use of signage. Advertising flags and banners will not normally be permitted except where appropriate for cultural institutions. Rotating advertisements will be resisted as these detract from the City’s character.
9.7.3 Particular care will be necessary with advertisements on or in the setting of listed buildings and within conservation areas. Internal illumination of advertisements in such areas will not normally be permitted.
Design 9
9.7.4 Advertisements above ground level are frequently detrimental to the appearance and visual amenity of the street scene and can detract from the character and qualities of individual buildings by obscuring architectural features and the City’s streetscape and skyline. While there are exceptions, such as traditional or historic signs, signs in an elevated position will not usually be permitted.
9.7.5 Appropriate action will be taken to have unauthorised advertisements removed. The City Corporation’s Transport Strategy requires that pavements are kept clear of obstructions through a range of actions, which include not permitting A-boards on the pavement and encouraging owners and occupiers not to place A-boards on private land adjacent to the pavement.

Policy DE7: Daylight and sunlight
1. Development proposals will be required to demonstrate that the daylight and sunlight available to nearby dwellings and other sensitive receptors including schools, hospitals, hotels and hostels, places of worship and open spaces, is appropriate for its context and provides acceptable standards of daylight and sunlight, taking account of the Building Research Establishment’s guidelines.
2. Development proposals should have regard to the daylight and sunlight levels of historic interiors and should seek opportunities to improve daylight and sunlight levels where this would be achievable and appropriate.
3. The design of new developments should allow for the lighting needs of intended occupiers and provide acceptable levels of daylight and sunlight consistent with a city centre context, minimising the need for artificial lighting.
4. Development should incorporate design measures to mitigate adverse solar glare effects on surrounding buildings and public realm.
Reason for the policy
9.8.0 The City is an urban centre with a very high density of buildings, resulting in lower average levels of daylight and sunlight to buildings and spaces in comparison to suburban or rural areas. The amount of daylight and sunlight received has an important effect on the amenity of dwellings, the appearance and enjoyment of the open spaces and streets of the City, and the energy efficiency of all buildings. Access to appropriate levels of daylight and sunlight is important for the mental health of workers and residents. Daylight and sunlight can enhance historic interiors, particularly those that have a cultural or community function including religious buildings.
How the policy works
9.8.1 The Building Research Establishment (BRE) has issued guidelines in ‘Site Layout Planning for Daylight and Sunlight’ that set out a methodology for assessing changes in daylight and sunlight arising from new development. The City Corporation will apply these methods, consistent with BRE and NPPF guidance that ideal daylight and sunlight conditions may not be practicable in densely developed city-centre locations. Given the importance of the City’s open spaces in a high-density urban environment, the impact of any changes to sunlight on the public realm will need to be carefully evaluated even if proposals comply with BRE guidelines. Developers will be required to submit daylight and sunlight assessments and undertake radiance studies in support of their proposals. The City Corporation may require independent verification of these assessments at the developer’s expense.
9.8.2 When considering proposed changes to existing lighting levels, the City Corporation will take account of the retained levels of daylight and the cumulative effect of development proposals, and existing levels of light if they are low. The City Corporation will take into account unusual existing circumstances, such as development on an open or low-rise site as well as the presence of balconies or other external features, which limit the daylight and sunlight that a building can receive. The City Corporation will publish further guidance for City developers on how it expects BRE guidance to be used and interpreted, including guidance on the use of methodologies such as radiance studies to enable better understanding of daylight and sunlight impacts to a range of existing land uses.
9.8.3 Planning considerations concerning daylight and sunlight operate independently of any common law rights and any light and air agreements which may exist. If a development is considered beneficial in the public interest and has planning permission, but it is not proceeding due to rights to light issues, the City Corporation may consider acquiring interests in land or appropriating land for planning purposes to enable development to proceed.
Design 9
Policy DE8: Lighting
1. Development should be designed in ways that consider the impacts of internal and external lighting and should include measures to reduce energy consumption, avoid spillage beyond where it is needed and protect the amenity of light-sensitive uses such as housing, hospitals, relevant open spaces and community uses. The design of lighting should be informed by the potential impacts on biodiversity, and should seek to make the City a safer and more welcoming place to be for all its communities after dark.
2. The external lighting of buildings should contribute positively to the unique character and – where relevant – grandeur of the City townscape by night.
3. External lighting of heritage assets within the City must be sympathetic to the building and the wider context in terms of tone and brightness.
4. Applications for major development and for lighting schemes should follow the submission requirements set out in the Lighting SPD (Lighting Strategy, Lighting Concept and Technical Lighting Design). All other applications should address how lighting has been considered as part of the submission.

Reason for the policy
9.9.0 The City Corporation aims to improve the night-time offering and create an after-dark street experience that befits a world class business and cultural centre. Well-designed lighting schemes on commercial properties within the City can help create an attractive night-time townscape and enhance the experience for visitors, whilst avoiding disturbance to residents.
9.9.1 Development has the potential to positively or adversely affect the level and quality of lighting in the surrounding area, so the lighting scheme should be incorporated into the detailed design process at an early stage. Careful planning and design are required to ensure proper consideration of key issues where lighting has an impact such as on biodiversity, movement, accessibility, safety, security as well as the reduction of energy use and light pollution.
9.9.2 Sensitively designed lighting schemes can improve accessibility for disabled people by reducing glare and excessive contrast. Well-designed lighting can support the prevention and detection of crime and anti-social behaviour and improve the perception of personal security. In the City, the predominance of glazed office buildings can lead to light pollution, which can impact residential amenity, undermine biodiversity and cause harm to wildlife. Impacts on the City’s open spaces – including the riverfront – are important considerations.
How the policy works
9.9.3 The highlighting of key buildings, bridges and other points of interest within the City at night time is appropriate where it enhances the overall experience of this unique area, and provides orientation and wayfinding after dark.
9.9.4 The external illumination of buildings, where appropriate, should be carefully designed to ensure visual sensitivity, minimal energy use and light pollution, and the discreet integration of light fittings into the building design. Lighting intensity, tone and colour need to respect the architectural form and detail of the building, be sensitive to the setting of historic buildings and limit adverse effects upon adjacent areas, uses and biodiversity.
9.9.5 The design of lighting schemes should be considered at an early stage in the development design process, having regard to the City of London Lighting SPD. For major applications and lighting schemes, developers should submit a Lighting Strategy at pre-application stage, a Lighting Concept with their planning application, and Technical Lighting Design details through condition if the application is approved. All other applications should consider the lighting impacts as part of the application.
9.9.6 Owners, occupiers and managers of existing buildings will be encouraged to adopt the principles set out in the Lighting SPD by signing up to the ‘Considerate Lighting Charter’ in the SPD.