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planning report PDU/2230a/01
14 July 2010
Swiss Cottage School, Avenue Road,
Swiss Cottage
in the London Borough of Camden
planning application no. 2010/2655/P
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
Construction of a new academy school and replacement special education needs school,
together with associated parking, access and landscaping.
The applicant
The applicant is BAM Construction Ltd, and the architect is Penoyre and Prasad.
Strategic issues
The principle of education use on this site is established by the long-standing existing use, and
the proposed redevelopment as part of the Building Schools for the Future programme is
accepted as improving educational facilities.
Whilst the design approach is acceptable, further information is required in relation to
materials and landscaping. There are also outstanding strategic issues regarding
accessibility, transport and climate change mitigation that require addressing before the
scheme can be considered fully compliant with London Plan policies.
Recommendation
That Camden Council be advised that while the application is generally acceptable in strategic
planning terms the application does not comply with the London Plan, for the reasons set out
in paragraph 70 of this report; but that the possible remedies set out in paragraph 72 of this
report could address these deficiencies.
Context
1 On 14 June 2010 the Mayor of London received documents from Camden 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 23 July 2010 to provide the Council with a statement
page 1
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.
2 The application is referable under Category 1B of the Schedule to the Order 2008:
”Development (other than development which only comprises the provision of houses, flats, or houses and
flats) which comprises or includes the erection of a building or buildings… (c) outside Central London
and with a total floorspace of more than 15,000 square metres”.
3 Once Camden 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.
4 The Mayor of London’s statement on this case will be made available on the GLA
website www.london.gov.uk.
Site description
5 The application site covers an area of 18,600 sq.m. (1.86ha) and is 500 metres south of
Swiss Cottage town centre and underground station and 500 metres north of Primrose Hill.
The site is bounded to the north by Adelaide Road, to the east by Harley Road and to the west
by Avenue Road. To the south and south-east, the site is bounded by residential properties.
The site lies within a built up area and is characterised by a mix of large detached, semi-
detached houses, purpose built mansion flats and high-rise residential development.
6 The site is currently occupied by two schools – the Swiss Cottage Special School and
the Frank Barnes School for Deaf Children. The Swiss Cottage School is an education
establishment catering for children and young people (from 2 to 16 years old) with complex
needs, specialising in cognition and learning. The school is currently operating at capacity and
has 144 students enrolled. The Frank Barnes School for Deaf Children offers a mainstream
primary school curriculum that is taught through British Sign Language. The school has a
capacity for 44 children between three and eleven years who are deaf and currently has 35
children enrolled from over 16 London boroughs and further a field. The schools consist of a
range of low-density, one and two storey buildings with some external spaces and play zones.
7 The nearest Strategic Road Network (SRN) is the A400, which is located approximately
4.5km south east of the site. The closest Transport for London Road Network (TLRN) is the
A41 Finchley Road located north-west of the site. The nearest London Underground Station is
Swiss Cottage (on the Jubilee Line) which is located approximately 0.3km north-west of the
site. St Johns Wood Underground Station is also located approximately 1.1km south of the site.
There are nine bus routes that serve the area surrounding the site. The site has a Public
Transport Accessibility Level (PTAL) of between 5 and 6a, on a scale where 1 is low and 6 is
high.
Details of the proposal
8 Detailed planning permission is sought for redevelopment of the site to provide a new
UCL-sponsored 1150 pupil academy and a replacement 230 pupil special needs school. The
two buildings would be connected by a series of outdoor areas, together with parking and
landscaping.
page 2
9 The UCL Academy would be six storeys in height, and include a new library, museum
and theatre. Two multi-use games areas (MUGA), a sports hall, shared courtyard and outdoor
podium are proposed, together with several levels of external terraces.
10 The second school, known as the Swiss Cottage Specialist SEN School would be four
storeys in height, and would be divided into three schools – upper, middle and lower. It would
include conference rooms, a hydrotherapy pool and outdoor learning areas.
11 The Adelaide Road site has been identified by Camden Council as one of two ‘sample
schemes’ as part of the Building Schools for the Future Programme (BSF). The Camden BSF
programme has been developed to accommodate an additional 1,200 pupils aged 11 to 16
(equivalent to eight forms of entry) within the borough, plus 530 post-16 places.
Case history
12 This application follows on from an outline planning permission that was granted in
November 2008 for an 1150 pupil academy, a replacement 230 pupil special education needs
school, together with 3,400 sq.m. of residential accommodation. The Mayor considered this
scheme in November 2008 (ref PDU/2230), where the principle of a new school was accepted.
It was noted that the application documents were lacking detail (due to the outline nature of
the application) and many of the requirements normally expected to be secured were being
dealt with by way of condition. It was noted that that the applicant was reluctant to provide
further details to aid the assessment of the scheme, because of the costs involved, noting that
outline permission was being sought to secure BSF funding.
13 There are some minor differences between the two schemes, mainly relating to the
footprint of the building, to account for site constraints caused by a Network Rail tunnel and
Thames Water sewer. This has resulted in there being no buildings proposed over the central
part of the site. Further design changes include broadening the range of external play spaces
and maximising daylight access. The residential element of the scheme has also been removed.
14 In considering the previous application, concern was raised regarding the need to move
the Frank Barnes School for Deaf Children, particularly given the lack of clarity regarding a
final location. Camden BSF has confirmed that planning permission has been granted for the
temporary relocation of the Frank Barnes School at a former leisure centre near the Kings
Cross regeneration area. It is intended that it will finally be located in a new school within
Kings Cross and an application is due to be submitted shortly in respect of the new permanent
school. This has been secured by a legal agreement.
Strategic planning issues and relevant policies and guidance
15 The relevant issues and corresponding policies are as follows:
Education/ community facilities London Plan
Urban design London Plan; PPS1
Inclusive design and access London Plan; PPS1; Accessible London: achieving an inclusive
environment SPG; Planning and Access for Disabled People: a
good practice guide (ODPM); Planning for Equality and
Diversity in Meeting the spatial needs of London’s diverse
communities SPG; Diversity and Equality in Planning: A good
practice guide (ODPM)
Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22;
draft PPS Planning for a Low Carbon Future in a Changing
page 3
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/parking London Plan; the Mayor’s Transport Strategy; PPG13;
Noise London Plan;
16 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 Camden Council Unitary Development Plan
(adopted 2006) and the London Plan (Consolidated with Alterations since 2004) February
2008.
17 The Camden Core Strategy (Submission Stage) and the draft replacement London Plan,
published in October 2009 for consultation, are also material considerations.
Education and community facilities
18 The London Plan seeks to support and maintain high quality educational opportunities
and life choices for London’s children. London Plan policy 3A.24 specifically relates to the
provision of education facilities. The policy notes that borough councils need to provide a
criteria based approach to the provision of new facilities and the expansion of existing facilities,
taking into account the need for new facilities, the potential for expansion of existing provision
and other policies within the London Plan. Draft replacement London Plan policy 3.19 also
supports development proposals which enhance education and skills provision.
19 The need for new facilities at the site has been identified by Camden Council in selecting
the Swiss Cottage School as one of two ‘sample schemes’ under the BSF programme. The
design and access statement notes that all of the buildings on site would require major work if
they were to be retained and reused as educational facilities, and their environmental
performance would be unsatisfactory. The redevelopment of the site to provide new modern
facilities will therefore enhance education facilities and provide the additional secondary school
places as well as the improved facilities for special needs children as required by Camden
Council. The Government’s recent announcement places this school in the “sample – for
discussion” category.
20 Paragraph 3.113 of the London Plan states that London’s school age population is
projected to increase by eight percent by 2016 and that Boroughs should ensure adequate
school provision to cope with this increase. The proposals will bring about an increase of
10,601 sq.m. in educational floor space on the site. The number of pupils on site will increase
by 1,192 compared to current levels. This is equivalent to a 227% increase in the educational
floorspace and a 634% increase in the number of pupils. Whilst the proposal represents a
significant increase in the amount of development on the site, compared with the existing
educational uses, the proposal will allow for more efficient and intensive use of the schools
resource and the uplift in pupil places is welcomed. It is noted that the actual footprint of the
buildings remains largely similar in size, with further provision being made for outdoor
facilities and sports courts, for example. The principle of redevelopment has been accepted
through the grant of outline planning permission.
Table 1: existing, approved and proposed development comparison
Existing Approved Proposed
Pupils on site 188 1,380 1,380
Staff on site 120 350 281
page 4
Education floorspace (sq.m.) 5,731 16,332 18,753
Parking provision 14 17 21
21 London Plan policy 3A.24 ‘Education facilities’ sets out that the use of the educational
facilities should be maximised out of school hours. This use of the school facilities by the local
community is also encouraged by London Plan Policy 3A.18 ‘Protection and enhancement of social
infrastructure and community facilities’ and the London Plan Policy 3D.6 ‘The Olympic and
Paralympic Games and sports facilities’.
22 The proposals for replacement education and sports facilities are compliant with
London Plan policies, and the applicant notes that given the location at a transport hub,
adjacent to a community library and leisure centre, that the academy will become an important
civic amenity, especially in its contribution to the Camden Campus for Learning and wider
audiences of community learning. The commitments in terms of community use of the schools
should be secured through a relevant planning condition, or section 106 obligation, in order to
ensure compliance with London Plan policies.
Urban design
23 Good design is central to all objectives of the London Plan and is specifically promoted
by the policies contained within Chapter 4B (‘Design principles for a compact city’) 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
maximising the potential of sites, tall and large-scale buildings, built heritage, views, and the
Blue Ribbon Network.
24 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.
25 The site is currently occupied by two separate school buildings. The Swiss Cottage
Specialist SEN School is a typical 1960’s school building with a number of more recent
additions. The Frank Barnes School is a smaller school building for deaf students, and is a 2-
storey 1970’s building. Neither of the existing buildings are considered to be of any significant
architectural merit. The applicant is proposing the demolition of both buildings and the re-
provision of a new UCL sponsored academy and an improved SEN school building with an
increased capacity from 150 students to 230. This approach is acceptable, and the principle has
been established through the granting of the outline planning permission.
26 The proposal seeks to re-enforce the urban block. The new school buildings are located
so as to line up with existing residential buildings along Avenue Road and Harley Road. This
approach creates a feeling of building continuity along the street, and also helps improve
definition and overlooking of the surrounding streets, which is acceptable.
Conservation area impacts
27 The site is adjacent to the Elsworthy Road Conservation Area, which is characterised
by 3 and 4-storey urban Victorian housing. The smaller elements of both schools are located
adjacent to this conservation area, which helps to create a more sympathetic relationship. The
page 5
height, location and form of the new school buildings sit comfortably alongside these existing
buildings and are acceptable.
28 The new buildings adopt a contemporary architectural style that would be clearly
recognisable and distinctive from existing buildings in the Conservation Area. However,
further information on the materials should be provided to allow a more complete assessment
of this impact.
UCL Academy
29 The UCL school building is a linear block that fronts onto Adelaide Road and wraps
around the corners of Avenue Road and Harley Road. The building acts as a noise shield
protecting the quieter play spaces behind from the busy Adelaide Road. The building would
include a ventilation and cooling system that would allow building users to open or close
windows, and for classrooms to remain suitably cooled.
30 This building varies in height from 2 and 3-storeys along Harley Road adjacent the
Elsworthy Conservation Area, and rises up to 6-storeys along the busier Adelaide Road. The
proposed heights are comparable to other existing buildings along both Harley Road and
Adelaide Road. The general location, form and heights are acceptable at a strategic planning
policy level.
31 The UCL building would be highly visible at the junction of Avenue Road and Adelaide
Road and the applicant has sought to create a focal point at this corner through the use of a
strong architectural expression. This approach is broadly supported.
32 The UCL building design has a variety of window placements and sizes, which add a
level of interest to the elevation treatment of the building. However, further detailed design
information on the main corner (Avenue Road and Adelaide Road junction) along with further
information on the materials, window arrangements and colouring should be provided to allow
a better understanding of the visual impact of this building and in particular its relationship
with the Elsworthy Conservation Area.
33 The energy centre is located on the ground floor of the Harley Street elevation, which
raises some concern as to the level of future interaction with the street and the quality of the
future street scene along this road. Further design information should be provided to address
this concern.
34 Along Avenue Road, the two school buildings are separated by two large multi use
games areas (MUGA). The applicant should provide further detail on the boundary and
building elevation treatment between the MUGA areas and the street.
35 Two pedestrian / cycle access points are proposed. The primary point is located along
Adelaide Road and allows a clear and direct connection with Swiss Cottage station. A second
entry / exit point is located along Harley Road. The provision of two pedestrian access points
is welcomed. A combined vehicle and servicing access point is providing along Harley Road
and the impacts of this new vehicle access point should be discussed in more detail with TfL
and the local transport team. The applicant has provided some design detail on the main entry
points to the UCL building, which should help improve legibility and way-finding in the area.
page 6
Fig 3: UCL Academy – north elevation from Adelaide Road (Source: Design and Access
Statement)
Fig 4: UCL Academy – east elevation from Harley Road (Source: Design and Access
Statement)
SEN building
36 The Swiss Cottage Specialist SEN (special educational needs) school building would be
rebuilt as a separate school building and located in the same place as the existing SEN junior
school building. The new building is 3-storeys in height, which is broadly comparable with
other existing buildings along Avenue Road and within the Elsworthy Conservation Area.
37 The new SEN building would be located slightly back from the pavement and would
include a drop off point in front of the school along Harley Way, as is the case with the existing
building. The success of this drop off point will be highly dependent on its detailed design. In
particular the applicant should provide further information on the boundary treatment between
the drop off point and the street, along with information as to the management of this area at
peak times. Parking along the street should be avoided where possible.
Fig 1: View from south-east to Swiss Cottage Specialist SEN School (Source: Design and
Access Statement)
Amenity space
38 The application includes a range of amenity areas across both sites, from dedicated
small scale ground level and roof terrace open spaces, to larger multi-use games (MUGA) play
areas (internal and external). The applicant should confirm the overall quantum of play space
provided and should set out how access to these varying play spaces would be managed
between both schools.
Accessibility and inclusive design
39 London Plan Policy 4B.5 ‘creating an inclusive environment’ and corresponding draft
replacement London Plan policy 7.2 expects all future development to meet the highest
standard of accessibility and inclusion. This together with the Supplementary Planning
Guidance ‘Accessible London: achieving an inclusive environment’ underpins the principles of
inclusive design and the aim to achieve an accessible and inclusive environment consistently
across London. Inclusive design principles, if embedded into the development and design
process from the outset, help to ensure that all of us, including older people, disabled and deaf
people, children and young people, can use the places and spaces proposed comfortably, safely
and with dignity. The aim of Policy 4B.5 is to ensure that proposals achieve the highest
standards of accessibility and inclusion not just the minimum. Furthermore, educational
establishments have a duty under the Disabilities Discrimination Act 2005 to ensure that their
facilities and services are accessible for disabled students.
40 An access statement has been submitted by the applicant, confirming that the scheme
will comply with Part M, and Building Bulletin 102 (which sets out special educational needs
standards). Power-assisted doors are proposed, together with wide corridors and accessible
toilets. Three passenger lifts are proposed for the Academy and five for the SEN School, and
page 7
are located close to main entrances to each section. The SEN school would include generous
provision of hoists and open circulation, and the bus drop-off and collection area is suitably
located and covered. The careful consideration in terms of a fire strategy is welcomed.
41 It is noted that to ensure even levels across the site and also the interface with the
specialist school, the primary entrance route requires a 1:20 ramp with adjacent stepped route.
Further clarification that there are no alternative options that negate the requirement for
ramps of this gradient should be provided before the application is referred back at stage 2.
Further information should be provided regarding ease of access throughout the shared
courtyards and sports areas to show how people of all abilities access and navigate the site.
Otherwise, the proposed development has been designed to allow step-free access to all areas
and the environment has been designed to be fully accessible and inclusive in line with London
Plan Policy 4B.5 and emerging policy 7.2.
Climate change mitigation and adaptation
42 The London Plan climate change policies as set out in chapter 4A collectively require
developments to make the fullest contribution to tackling climate change by minimising carbon
dioxide emissions, adopting sustainable design and construction measures, prioritising
decentralised energy supply, and incorporating renewable energy technologies with a target of
20% carbon reductions from on-site renewable energy. The policies set out ways in which
developers must address mitigation of, and adaptation to, the effects of climate change. Policies
4A.2 to 4A.8 of the London Plan focus on how to mitigate climate change, and the carbon
dioxide emissions reduction targets that are necessary across London to achieve this.
43 The corresponding policies in the draft replacement London Plan are set out in Chapter
5. These policies follow the same general approach with respect to the energy hierarchy but
places greater emphasis on minimising carbon dioxide emissions and making use of
decentralised energy systems and networks.
Energy
44 London Plan policies 4A.4-11 focus on mitigation of climate change and require a
reduction in a development’s carbon dioxide emissions through the use of passive design,
energy efficiency and renewable energy measures. The London Plan requires developments to
make the fullest contribution to tackling climate change by minimising carbon dioxide
emissions, adopting sustainable design and construction measures and prioritising
decentralised energy, including renewables.
Baseline emissions
45 The carbon dioxide emissions of the proposed development have been modelled using
building regulations compliance modelling software. The baseline emissions are estimated as
36kg carbon dioxide per sq.m. and 42kg carbon dioxide per sq.m. for the Academy and
Specialist School respectively. These estimates include unregulated emissions in line with
London Plan requirements. However, the applicant should also provide the combined annual
tonnes of carbon dioxide emissions for a 2006 Part L compliant development, including
unregulated emissions.
Energy efficiency standards
page 8
46 The development will incorporate a wide range of passive design features and demand
reduction measures. Both air permeability and heat loss parameters will significantly exceed
the building regulations requirements. Energy efficient lighting and controls will be adopted,
as well as low velocity mechanical ventilation systems. The overall effect of the measures is to
reduce emissions 52% beyond the baseline emissions. This level of energy efficiency is
welcomed. Output sheets from the modelling exercise should be provided to support these
saving figures for energy efficiency.
District heating
47 The applicant should investigate whether the proposals are in the vicinity of any
existing or planned district heating schemes. Where this is the case, the possibility of linking
the development into the district heating network should be evaluated. Further information is
required in this regard.
48 The heating systems for the academy and the school appear to have been considered
independently. The applicant should investigate the possibility of linking the heating systems
for the two buildings via a single site wide heating network and supplying the heat for the
network from a single energy centre.
Combined Heat and Power
49 Given the type of buildings in question, with their relatively short operating hours and
limited heat load, it is accepted that CHP is unlikely to be applicable to this development.
Cooling
50 Overhangs and solar control glass will be used to minimise unwanted solar gains in
summer. The remaining active cooling requirements, e.g. for the IT and server rooms, will be
provided using ground source heat pumps operating in cooling mode. Where possible, cooling
of the IT rooms will be provided using the ground coil without operating the heat pump.
Renewable energy technologies
51 A combination of ground source heat pumps, 216 sq.m. of solar thermal collectors and
565 sq.m. of photovoltaic panels will be used to provide a further reduction in carbon emissions
from renewable energy of 27% and 23% in the academy and Swiss School respectively.
52 Taking into account the cumulative effect of energy efficiency measures and renewable
energy, reductions of 65% and 63% compared to a 2006 Building Regulations compliant
development, including unregulated emissions, will be achieved for the Academy and School
respectively.
Climate change adaptation
53 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. Specific policies cover overheating, living roofs and walls and water. These
policies have also been carried over into the draft replacement London Plan.
54 The energy and sustainability assessment includes details of how the proposals will seek
to achieve a BREEAM ‘Excellent’ rating, and reduce target emission rates through PassivHaus
page 9
measures. A BREEAM pre-assessment has been provided. Reference to the Mayor’s essential
and preferred standards for sustainable design and construction (as set out in the Sustainable
design and construction SPG) has not been provided, but the commitments made in terms of
natural ventilation, energy efficient lighting, sustainable urban drainage, green roofs, water
consumption and rainwater harvesting are welcomed and should be secured by condition.
Transport for London comments
55 In considering the previous outline planning application, it was noted that there was a
lack of information or mitigation relating to buses. Other points noted included the need to
address pedestrian movement at the gyratory and that a robust travel plan to support the
development was required. The information submitted with the current application is such
that the car and cycle parking proposals are now considered acceptable, and the travel plan is
acceptable subject to supply of some further information. With regard to the gyratory and
pedestrian movement, TfL has been in discussion with the applicant’s consultant and whilst
progress has been made an agreed position is yet to be reached.
56 The main pedestrian entrance to the UCL Academy School is proposed to be located on
the southern side of Adelaide Road. Therefore, the design of the pedestrian crossing facilities
must support the desire lines and projected increase in pedestrian demand generated by the
school. A staggered pedestrian crossing is proposed between the junctions of Adelaide
Road/Avenue Road and Adelaide Road/King Henry’s Road. However, in order for this to
operate effectively, it must be fully linked to the existing junctions at either end of Adelaide
Road. This proposal would considerably increase the cost of TfL’s proposed gyratory scheme
and these works would need to be agreed with TfL and funded by the applicant as part of a
section 278 agreement, secured through the section 106 agreement
57 This development will result in an additional 551 bus trips in the peak hours, which
equates to eight additional double decker buses. Therefore, the proposal will have a significant
impact on the bus network. Although there will be some excess capacity on routes in close
proximity to the school, some additional capacity will be required on heavily used routes.
Therefore it is essential that a directional split of trips for the trip generation be provided so
that it is made clear as to which routes and corridors would be affected. In addition, a bus stop
audit of the stops used by students should be carried out in order to ascertain that the increased
demand can be accommodated, and improvements secured accordingly. The applicant should
work with TfL to address this issue and the implementation of any possible mitigation
measures to ensure conformity with London Plan policy 3C.2 and draft replacement London
Plan policy 6.2.
58 This development will result in large numbers of additional pedestrians using the
surrounding pedestrian footways. Whilst it appears that the existing footways on Avenue
Road and Adelaide Road will be able to cope with the increase, it will be important to ensure
the areas around the bus stops can accommodate the increase of waiting passengers. In line
with London Plan 3C.21 and draft replacement policy 6.10, there should be adequate footway
space around the bus stops, unhindered for other pedestrians and particularly for disabled
users. TfL recommends that a pedestrian environment review system (PERS) audit is
undertaken to ensure the applicant has explored all opportunities to improve pedestrian links
to the surrounding area.
59 A total of 27 car parking spaces have been proposed, which includes 19 standard bays
and 8 blue badge spaces. This is in general conformity with London Plan policy 3C.23 and draft
replacement policy 6.13. It is noted that car parking is in accordance with Camden’s Unitary
Development Plan (UDP) and emerging LDF. The restriction on provision of visitor parking
page 10
is welcomed and conforms with London Plan policy 3C.17 and draft replacement London Plan
policy 6.3.
60 This proposal includes 170 cycle spaces (1 per 10 pupils/staff at both the UCL Academy
and SCSSS), which is consistent with draft revised London Plan Table 6.2. The provision of 40
cycle spaces for visitors is supported, and allows expansion of cycling as predicted by the travel
plan for the UCL Academy. In order to realise the aspirations of the travel plan and maximise
this mode shift, it is recommended that the applicant investigate additional measures to
improve cycle routes to the schools. Large numbers of cyclists will be accessing this site and,
whilst this is supported in principle, more information is required on how cyclists will navigate
from the cycle storage areas to the cycle paths and onwards. The provision of showers and
changing facilities for the staff and students at both schools is welcomed, but it is recommended
that secure locker rooms be installed. Further commitments are required to ensure that the
proposals are in general conformity with London Plan policy 3C.22 and draft replacement
London Plan policy 6.9.
61 It is noted that the travel plan submitted by the applicant is not satisfactory in terms of
the ATTrBuTE assessment used by TfL to assess the content. However, there are a number of
positive aspects which are in general conformity with London Plan (2008) policy 3C.2, together
with draft replacement London Plan policies 6.3 and 6.11. TfL has made a direct request to the
Council that some further work be undertaken prior to the travel plan being agreed.
62 A construction management plan and a delivery and servicing plan should be provided,
in line with the London Plan (2008) policy 3C.25 and draft replacement London Plan policy
6.14. TfL has directly requested that the Council require further work be undertaken on these
documents prior to them being agreed.
63 It has been concluded by TfL that due to the proximity to London Underground
stations and size and nature of the development, there will be a negligible impact upon London
Underground Services.
Noise
64 In considering the previous application, it was noted that there were several potential
noise issues that were not considered in the acoustic strategy report provided by the applicants.
This included noise impacts on the school, particularly the external teaching areas such as the
games areas at the northern and southern ends of the site, where noise levels may exceed the
recommendations of BB93, which is a building bulletin for classroom acoustics. BB93 states
upper limits for indoor ambient noise levels in different types of rooms in schools, the purpose
being to allow for clear communication of speech between teacher and student and for other
student activities, including music performance. These form the base criteria for design of the
building envelope.
65 An updated acoustic strategy has been submitted by the applicant which outlines the
measures proposed in order to meet relevant standards, including ventilation treatment,
suspended floors and absorption panels. The commitments that have been set out should be
secured by condition to ensure compliance with London Plan policy 4A.20.
Local planning authority’s position
66 It is understood that the planning application is due for consideration by Camden
Council in August 2010.
page 11
Legal considerations
67 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. 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
68 There are no financial considerations at this stage.
Conclusion
69 London Plan policies on education and community facilities, design, accessibility,
sustainable development, transport and noise are relevant to this application. The application
complies with some of these policies but not with others, for the following reasons:
Education and community facilities: the principle of education use on this site is
established by the long-standing existing use and the proposed redevelopment as part of
the Building Schools for the Future programme is accepted as improving educational
facilities. The education and community uses are compliant with London Plan policies
3A.24 and 3A.18.
Design: The design approach is broadly supported, with acceptable layouts and
relationship with surrounding buildings. Further information is required in relation to
materials and elevational treatment to ensure compliance with London Plan design
policies in Chapter 4B.
Accessibility and inclusive design: The proposal is broadly in accordance with
London Plan Policy 4B.5 relating to providing an inclusive environment, subject to
further information being provided in relation to ramps and gradients.
Climate change mitigation and adaptation: The proposals are acceptable in principle,
subject to further information and revisions in relation to the energy strategy.
Transport: The car and cycle parking proposals are acceptable, but there are several
issues which require further work before the proposals can be accepted as fully
compliant with London Plan transport policies 3C.23, 3C.22, 3C.20, 3C.19 and 3C.2.
Noise: Suitable measures have been incorporated into the design of the scheme to
ensure that the scheme achieves relevant standards for educational standards, in
accordance with London Plan policy 4A.20.
70 Whilst the application is broadly acceptable in strategic planning terms, on balance, the
application does not comply with the London Plan.
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71 The following changes might, however, remedy the above-mentioned deficiencies, and
could possibly lead to the application becoming compliant with the London Plan:
Design: To enable a complete assessment of the impact upon the conservation area,
further information regarding materials is required before the application is referred
back at stage 2. In addition, details regarding elevational treatment for the energy
centre and MUGA, and the overall quantum of play space should be provided.
Accessibility: Further information is required in relation to the ramps and gradients of
the site, and the ease of navigation through external areas as detailed in the report
above.
Climate change: Further details should be provided in relation to baseline carbon
emissions, energy efficient measures, district heating, the CHP and cooling systems.
Transport: Further information on the direction of travel of the additional bus users
from this development is required, so that the impact on the network can be accurately
assessed and contributions can be calculated accordingly. TfL will need to agree the
junction design and proposals for the pedestrian crossing of Adelaide Road given the
traffic constraints of the gyratory.
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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