myatts field north report
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planning report PDU/2308/02
29 June 2010
Myatts Field North Housing Estate, Brixton
in the London Borough of Lambeth
planning application no. PA/09/01122
Strategic planning application stage II referral (new powers)
Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and
2007; Town & Country Planning (Mayor of London) Order 2008
The proposal
Redevelopment of the Myatts Field North Estate including the demolition of 305 residential
units, refurbishment of 172 residential units and erection of approximately 808 new residential
units together with new roads and footpaths, community centre, retail space, energy centre,
car parking, cycle parking and landscaping.
The applicant
The applicant is Regenter Ltd, and the architect is PRP Architects.
Strategic issues
The redevelopment of Myatts Field North is a significant opportunity to replace and
significantly add to the existing social and community infrastructure to provide a balanced
and mixed community, and is acceptable in strategic planning terms.
Key strategic issues regarding affordable housing, design, climate change, and transport
have all been satisfactorily resolved.
Recommendation
That Lambeth Council be advised that the Mayor is content for it to determine the case itself,
subject to any action that the Secretary of State may take, and does not therefore wish to
direct refusal or direct that he is to be the local planning authority.
Context
1 On 15 April 2010 the Mayor of London received documents from Lambeth Council
notifying him of a planning application of potential strategic importance to develop the above
site for the above uses. This was referred to the Mayor under Category 1A of the Schedule to
the Order 2008: ”Development which comprises or includes the provision of 150 houses, flats, or house
and flats”.
2 On 19 May 2010 the Mayor considered planning report PDU/2308/01, and
subsequently advised Lambeth Council that the application did not comply with the London
Plan, for the reasons set out in paragraph 114 of the above-mentioned report; but that the
possible remedies set out in paragraph 116 of that report could address these deficiencies.
page 1
3 A copy of the above-mentioned report is attached. The essentials of the case with
regard to the proposal, the site, case history, strategic planning issues and relevant policies and
guidance are as set out therein, unless otherwise stated in this report. On 16 June 2010
Lambeth Council decided that it was minded to grant planning permission for the revised
application, and on 18 June 2010 it advised the Mayor of this decision. Under the provisions of
Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may
allow the draft decision to proceed unchanged, direct Lambeth Council under Article 6 to
refuse the application or issue a direction to Lambeth Council under Article 7 that he is to act
as the Local Planning Authority for the purposes of determining the application. The Mayor
has until 1 July 2010 to notify the Council of his decision and to issue any direction.
4 The decision on this case, and the reasons will be made available on the GLA’s website
www.london.gov.uk.
Update
5 At the consultation stage Lambeth Council was advised that the application did not
comply with the London Plan. Since then, further information has been provided in order to
address the matters that were raised. Addressing each of these points in turn, the following is
noted:
Affordable housing
6 At the consultation stage, further information was requested to demonstrate that the
scheme provides the maximum reasonable amount of affordable housing, and that an
appropriate housing mix and tenure would be achieved.
7 The applicant’s viability assessment demonstrates that the scheme would not be viable
without social housing grant funding on the new affordable housing or a reduction in the
quantum of affordable units. It is noted that 49% of all the homes to be built (both re-provision
and additional) would be affordable. Lambeth Council officers, in the report to planning
committee, note that the overall affordable housing provision across the entire estate, including
the refurbished units, would be 60% (based on habitable rooms). The provision of private units
is required to fund the proposed improvements to the existing affordable housing stock. It is
also noted that the scheme has been the subject of scrutiny by the Homes and Communities
Agency, Lambeth Housing and the Department of Communities and Local Government, in
relation to the grant funding that has been secured.
8 On this basis, officers are satisfied that the scheme would provide the maximum
reasonable amount of affordable housing. The Council proposes a section 106 obligation which
secures 60% affordable housing (by habitable rooms) to be provided across the entire estate.
9 In relation to dwelling mix, the estate presently comprises largely one and three
bedroom units. The proposed housing schedule has been informed in part by the need to re-
house existing residents and a housing needs assessment which determined that a wider
provision of housing is needed. The scheme proposes over 34% of units would be three bed or
larger, which is in line with strategic policy.
10 On this basis, the proposal complies with policy 3A.5, 3A.9 and 3A.10 of the London
Plan.
Urban design
page 2
11 At the initial consultation stage, it was advised that the design principles of the scheme
were broadly consistent with the London Plan, subject to further clarification and amendments
in relation to materials and detailed design of some of the blocks.
12 Officers subsequently met with the architect to discuss the proposals in order to resolve
the outstanding issues relating to the overly repetitive use of materials and architectural styles.
At the meeting, the architect was made aware that the selection of external materials and of the
brick types is crucial to the delivery of a high quality housing scheme. Various elevational
treatment options were produced and discussed at the meeting. The architect reassured officers
that brick work with stone detailing would be used as primary materials, together with
building breaks and recessed balconies to articulate and to provide subtle variations to the
elevations. Officers subsequently accepted that the consultation exercises carried out by the
applicant has led to the restrained design approach that is being taken, with more vibrant
landscaping being proposed to counter-balance this. Following the meeting, the architect has
submitted further revised drawings to illustrate a greater contrast between the colours of the
brickwork. This demonstrates the applicant's commitment in delivering high quality public
open space and housing.
13 It is noted that Lambeth Council’s planning committee considered that the second phase
of development should have a wider variety of architectural styles and an informative has
accordingly been included in the draft decision notice requesting this.
14 On this basis, the concerns raised in the initial consultation have been broadly addressed
and scheme is now in compliance with policies 4B.1, 4B.3 and 4B.9 of the London Plan.
Climate change mitigation
15 At the initial consultation stage, it was advised that the energy strategy was generally
acceptable, however further information was requested in relation to baseline carbon dioxide
emissions, additional energy efficiency savings and the communal heating network initiatives.
16 The applicant has confirmed that the carbon savings have been related to 2010
compliant buildings (as well as 2006). The applicant has also clarified that, considering the
new build elements alone, the savings from energy efficiency amount to an improvement of
15% beyond the baseline figures. This figure is more in line with what would be expected for a
development such as this. The community centre and the retail areas will be connected to the
network, which is supported. A schematic plan has also been provided indicating the different
buildings that will be connected to the heat network.
17 The combined heat and power (CHP) system has been designed to enable linking with
the adjoining Myatts Field South in the future, to provide for its heating needs. It is presently
connected to the energy centre on the site. Whilst the applicant has confirmed that there is
every intention to connect to this site, because it is beyond the control of the applicant it would
not be possible to include this as a section 106 obligation. Whilst it would be desirable for
there to be definitive assurances that these schemes would be linked, the proposal is not
unacceptable in planning terms. As Lambeth Council support the proposal, GLA officers raise
no objections in this respect.
18 On this basis, the scheme complies with London Plan policies 4A.1 to 4A.21.
Climate change adaptation
page 3
19 At the initial consultation stage, it was noted that there was a lack of detail regarding
proposed green and brown roofs, including details of where these were to be incorporated.
20 The applicant has confirmed that cycle stores and carports throughout the scheme
would feature green roofs, and that they are also likely to feature in the design of the
community centre (phase 1 reserved matter). Lambeth Council has included a condition in the
draft decision notice which requires the applicant to provide details of where it is possible,
viable and appropriate to install green or brown roofs during later phases of the scheme.
21 Biodiversity in the local environment will be also encouraged by the provision of a new
park, allotments / community gardens, verges, tree planting and private gardens. Sustainable
drainage on site will be achieved through a Sustainable Urban Drainage System, details of
which have been secured by way of condition. The Council has also imposed conditions in
relation to Code for Sustainable Homes and BREEAM. On this basis, the scheme complies
with London Plan policy 4A.9 in relation to adaptation to climate change.
Transport for London comments
22 At consultation stage, Transport for London (TfL) requested a contribution of
£270,000 towards capacity improvements to the local bus network, necessary to mitigate the
impacts of this development, and an additional £100,000 towards a new pedestrian crossing
across Brixton Road. Further information was also requested on cycle parking and travel plan,
whilst a construction logistics plan and delivery and servicing plan needed to be secured by
appropriate planning obligations or conditions.
23 Further information has since been received regarding cycle parking layouts which is
considered to be acceptable. The travel plan will be secured through the Section 106 agreement
and both the delivery and servicing plans and construction logistics plan have been secured by
planning conditions, this is welcomed.
24 The recommended contributions as set out in the Council’s planning committee report
secured a total of £250,000 towards improvement measures for pedestrians and buses.
Following further discussions with both the council and the applicant in relation to transport
mitigation priorities, TfL has requested that amendments to the levels and apportionment be
made and the Section 106 altered to reflect this.
25 TfL’s proposed amendments consist of a reduced contribution of £30,000 towards the
requirement for a design feasibility study of a pedestrian crossing facility across Brixton Road
and an increased contribution of £270,000 (£90,000 per year for 3 years) towards bus capacity
enhancements on services operating along the Camberwell New Road.
26 The Council and applicant have now confirmed in writing that they agree to TfL’s
suggested amendments to the package of planning obligations and the council has agreed that
the Section 106 agreement will be revised accordingly, and the planning permission will be
issued on that basis. The Council has also agreed to consult TfL on the drafting of the Section
106 agreement to ensure that these changes are fully taken in to account.
27 On balance, TfL considers that all of the issues raised at consultation stage have now
been satisfactorily addressed through the submission of additional information, planning
conditions and revised obligations. TfL therefore considers this application to be in general
conformity with the London Plan and acceptable in transport terms.
Response to consultation
page 4
28 The application was advertised by site and press notices and consultation letters, which
were sent to 2729 neighbouring properties.
29 A total of 43 responses were received as a result of the consultation process, with
concerns raised in relation to the following:
The open space to the east of Akerman Road should not be built on.
Buildings are too tall to the east of Akerman Road.
Buildings are too tall/buildings are too bulky.
Buildings would be out of proportion and out of character with surroundings.
Scheme represents overdevelopment of the site.
Density would be too high.
Loss of open space, health facility and sports facilities.
Loss of trees.
Loss of privacy/overlooking.
Loss of sunlight and daylight.
Development would harm the setting of listed buildings and adjacent conservation
areas.
The scheme would not improve the permeability of the site.
The park should not be in the centre of the estate.
The social housing levels are too high (a further objection states that they are too
low).
Concerns regarding maintenance of the estate and public open spaces.
The travel plan and transport assessment are flawed; public transport is insufficient
and parking problems and congestion would be exacerbated.
Local infrastructure could not support the development and there are not enough
community facilities to support the development.
Consultation exercise was not extensive enough.
30 Comments have been received from the Minet Conservation Association and Myatts
Field North Action Team, two local amenity groups. Objections are raised in relation to
impacts upon the conversation area, parking and traffic management, noise and disturbance,
loss of open space, and the consultation process.
31 The local ward councillor has provided comments on the scheme in relation to traffic
and parking, loss of open space, amenity impact, and youth engagement. Section 106
obligations are suggested to commit funding to mitigate the impacts of the scheme, and these
have been secured by the Council.
32 Other statutory consultees responded as follows:
CABE: No comments received.
Environment Agency: Conditions have been suggested in relation to surface water run
off rates and flood risk management. It is noted that these conditions have been
included in the draft decision notice.
page 5
English Heritage: Welcomes the opportunity that the regeneration of Myatt’s Field
North brings to reintegrate areas of the Borough, improving legibility and access.
Concerns are raised in relation to the impact of the proposals upon surrounding
buildings of interest and upon the character of adjacent conservation areas, and on this
basis, English Heritage is unable to support the scheme.
London Fire and Emergency Planning Authority (LFEPA): No response received.
London Underground: Advises that it has no comment to make on this application.
Thames Water: Has requested a condition requiring details of a drainage strategy to
be submitted, in the absence of sufficient details having been submitted with the
application. Other conditions and informatives are suggested in relation to water
infrastructure, piling, trade effluent consent and sewers. These conditions have been
included in the draft decision notice.
English Nature: The proposal does not affect any priority interest areas for Natural
England, but the retention, improvement and enhancement of green spaces within and
around this development is to be encouraged.
Southern Gas Network: Notes the presence of a gas main in the proximity of the site
and that precautions will be necessary in relation to excavations.
Southwark Council: No comments received.
33 In relation to the objections raised by local residents, matters relating to urban design,
density, affordable housing, open space, and transport have been dealt with in this and the
previous report.
34 Matters relating to impact upon local amenities, infrastructure and local views are not
in this instance strategic planning matters and have been assessed by Lambeth Council in its
committee report.
35 With respect to the objections raised by English Heritage in relation to impacts upon
listed buildings and conservation areas, these are local matters that have been considered by
Lambeth Council in its committee report. Nevertheless, it is considered that the high design
quality of the scheme and its responsive which is being secured by way of detailed reserved
matters planning conditions would result in an acceptable impact upon the local area and its
heritage assets.
Article 7: Direction that the Mayor is to be the local planning authority
36 Under Article 7 of the Order the Mayor could take over this application provided the
policy tests set out in that Article are met. In this instance the Council has resolved to grant
permission with conditions and planning obligations which satisfactorily addresses the matters
raised at stage I, therefore there is no sound planning reason for the Mayor to take over this
application.
Legal considerations
37 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor
of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning
authority to refuse permission for a planning application referred to him under Article 4 of the
Order. He also has the power to issue a direction under Article 7 that he is to act as the local
planning authority for the purpose of determining the application. The Mayor may also leave
page 6
the decision to the local authority. In directing refusal the Mayor must have regard to the
matters set out in Article 6(2) of the Order, including the principal purposes of the Greater
London Authority, the effect on health and sustainable development, national policies and
international obligations, regional planning guidance, and the use of the River Thames. The
Mayor may direct refusal if he considers that to grant permission would be contrary to good
strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out
his reasons, and the local planning authority must issue these with the refusal notice. If the
Mayor decides to direct that he is to be the local planning authority, he must have regard to the
matters set out in Article 7(3) and set out his reasons in the direction. The Mayor must also
have regard to the guidance set out in GOL circular 1/2008 when deciding whether or not to
issue a direction under Articles 6 or 7.
Financial considerations
38 Should the Mayor direct refusal, he would be the principal party at any subsequent
appeal hearing or public inquiry. Government guidance in Circular 03/2009 (‘Costs Awards in
Appeals and Other Planning Proceedings’) emphasises that parties usually pay their own expenses
arising from an appeal.
39 Following an inquiry caused by a direction to refuse, costs may be awarded against the
Mayor if he has either directed refusal unreasonably; handled a referral from a planning
authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding
whether the Mayor has acted unreasonably will be the extent to which he has taken account of
established planning policy.
40 Should the Mayor take over the application he would be responsible for holding a
representation hearing and negotiating any planning obligation. He would also be responsible
for determining any reserved matters applications (unless he directs the council to do so) and
determining any approval of details (unless the council agrees to do so).
Conclusion
41 Having regard to the details of the application, the matters set out in Lambeth Council’s
committee report and its draft decision notice, this regeneration scheme is acceptable in
strategic planning terms. Further information has been submitted regarding design, affordable
housing, climate change and transport, which address all issues that were raised previously.
On this basis, there are no sound reasons for the Mayor to intervene in this particular case.
for further information, contact Planning Decisions Unit:
Colin Wilson, Senior Manager – Planning Decisions
020 7983 4783 email colin.wilson@london.gov.uk
Justin Carr, Strategic Planning Manager (Development Decisions)
020 7983 4895 email justin.carr@london.gov.uk
Samantha Wells, Case Officer
020 7983 4266 email samantha.wells@london.gov.uk
page 7
planning report PDU/2308/01
19 May 2010
Myatts Field North Housing Estate, Brixton
in the London Borough of Lambeth
planning application no. 10/01014/OUT
Strategic planning application stage 1 referral (new powers)
Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and
2007; Town & Country Planning (Mayor of London) Order 2008
The proposal
Redevelopment of the Myatts Field North Estate including the demolition of 305 residential
units, refurbishment of 172 residential units and erection of approximately 808 new residential
units together with new roads and footpaths, community centre, retail space, energy centre,
car parking, cycle parking and landscaping.
The applicant
The applicant is Regenter Ltd, and the architect is PRP Architects.
Strategic issues
The principle of the redevelopment of the estate is supported, as well as the density and
approach to open space and play space. Further clarification is required regarding
affordable housing, housing mix, and tenure that are proposed, including the availability of
social housing grant.
Further work is also required in relation to design and materials, transport and climate
change before the scheme can be said to comply with London Plan policy.
Recommendation
That Lambeth Council be advised that the application does not comply with the London Plan,
for the reasons set out in paragraph 114 of this report; but that the possible remedies set out
in paragraph 116 of this report could address these deficiencies.
Context
42 On 15 April 2010 the Mayor of London received documents from Lambeth Council
notifying him of a planning application of potential strategic importance to develop the above
site for the above uses. Under the provisions of The Town & Country Planning (Mayor of
London) Order 2008 the Mayor has until 26 May 2010 to provide the Council with a statement
setting out whether he considers that the application complies with the London Plan, and his
reasons for taking that view. The Mayor may also provide other comments. This report sets
out information for the Mayor’s use in deciding what decision to make.
page 8
43 The application is referable under Category 1A of the Schedule to the Order 2008:
”Development which comprises or includes the provision of 150 houses, flats, or house and flats”.
44 Once Lambeth Council has resolved to determine the application, it is required to refer
it back to the Mayor for his decision as to whether to direct refusal; take it over for his own
determination; or allow the Council to determine it itself.
45 The Deputy Mayor of London’s statement on this case will be made available on the
GLA website www.london.gov.uk.
Site description
46 The Myatts Field North Estate is situated between Oval and Brixton underground
stations in Lambeth, immediately east of Brixton Road. The site is 12.4 hectares in area, and is
bounded by Mostyn Road and the Myatts Field South Estate to the south; Cowley Road and
the Cowley Estate to the west; Akerman Road and adjacent open space to the south-east;
Patmos Road to the north east and Cancel Road to the north.
47 The estate is owned by Lambeth Council and was built in the early 1970s. It contains
477 properties in total (ranging from 1-bedroom to 5-bedroom units) of which 58 units are
leasehold/freehold. There are a number of open spaces within the site, including Mostyn
Garden, Hammelton, Fairburn and Bramah Greens, Dan Leno Garden and Olive Morris
Gardens. The site also includes a local housing office, health centre and community centre.
48 The surrounding area is largely residential in character, but also features Charles
Edward Brook School and the open space of Myatts Fields Park to the east, and local
commercial uses along Brixton Road and Camberwell New Road.
49 The estate has been identified for redevelopment due to the costs of bringing the
accommodation in line with decent homes standards, although 172 units have been identified
for refurbishment rather than demolition as significant amounts of Single Regeneration Budget
funding was used to improve these properties in 2001.
Figure 1: Aerial photograph (Source: Submitted Design and Access Statement)
50 The site has a varying PTAL of 2 to 4, on a scale of 1 to 6, where 6 is most accessible.
The site is located 100m east of A23 Brixton Road and 250m to the west of Camberwell New
Road, both of which make up part of the Transport for London Road Network (TLRN). The
site is directly served by bus route P5, and in addition five buses operate along A23 Brixton
Road, and A202 Camberwell New Road is served by three buses. Both Stockwell and Oval tube
stations are over a kilometre from the site and provide access to the Victoria and Northern
lines.
Details of the proposal
51 The scheme proposes the demolition of 305 existing homes, refurbishment of 172 homes
and erection of 808 new homes, together with a new community centre, retail floor space, a
new park, with associated landscaping, car parking and cycle parking.
page 9
52 Through the demolition, refurbishment and new build, a total of 980 units would be
provided, comprising 301 one-bed flats, 343 two-bed flats, 194 three bed flats, 78 three-bed
houses, 56 four-bed houses and 8 five-bed houses.
53 The applicant has submitted a hybrid planning application, with with detailed
application has been submitted for Phase 1, which comprises demolition of the housing office
and 305 units, and construction of 485 new homes, new roads, realignment of Akerman Road,
195 parking spaces, 580 cycle parking spaces, and associated landscaping. This phase also
includes the installation of a gas fired power CHP boiler.
54 Outline planning permission being sought to approve the scale, layout and access for
part of the development (Phase 2), with appearance and landscaping reserved. This application
comprises construction of 323 units, the new community centre and retail floor space, park and
landscaping.
Figure 2: Massing diagram (Source: submitted Design and Access Statement)
page 10
Case history
55 Pre-application meetings were held with the applicant to discuss the redevelopment, on
20 November 2008 and 24 September 2009, with advice notes being subsequently provided.
56 Lambeth Council’s housing department has been pursuing options to regenerate Myatts
Field North for a number of years. In order to generate additional funds, it has successfully
pursued a Private Finance Initiative (PFI) project to raise the necessary funds to improve the
estate. The PFI bid process commenced in 2006, with several groups bidding to take the
scheme forward. Three bidders were selected to develop and refine their bids for submission to
Lambeth Housing, the HCA and DCLG, with the applicant being the appointed the preferred
bidder.
57 Prior to the most recent planning application, an outline application for the demolition
of 302 homes, refurbishment of 175 homes, and building of 500 new homes, re-provision of
community and retail uses and improvements to the public realm was referred to the previous
Mayor in February 2007. This scheme was acceptable, except in relation to the energy
strategy, and was recommended for permission by Lambeth Council in November 2007. It was
not subsequently referred back to the Mayor (ref PDU/1492) and a final decision was not
issued. This scheme proposed an uplift of 198 new homes on the site, and following the
submission of a viability assessment, an affordable housing offer was not made on the uplift.
Strategic planning issues and relevant policies and guidance
58 The relevant issues and corresponding policies are as follows:
Principle of development London Plan; PPS1
Density London Plan; PPS3; Housing SPG; draft revised interim Housing
SPG
Housing/affordable housing London Plan; PPS3; Housing SPG; Providing for Children and
Young People’s Play and Informal Recreation SPG, Housing
Strategy; draft revised interim Housing SPG
Density London Plan; PPS3; Housing SPG; draft revised interim Housing
SPG
Urban design London Plan; PPS1
Access and inclusive design London Plan; PPS1; Accessible London: achieving an inclusive
environment SPG; Planning and Access for Disabled People: a good
practice guide (ODPM)
Open Space London Plan
Child play space London Plan; Providing for Children and Young People’s Play and
Informal Recreation SPG
Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22;
draft PPS Planning for a Low Carbon Future in a Changing
Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change
Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy;
Sustainable Design and Construction SPG
Transport London Plan; the Mayor’s Transport Strategy; PPG13
59 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004,
the development plan in force for the area is the Lambeth Unitary Development Plan 2007 and
the London Plan (Consolidated with Alterations since 2004).
page 11
60 The draft replacement London Plan, published in October 2009 for consultation,
together with the Lambeth Core Strategy Development Plan document (pre-submission stage)
are also relevant material considerations.
Principle of development
61 London Plan policy 2A.7 encourages regeneration in areas where there is substantial
deprivation, requiring boroughs to “set out integrated spatial policies that bring together
regeneration, development and transport proposals with improvements in learning and skills, health,
safety, access, employment, environment and housing.” This policy is reinforced under policy 2.14 of
the draft replacement London Plan.
62 London Plan policy 3A.29 ‘supporting neighbourhood plans’ states “The Mayor will
encourage communities and neighbourhood-based organisations to prepare planning frameworks or
neighbourhood plans based upon identifying local economic, social, physical and environmental needs and
opportunities to strengthen local Neighbourhood Renewal Strategies”. The Mayor encourages
boroughs to adopt locally prepared frameworks or plans including those prepared by housing
association-led estate regeneration schemes, Development Trusts and Urban Regeneration
Companies as supplementary planning documents.
63 As stated under paragraph 15 above, Lambeth Council has been pursuing options to
regenerate the Myatts Field North Estate for a number of years and following a residents'
ballot in July 2005 to support a Private Finance Initiative (PFI) redevelopment scheme for the
estate, development planning guidance was prepared on behalf of Lambeth Council to guide the
bidding and redevelopment process. This document sets out the vision, key issues, priorities
and principles that Lambeth Council wishes to promote for the estate. The aspirations of
Lambeth Council in undertaking this regeneration scheme, and using planning guidance to
steer this process is in accordance with policy 3A.29. Subject to the detailed policy matters set
out in this report, the principle of estate renewal is supported.
Housing – affordable housing
64 The London Plan, in seeking to increase London’s housing supply and maximise the
potential of individual sites, focuses on securing housing choice and the maximum reasonable
amount of affordable housing (policies 3A.1, 5 and 10). The corresponding policies are set out
in Chapter 3 of the draft replacement London Plan.
65 The approach employed by the GLA when assessing estate renewal is to take into
account the regeneration benefits to the local community, the proportion of affordable housing
in the surrounding area, and the amount of affordable housing being, or planned to be, provided
elsewhere in the borough.
66 The existing estate comprises the following units, which contains 376 social rented
units and 101 private units:
Table 1: existing units on site
67 Policy 3A.15 of the London Plan provides guidance to boroughs preparing DPDs
regarding the loss of housing including affordable housing, stating that DPDs should prevent
the loss of housing, including affordable housing, without its planned replacements at existing
or higher densities. This is re-iterated in policy 3.15 of the draft replacement London Plan
page 12
which goes on to state that at least equivalent floorspace should be provided in housing
redevelopments. Paragraph 3.75 of the London Plan notes that “where redevelopment of
affordable housing is proposed, it should not be permitted unless it is replaced by better quality
accommodation, providing at least an equivalent floorspace.” Section 20 of the Housing SPG
provides further guidance on this matter, stating that estate regeneration schemes should be
undertaken on the basis of no net loss of housing or net loss of affordable housing. Paragraph
20.2 of the Housing SPG notes that “Replacement of social rented units by intermediate provision
may be acceptable where this can be justified by a requirement to achieve a wider range of types of
provision in a neighbourhood”.
68 The proposed scheme is made up of the following:
Social Total by
Type rented Intermediate Market Total unit type %
1 bed flat 104 22 175 301 31
2 bed flat 115 19 209 343 35
3 bed flat 149 0 45 194
3 bed house 67 0 11 78 28
4 bed house 39 0 17 56 6
5 bed house 7 0 1 8 1
Total 481 41 458 980
Habitable rooms 1916 101 1366 3383
% based on
57% 3% 40%
habitable rooms
Table 2: Proposed mix of units
Re-provision of affordable housing/tenure split
69 As noted in table 1 above, there are presently 477 homes on the site of which 77% are
social rented units. The scheme proposes 522 affordable housing units, of which 247 would be
replacement new homes, 146 will be additional new homes and 129 would be refurbished
homes. Affordable housing across the whole site would be 60% based on habitable rooms, with
92% of the affordable homes being social rented, and 8% shared ownership.
70 Breaking the scheme down further, in terms of the 808 new builds, 57% of the units
would be affordable, with 90% being provided as social rented and 10% as intermediate
accommodation. Stripping out the PFI re-provision units and focussing on the additional 503
units, 105 would be social rented and 41 shared ownership. This equates to 34% affordable
housing with a 72:28 split. In comparison to the existing provision, the percentage of social
rented accommodation is reduced from 79% to 49%, intermediate accommodation is introduced
to account for 4% of all units, and the percentage of private sale units increases from 21% to
47%.
71 The proposal results in a qualitative and quantitative improvement to the affordable
housing stock on the estate. There would be an increase in habitable rooms and an overall
increase of 145 affordable homes, together with an improvement to existing properties. On this
basis the scheme is in accordance with the London Plan and Housing SPG. The introduction
of shared ownership units to the scheme is acceptable and in accordance with London Plan
policies, which enables the introduction of mixed tenure in estate renewal schemes, so as to
page 13
provide mixed and balanced communities. Whilst it is understood that the scheme is in
accordance with the aspirations set out in the planning guidance, Lambeth Council should be
satisfied that the tenure split meets identifiable local needs and not just the needs of existing
tenants.
Viability
72 London Plan Policy 3A.10 requires borough councils to seek the maximum reasonable
amount of affordable housing when negotiating on individual private residential and mix-use
schemes. In doing so, each council should have regard to its own overall target for the amount
of affordable housing provision. Policy 3A.9 states that such targets should be based on an
assessment of regional and local housing need and a realistic assessment of supply, and should
take account of the London Plan strategic target that 35% of housing should be social and 15%
intermediate provision, and of the promotion of mixed and balanced communities. In addition,
Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain
residential development, and to the individual circumstances of the site. Targets should be
applied flexibly, taking account of individual site costs, the availability of public subsidy and
other scheme requirements. The corresponding policies are set out in Chapter 3 of the draft
replacement London Plan. Lambeth in its adopted Unitary Development Plan sets an overall
affordable housing borough target of 50%.
73 Policy 3A.10 of the London Plan is supported by paragraph 3.52, which urges borough
councils to take account of economic viability when estimating the appropriate amount of
affordable provision. The ‘Three Dragons’ development control toolkit is recommended for
this purpose. The results of a toolkit appraisal might need to be independently verified. This is
reinforced under policy 3.13 of the draft replacement London Plan.
74 In relation to estate renewal, where private housing is needed to support replacement of
affordable housing provision in estate renewal schemes, the net gain in total provision need not
achieve the usual proportion of affordable housing provision, where this is necessary to cross
subsidise redevelopment. Where this is the case, the applicant is expected to demonstrate that
the maximum reasonable amount of affordable housing is being provided by way of an open
book appraisal.
75 In this instance, the overall provision of affordable housing represents 60% of all units,
but because the scheme entails refurbishment and re-provision of units by way of PFI funding,
it is appropriate to also consider the additional 503 units being financed by the consortium. Of
these, 357 would be for sale, 41 for intermediate and 105 for social rented. This represents
36% affordable housing, based on habitable rooms.
76 The applicant has prepared a viability assessment, and states that the maximum level of
affordable housing is being provided in the scheme. The applicant states that the costs and
revenues of the regeneration proposals have been extensively tested and assessed to establish
the maximum feasible quantum of affordable housing that can be delivered in the scheme.
They advise that the proposed scheme is not viable without social housing grant funding on the
new affordable units or a reduction in the overall quantum of affordable housing. They note
that these assertions have also been tested through the scrutiny of the PFI bid by the HCA,
DCLG and Lambeth Council housing department.
77 Whilst the viability appraisal has been submitted, it was not received in sufficient time
to enable scrutiny or discussion with the local authority over its validity. At the time of
writing, Lambeth Council have not confirmed their intentions in terms of scrutiny of the
appraisal, or whether further s106 financial obligations would be required (which may impact
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upon the level of affordable housing). Furthermore, details of the potential for social housing
grant over and above the PFI funding has not been provided, or indeed whether the HCA
would support further funding of the scheme. Further discussion will be required before the
application is referred back at Stage 2, to enable the Mayor to be satisfied that the maximum
level of affordable housing is being provided in the non-PFI element of the scheme. Given the
phasing of the development, it may also be that cascading or review mechanisms are
appropriate and these should be discussed so as to ensure that there are appropriate clauses
included in the s106 agreement in relation to tenure and mix of units.
Mix of units
78 London Plan Policy 3A.5 requires new development to offer a range of housing choices
in terms of the mix of unit sizes and types, taking into account the housing requirements of
different groups. In support of this policy, the Mayor’s Housing Supplementary Planning
Guidance (SPG) seeks to secure family accommodation within residential schemes, particularly
within the social rented sector, and sets strategic guidance for councils in assessing their local
needs.
79 The scheme proposes a range of unit types, with flats, maisonettes, houses and
bungalows proposed. Over a third of units would be three-bed or larger, and whilst the
majority of these are in the social rented sector and are therefore welcomed, it is noted that
there would only be an increase of 28 three-bed plus units over the existing provision. Officers
recognise that the offer reflects an increase in the levels of family housing when compared with
the previous housing on the site, which is welcomed. However, in order to comply with the
London Plan and Housing SPG, further discussion is required before the application is referred
back at Stage 2, to establish to what extent the determined mix is a result of consultation with
existing tenants, and the need to re-house them, or whether it is to meet local needs.
Residential quality
80 The Government’s ‘Decent Homes Standards’ aims to bring all social housing into a
decent condition by 2010. To meet this standard, properties must have reasonably modern
facilities and be warm and weatherproof.
81 The applicant has provided details of the dwelling typology for each of the unit types.
All family houses have private gardens, and the maisonettes would have access to a private
garden or a roof terrace. All flats would be provided with either a private terraced patio
(ground floor units) or recessed balcony (upper level units). Indicative layouts, showing
proposed private amenity spaces have been provided, and it is stated that these would exceed
the Council’s standards for amenity space. It is considered that these are sufficiently sized to
provide meaningful benefits for residents. Flats would be arranged in small clusters, with there
generally being five flats accessing a single level of a core, with no long corridors which is
welcomed.
82 During the initial consultations at pre-application stage it was noted that there were a
significant number of single aspect, north, south and west facing units. The applicant
subsequently amended the scheme to ensure that most dwellings are dual aspect, with primary
living spaces and private amenity space overlooking surrounding spaces or gardens. Single
aspect units are generally limited to east or west facing units, which is welcome. Confirmation
of the number of north facing flats should be provided and details provided of how their design
has been maximised, in relation to window sizes for instance.
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83 The proposed three-storey height of the new houses is considered appropriate for the
setting. The internal arrangement of rooms is well considered, with kitchens to be located to
the front of the houses to give improved surveillance to the streets. Large storage areas will be
provided to each floor. Landings and stairways are naturally lit with potential for lifts to be
installed in the future. Externally the majority of houses are provided with a front garden and a
large rear garden with a patio area adjacent to the house.
84 The apartments are designed to ensure that they are tenure blind and different tenures
are dispersed throughout the neighbourhood. The unit sizes vary but the applicant states that
each new unit (private and affordable) will achieve an acceptable size when compared with the
space standards set out in the Council’s SPG. A checklist has been provided which shows a
comparison against Lambeth Council, Notting Hill Housing Trust and the Mayor’s draft
Housing Design Guide and draft replacement London Plan (2009), which show that overall
unit sizes and individual unit sizes generally comply. It would be appropriate for the applicant
to provide details of how the dimensions, as well as the gross internal area, compares to enable
the Council to consider these details when assessing the detailed/reserved matters applications.
Density
85 Policy 3A.3 of the London Plan aims to maximise the potential of a site taking account
of local context, London Plan design principles and public transport capacity. Table 3A.2 of
the London Plan provides a framework for assessing density based on habitable rooms and
dwellings per hectare. The consultation draft replacement London Plan policy 3.4 and Table
3.2 moves away from ‘maximise’ to ‘optimise’ taking into account all those matters in existing
policy but with greater emphasis on local context and the design principles set out in Chapter 7
of the draft plan.
86 Paragraph 20.3 of the Housing SPG notes that “to achieve 100% replacement of demolished
social rented units, development at significantly increased density may be necessary to generate sufficient
value from market development to support replacement of affordable housing provision or to achieve a
mixed and balanced community objective.”
87 The existing density of the site is in the region of 340 habitable rooms per hectare. The
planning guidance for the site, Lambeth’s UDP and the London Plan suggest a density that is
no higher than 450 habitable rooms per hectare. The proposed density of the scheme is 429
habitable rooms per hectare. Given the site has only a medium level of public transport
accessibility, the proposed increase of density on this site is acceptable. It also allows for a
significant proportion of the open space to be retained, while including private gardens where
appropriate.
Urban design
88 Good design is central to all objectives of the London Plan and is specifically promoted
by the policies contained within Chapter 4B, which address both general design principles and
specific design issues. London Plan Policy 4B.1 sets out a series of overarching design
principles for development in London. Other design polices in this chapter and elsewhere in the
London Plan include specific design requirements relating to specific issues. London Plan
policies 4B.9 and 4B.10, which set out specific design requirements relating to maximising the
potential of sites, the quality of new housing provision, tall and large-scale buildings, built
heritage, views, and the Blue Ribbon network.
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89 The draft replacement London Plan reinforces these principles, with new development
required to have regard to its context, and reinforce or enhance the character, legibility and
permeability of the neighbourhood (Policy 7.1).
90 Further to the above, the Mayor has published his draft London Housing Design Guide.
Although this is not supplementary planning guidance, the principles within it should help the
scheme to demonstrate consistency with London Plan strategic design principles.
91 The applicant has been involved in a series of pre-application discussions regarding the
proposed development, and officers are broadly content with the quality of the design. The
submitted design and access statement is of high quality; it describes the design concept in a
clear and concise manner, and explains how the detailed design has been refined through the
pre-application consultation process with key authorities.
Massing and scale
92 The masterplan concept for the site is generally well considered, taking into account the
difficulties of incorporating the existing (retained) buildings. The massing and scale proposed is
appropriate to the surrounding residential context and the architecture responds to the
Georgian vernacular. The proposal has been further improved to address concerns raised
previously at pre-application stage in relation to layout, built form and materials.
Layout, design and appearance
93 The neighbourhood around Myatts Field North has a variety of local building styles
and periods of architecture. The rationale of introducing character areas in the neighbourhood
is supported, as it would help define and develop elevational treatments and spatial
characteristics of both the architecture and landscape design around the new neighbourhood.
The proposed character areas are generally well designed, and would help create design
diversity within the new streets, and provide the opportunity for different styles of architecture
to be introduced to relate to, and respect, the character of the conservation areas.
94 The perimeter block approach applied to the designing of the new housing blocks is
welcomed. This approach provides well defined public spaces and quiet private spaces that are
well overlooked and secure.
95 The terrace form, applied to the family homes, enhances the concept of neighbourhood
and community. The rationale of introducing primary access to dwellings, through frequent
front doors positioned along the street, support an active street frontage that is well
overlooked.
96 Officers welcome the design approach to ensure that all new homes will be
indistinguishable in terms of ownership. The different tenures will be constructed from the
same palette of materials, and be designed to the same standards across the whole development.
97 Whilst the architects have continued to develop the elevation design of the buildings, in
order to address previously raised design issues relating to the appearance of the buildings, the
latest images demonstrate that the majority of building blocks remain bulky. Further work is
therefore required to reduce the ‘blocky’ appearance of some of the elevations. The challenge
will be to ensure that the proposed design and finish are consistent enough to create a sense of
place, without relying on over-repetition. It will be important to provide images of the
proposed blocks to demonstrate the quality of the final development.
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98 As noted previously, the proposed scheme would increase the number of family homes
enjoying private open space, such as individual gardens and roof terraces, and this aspect of the
masterplan proposal is strongly supported.
99 The proposed location of the new community facility, in the central point of the park, is
considered appropriate as it would create a focal point which helps give a sense of identity for
the local residents. The proposed local area management offices, creche area, cafe, training and
changing facilities would help generate activities in the park throughout different times of the
day, making a positive contribution to the public realm.
100 The enhancement of existing retail facilities is supported as it would add variety and
choices for local residents as well as the wider community.
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Materials
101 The rationale of using high quality brickwork as the main material for the facades is
supported, as it would complement and integrate with the vernacular style of the local
Victorian buildings. Whilst the proposed materials are of good quality, and appear visually
pleasing for individual buildings, the proposed facades do not appear to have sufficient
variations to support the vision of creating distinct character areas for the development. The
proposed materials have the potential to result in a bland scheme and have a negative impact on
legibility. The architect is therefore asked to introduce variations to the elevational treatment
and avoid over-repetition of the same materials, in order to improve and support the different
architectural approach intended for the character areas, and to enhance the legibility of the
scheme, ensuring visual interest is maintained throughout the finished development.
Access, movement and public realm
102 The masterplan provides a clear and legible hierarchy of streets, footpaths and
cycleways, and this is welcomed. However, as noted above, further improvement should be
made to the building materials to help support the legibility of the overall development.
103 The design of the public realm is of good quality and would help support traffic calming
such as the introduction of shared pedestrian and cycle surfaces. The streets generally have
clearly defined boundary treatments, providing clear visual cues between public and private
areas.
Car Parking
104 The car parking arrangement to this scheme has generally been designed to a good
standard. Whilst recognising the high density requirements of the site, the proposals provide
adequate parking provision at street level. The variety of parking proposed responses well to
the different dwelling types, which help minimise adverse visual impact on the streetscene, and
is supported.
Landscape and open spaces
105 The rationale of providing a wide range and diversity of play spaces, and a varied
sequence of public open spaces for the development is strongly supported, as this would help
improve the use and availability of community facilities to a much wider range of residents
throughout the community. The creation of Melbourne Square and the community garden on
Hammelton Green, in particular, would offer a wider range of spatial and visual experiences to
all and this is welcomed.
Conclusion
106 In summary, the design proposal for the Myatts Field North Estate regeneration offers
an opportunity to deliver much improved design quality compared to the existing estate. The
proposed scheme would restructure the estate into a well-connected, safe community and
ensure its integration into the wider area. This approach is strongly supported. Further
revisions to the detailed design of the proposed buildings should be made to ensure the
scheme’s compliance with the London Plan.
Access and inclusive design
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107 London Plan policy 4B.5 and the corresponding draft replacement London Plan policy
7.2 seek to ensure that proposals achieve the highest standards of accessibility and inclusion
(not just the minimum), and this and all developments should seek to better minimum access
requirements. Policy 3A.5 requires that 10% of new housing is designed to be wheelchair
accessible, or easily adaptable for residents who are wheelchair users. Design and access
statements should explain the design thinking behind the application and demonstrate how the
principles of inclusive design, including the specific access needs of people with disabilities,
have been integrated into the proposed development and how inclusion will be maintained and
managed.
108 The applicant has committed to ensuring that all of the housing is designed to Lifetime
Homes Standards, but in order to validate this, an example layout should be provided to show
how the sixteen principles have been met. The details of how this is to be achieved should be
secured at detailed design stage. The accommodation schedule indicates that 46 of the new
build units in Phase 1 would be wheelchair adaptable, of which seven would be purpose built
wheelchair houses and 38 wheelchair adaptable flats. This equates to 9.5% but the applicant
confirms that 10% of all units, across both phases, will be suitable or easily adaptable for
wheelchair users, including at least eleven further wheelchair houses/bungalows. The
applicant has committed to ensuring that the allocation of wheelchair housing would be across
tenures and mixes, which is welcomed. Lift access is provided for the multi-storey blocks of
flats, which addresses concerns raised at pre-application stage about walk up blocks. Lambeth
Council should secure these commitments by way of condition.
109 The applicant confirms that the masterplan proposals have been constructed around the
principles of inclusive design, specifically in that the needs of disabled people have been
integrated into the proposed development in the landscaping, access, maintenance and
management standards of the site. An audit of the existing access arrangements and
consultation with local disabled people and access groups has been carried out. The applicant
has committed to ensuring the design of the public realm, and the proposed improvements to
open space, take into account the access needs of disabled people, older people and children and
integrate them into the design. For example the colouring and textures of the design of shared
surfaces has been detailed so that safety for visually impaired pedestrians will be ensured while
allowing wheelchair users and parents with pushchairs easy level access.
110 Each wheelchair accessible home has a parking space reserved for use by blue badge
holders and these spaces are located as close to the wheel chair properties as possible. The
arrangements for the future review of demand and supply of bays for disabled people is
reflected in the parking management and travel plans. The applicant proposes to provide
information, as part of the marketing information, with reference to the apartments that can be
fitted out to wheelchair accessible standards. In relation to the community and health facilities,
detailed layout for these elements are reserved for consideration as part of Phase 2. It will be
important to ensure that these are fully accessible, with blue badge visitor parking also being
accommodated
111 Given that landscaping is to be considered as a reserved matter, and that this will not be
referred to the Mayor, Lambeth Council will need to ensure that the details of the home zone
routes and shared spaces are fully inclusive, paying attention to the needs of visually impaired
people. The design team have created a positive arrangement of streets and open spaces and
principles should be applied throughout the reserved matters stages, to public realm and
amenity space. Consideration should also be given to the play space, blue badge parking
location, and the allocation of units to ensure that the scheme is fully inclusive, in accordance
with the commitments made by the applicant in their access strategy.
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112 The applicant is also encouraged to work closely with the local access forum and
wheelchair users to ensure that inclusive design principles continue to be incorporated into all
aspects of the scheme at the detailed approval stage. Given the poor public transport
accessibility in the area, improvements to the frequency and location of the bus route is
welcomed.
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Loss of open space
113 Mostyn Gardens, which is within the application site boundary is designated ‘local open
space’. At pre-application stage and in relation to the previous application, it was noted that
the scheme would result in the loss of open space. The applicant has confirmed in recent
correspondence, the following existing and proposed open space:
Public open space Private open space Home zones Total
Existing 5.5 ha 1.6 ha 0 7.1 ha
Proposed 4 ha 2.3 ha 0.8 ha 7.1 ha
114 PPG17 resists the loss of valuable open spaces and recreational spaces, and requires an
assessment by local authorities of local needs. Lambeth Council’s policies seek to protect open
space in the borough, although its designation for Myatts Field North (MDO 37) states that
any loss of open space should be minimised and compensated for by enhancing the remaining
open space. This is reinforced in the planning guidance prepared for the site.
115 The applicant has noted that the improvements proposed to the accessibility and
usability of this space will mitigate any loss, and that some of the loss of public open space was
a result of providing private gardens to all of the housing units. The proposals to re-provide
park areas and public squares ensure that the open space provided on the site contributes
effectively to the character of the redeveloped estate. Whilst the redevelopment of the estate
results in a loss of public open space, this loss is compensated by the re-provision of an
improved quality and arrangement of more usable and safer open spaces that will provide for a
range of needs.
116 The redevelopment also includes reinstatement of Melbourne Square in the southwest
corner of the estate. This remains a protected London Square even though it was demolished
in the early 1960’s to make way for the estate. The reinstatement of Melbourne Square will
add to the variety of the open space offer and provide historic value and interest. It is
considered that this approach is successful. The introduction of communal gardens/allotments
is also an initiative that is welcomed, and in accordance with the London Plan.
117 Although Lambeth Council officers have previously stated that they are comfortable
with the loss of open space in this location, and indeed have supported a previous application
that proposed a loss, it would be appropriate for Sport England to be consulted if there is a loss
of playing fields over 0.2 ha.
118 On balance, subject to the details of the landscaping and open space being secured by
Lambeth Council through the reserved matters applications, this aspect of the proposal
complies with London Plan policy.
Children’s play space
119 Policy 3D.13 of the London Plan and policy 3.6 of the draft replacement London Plan
sets out that “the Mayor will and the boroughs should ensure developments that include
housing make provision for play and informal recreation, based on the expected child
population generated by the scheme and an assessment of future needs”. Using the
methodology within the Mayor’s supplementary planning guidance ‘Providing for Children
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and Young People’s Play and Informal Recreation’ it is anticipated that there will be
approximately 795 children within the development. The guidance sets a benchmark of 10
sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided
on-site. As such the development should make provision for 7,950 sq.m. of playspace.
120 The age category will comprise the following:
0 – 4 = 310 (3,100 sq.m.)
5 – 10 = 294 ( 2,940 sq.m.)
11 – 15 = 190 (1,900 sq.m.)
121 This represents a significant population of young people at the end state of the proposed
regeneration. The strategy needs to take account of the needs of existing and future residents.
Key to this is access to play space during and after construction.
122 The application documentation incorporates a play strategy, but it is noted that
landscaping is reserved for future consideration. The scheme proposes 3,214 sq.m of formal
play space for children and teenagers, together with 1,360 sq.m. of outdoor play facilities.
Whilst there would be a range of equipped and other play spaces provided in close proximity to
homes throughout the site, the provision would represent less than half of the requirement.
However, this is offset by the availability of other open land, such as the parks and gardens,
green amenity spaces, civic spaces and doorstep play, which together amount to over 60,000
sq.m. In this instance, given the qualitative improvements, as well as provision of a network of
opportunities incorporated into the design of the scheme, it is considered that the level of play
space to be provided is acceptable and in accordance with the London Plan. The detail of the
play strategy should be secured as part of the reserved matters.
Climate change mitigation
123 The climate change policies as set out in chapter 4A of the London Plan and chapter 5
of the draft replacement London Plan collectively require developments to make the fullest
contribution to the mitigation and adaptation to climate change and to minimise carbon dioxide
emissions (policy 4A.1).
Baseline carbon dioxide emissions
124 The baseline emissions have been estimated to be 6,287 tonnes of CO2 per annum. The
emissions relating to the residential elements of the development and the main non-domestic
elements of the development have been based on modelling using Building Regulations
compliant software packages. In line with London Plan requirements, both regulated and
unregulated emissions have been taken into account.
125 The applicant should also relate the development to 2010 Building Regulations and
details of this should be provided before the application is reported back at Stage 2.
Energy efficiency standards
126 A range of passive design measures and energy efficient building services will be
adopted reducing carbon emissions to 8% below the baseline emissions. Air permeability and
heat loss parameters will be improved well beyond the minimum requirements found within
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building regulations. Other measures include high efficiency lighting and mechanical
ventilation with heat recovery (MVHR).
127 Best practise suggest that up to 25% CO2 savings can be achieved through energy
efficiency measures alone in similar developments. The applicant is requested to provide
details of investigations into where additional savings can be secured.
District heating
128 The applicant has committed to implementing a site wide heating network to supply all
the 808 new dwellings within the development.
129 A district heating network for the site has been proposed. In addition to the new build
there are 172 existing dwellings and 8 commercial units to be connected and linked to a new
district heating network. There is also provision for Myatts Field South (400 dwellings) to
connect to the network. A local school has also expressed an interest in joining the network.
The applicant should explore connecting the community and retail areas to the communal heat
network.
130 The plant will be located in the existing ‘submarine’ plant room - the energy centre for
the original Myatts Field district heating network, and will be modulated to suit the proposed
phasing programme to reflect the gradual increase of load.
131 The applicant should provide a simple schematic of the communal heating network
showing all building uses connected in to the network and how the network evolves including
indicative timescales if available.
Combined Heat and Power
132 The applicant is proposing to install a 1.8MWe combined heat and power (CHP) sized
to meet the domestic hot water and heating loads. The CHP will be the lead boiler for domestic
hot water and heating with gas fired boilers used to provide additional capacity in peak periods.
This would provide a claimed 75% reduction in carbon emissions beyond those due to energy
efficiency measures. Sizing of the CHP and the proposed Co2 savings appears to reflect the
loads of both the existing and proposed development which could link into the proposed
communal heat network. Further information on the savings relating to the new build element
should be provided.
Cooling
133 A general natural cross flow ventilation strategy has been applied to the apartments.
Mechanical ventilation and cooling will only be used in areas (the community and retail)
predicted to overheat in the summer. Cooling will be supplied to the offices and retail units by
air source heat pumps. This is an acceptable solution.
Renewable energy technologies
134 The applicant is proposing the installation of approximately 372 sq.m. (186 panels) of
photovoltaic panels, producing a 2.6% reduction in carbon emissions over and above those due
to energy efficiency and CHP. The potential for greater contributions from photovoltaic panels
are constrained due to the limited roof space (350 sq.m.).
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135 It is acknowledged that the potential for other renewable technologies is constrained
due to the characteristics of the site and the extent to which they could be successfully
integrated with CHP.
136 In summary, the proposals are broadly acceptable in principle subject to further
information and revisions. Appropriately worded conditions will be required to ensure that
every new dwelling and building shall be connected to district heating supplied with heat from
the submarine energy centre and that no less than 372 sq.m. of roof mounted solar photovoltaic
panels (with a southern component and absent of significant shading throughout the year)
should be mounted on the roof of the development.
Climate change adaptation
137 The London Plan promotes five principles in Policy 4A.9 to promote and support the
most effective adaptation to climate change. These are to minimise overheating and contribute
to heat island effects; minimise solar gain in summer; contribute to flood risk reduction,
including applying sustainable drainage; minimising water use; and protect and enhance green
infrastructure (the corresponding draft replacement London Plan policy is policy 5.3). There
are specific policies covering overheating, living roofs and water. Further guidance on these
policies is given in the Mayor’s SPG Sustainable Design and Construction. The applicant has
submitted an assessment of the scheme against the essential and preferred standards within
London Plan Policy 4A.3 and the Sustainable Design and Construction SPG.
138 Policy 4A.11 and draft London Plan policy 5.11 seek major developments to incorporate
living roofs and walls where feasible. Policy 4A.14 of the London Plan and Policy 5.13 of the
draft replacement plan seek to ensure that surface water run-off is managed as close to its
source as possible and sets out a hierarchy of preferred measures to achieve this. Policy 4A.16
of the London Plan and policy 5.15 of the draft replacement plan seek to ensure that new
development has proper regard to the impacts on water demand and existing capacity by
minimising the use of treated water and maximising rainwater harvesting.
139 The applicant has submitted a sustainability statement, which includes an assessment
against the Mayor’s essential standards. All homes would be designed to meet Code for
Sustainable Homes Level 3, and the non-residential uses would be designed to meet BREEAM
excellent standards. A sustainable drainage system (SUDS) would be installed throughout the
site, and this provision is welcomed. Other measures such as permeable paving, water butts
and rainwater harvesting are also proposed. Noting the proposed allotments/communal
gardens, provision for irrigation and composting are also welcomed.
140 It is noted, however, that there is no reference to the inclusion of green or brown roofs,
a commitment which was suggested at pre-application stage. This aspect should be reviewed
in order to comply with the London Plan, and plans provided showing where these could be
incorporated into the scheme. These commitments would need to be secured by way of
condition.
Comments from Transport for London
141 A key urban design principle for this masterplan revolves around the need to improve
the connections through the site, enabling safer routes and better connection with the wider
community and key public transport routes.
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142 Bus routes operating along the A202 Camberwell New Road,and in particular those
serving Oval and Vauxhall Underground stations, currently experience high levels of demand
and have little spare capacity in the peak periods. According to the transport assessment (TA),
this development will generate additional demand for these services in the AM peak. In order
to help mitigate this impact, and to ensure the capacity of bus services is enhanced to serve this
redevelopment, TfL requests a contribution of £270,000 (£90,000/ year for 3 years) towards
increasing capacity on the local bus network.
143 This contribution will go towards improving capacity on northbound services in the
AM peak and southbound services in the PM peak, as well as helping to satisfy information and
requirements in London Plan policies 3C.14 and 3C.20 and draft replacement London Plan
policy 6.7.
144 The transport assessment identifies a high level of personal injury accidents on Brixton
Road. Given the width and busy nature of the road, it is currently difficult to access both the
northbound bus stops and local amenities on the opposite side of the road from the site. TfL
therefore requests a contribution of £100,000 towards the installation of a new signalised
pedestrian crossing across Brixton Road, close to the junction with Mostyn Road and Lorn
Road to mitigate the increased demand for pedestrian movement across Brixton Road, improve
general road safety and satisfy London Plan policy 3C.21 and draft replacement London Plan
policy 6.10.
145 Car parking is being proposed at a ratio of 0.4 spaces per residential unit. This is
acceptable and complies with London Plan policy 3C.24 and draft replacement London Plan
policy 6.13. The provision of two car club spaces within the development is also welcomed. A
robust car parking management strategy should be prepared and agreed with the council in
consultation with TfL and secured by use of a planning condition or obligation.
146 Any on-site car parking should be provided with electric vehicle charging points in line
with emerging best practice and draft replacement London Plan policy 6.13, which states that
20% of all residential spaces must be equipped for electric vehicles (or 1 point/ 5 car parking
spaces) with an additional 20% passive provision.
147 TfL would support any future plans for a Controlled Parking Zone (CPZ) in the area
and is also supportive of any aspirations Lambeth may have for the developer to fund a study in
the area.
148 Cycle parking is proposed at a ratio of more than one space per residential unit. This is
in line with London Plan policy 3C.22 and the guidance found in draft replacement London
Plan policy 6.9.
149 A framework travel plan has been submitted and is welcomed. Whilst the travel plan is
of a good standard additional work is required before it can be considered to be in line with
TfL’s guidance on residential travel planning in London, as referred to in London Plan policy
3C.2 and draft replacement London Plan policy 6.3. The travel plan should be secured,
enforced, funded, monitored and reviewed as part of the Section 106 agreement.
150 Both a delivery and servicing plan and construction logistics plan have been submitted
as part of this application. These are welcomed and considered to be acceptable strategies for
managing freight and construction on-site. TfL requests that these are secured by an
appropriate planning condition, in order to enable the documents to be in general conformity
with London Plan policies 3C.17, 3C.25 and draft replacement London Plan policy 6.14.
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151 In summary TfL supports this development in principle subject to appropriate
mitigation being secured towards improving local bus services, improving road safety and
providing pedestrian crossing facilities on Brixton Road.
Local planning authority’s position
152 The application is likely to be considered by Lambeth Council’s planning committee in
June 2010.
Legal considerations
153 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor
of London) Order 2008 the Mayor is required to provide the local planning authority with a
statement setting out whether he considers that the application complies with the London Plan,
and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must
consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft
decision on the application, in order that the Mayor may decide whether to allow the draft
decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the
application, or issue a direction under Article 7 of the Order that he is to act as the local
planning authority for the purpose of determining the application and any connected
application. There is no obligation at this present stage for the Mayor to indicate his
intentions regarding a possible direction, and no such decision should be inferred from the
Mayor’s statement and comments.
Financial considerations
154 There are no financial considerations at this stage.
Conclusion
155 London Plan policies on estate renewal, housing, density, urban design, tall buildings,
access, child play space, climate change and transport are relevant to this application. The
application complies with some of these policies but not with others, for the following reasons:
Principle of development: The principle of estate renewal with an increased housing
provision is supported by London Plan policy.
Open space: Whilst the scheme does entail the loss of public open space, the level of
open space overall would remain the same, and the quality of open space would be
improved
Housing: The creation of additional dwellings and improved affordable housing is
acceptable in principle, together with the introduction of intermediate housing. Further
information is required to demonstrate that the proposal provides the maximum
reasonable amount of affordable housing, and that an appropriate housing mix and
tenure will be achieved in the built out scheme in order to comply with the London
Plan.
Standard of residential accommodation: The applicant has committed to providing a
satisfactory residential environment for its occupiers in terms of size and layout of the
units. These commitments should be secured by way of condition.
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Density: The proposed residential density is within the guidance range for this location.
As such the proposal complies with policies 3A.3 and 4B.1 of the London Plan.
Urban design: The proposal is broadly consistent with the design principles of the
London Plan, subject to further clarification and amendments in relation to materials
and detailed design of the blocks.
Child play space: A robust play strategy has been submitted, and the scheme is in
accordance with the London Plan and relevant planning guidance, subject to being
secured by way of condition.
Inclusive access: The applicant has committed to meeting Lifetime Homes standards,
together with provision of 10% wheelchair accessible units in accordance with London
Plan policies, but further clarification is required in relation to this and the landscaping
strategy in order to be satisfied that these commitments can be achieved in the detailed
design stages.
Climate change mitigation and adaptation: The applicant has broadly followed the
energy hierarchy in Policy 4A.1 and considered the Mayor’s SPG on sustainable design
and construction. Sufficient information has been provided to understand the proposals
as a whole and to verify carbon dioxide savings in principle, subject to clarification and
further information.
Transport: The scheme is broadly acceptable from a transport and parking perspective
subject to appropriate mitigation being secured towards improving local bus services,
improving road safety and providing pedestrian crossing facilities on Brixton Road.
156 Whilst the application is broadly acceptable in strategic planning terms, on balance the
application does not comply with the London Plan.
157 The following changes might, however, remedy the above-mentioned deficiencies, and
could possibly lead to the application becoming compliant with the London Plan:
Housing/affordable housing: Details relating to the financial viability of the scheme
should be provided before the application is referred back to the Mayor.
Urban design: Further work is required in relation to the treatment of some of the
blocks, including the proposed materials.
Climate change mitigation and adaptation: Further information should be provided
regarding baseline carbon dioxide emissions, additional energy efficiency savings and
the communal heating network as described within the energy section above. Green
and/or brown roofs and walls should also be considered and details provided. The
measures proposed would need to be secured by way of condition or s106 planning
obligation.
Transport: Further discussion is required in relation to financial contributions towards
public transport and road safety.
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for further information, contact Planning Decisions Unit:
Colin Wilson, Senior Manager - Planning Decisions
020 7983 4783 email colin.wilson@london.gov.uk
Justin Carr, Strategic Planning Manager (Development Decisions)
020 7983 4895 email justin.carr@london.gov.uk
Samantha Wells, Case Officer
020 7983 4266 email samantha.wells@london.gov.uk
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