planning report PDU/2616/01
17 November 2010
in the London Borough of Havering
planning application no. P1451.10
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 application proposes the development of 242 new residential units, provided as 194 houses
and 78 flats. Building heights range between 2 and 3-storeys. The scheme also proposes 375
car parking spaces and a range of amenity spaces of varying sizes and design.
The applicant is Havering Council, and the architect is LDA design.
The loss of local open space is disappointing, however, given the surplus of existing open
space in this area this could be acceptable. The reprovision of the existing sports pitches to a
better design standard on an alternative site could be acceptable, however, further information
is required on this.
In addition, there are also a number of more detailed planning policy concerns in relation to
housing mix and affordable housing, housing design standards, transport and the
proposed level of car parking, the energy strategy, climate change mitigation measures,
urban design and a design code, access and inclusive design, and flooding.
That Havering 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 87 of this report; but that the possible remedies set out in
paragraph 89 could address these deficiencies.
1 On the Mayor of London received documents from Havering 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 November 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.
2 The application is referable under Category 1A and 3C of the Schedule to the Order
‘Development which comprises or includes the provision of more than 150 houses, flats, or
houses and flats.’
‘Development which is likely to prejudice the use as a playing field of more than 2 hectares of
land which is used as a playing field at the time the relevant application for planning
permission is made.’
3 Once Havering 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
5 The site is located at Gooshays Drive, in the Harold Hill area of the London Borough of
Havering. The site is 5.69 hectares in size and is bound by the Central Park Sports Centre to
the north, Gooshays Drive to the west, Paines Brook and the Central Park to the east, with
Petersfield Avenue to the south. The surrounding area is primarily comprised of two storey
houses. Hilldene shops are approximately 400 metres to the west of the site.
6 The site is open land and is designated as land for parks, open space and playing fields,
with over 95% of the site currently undeveloped. The site is controlled by Albemarle Youth
Centre and the site is not readily open to the public. It is used by members of the youth club
and by Romford Royals football club. The remainder of the urban block, outside the red line
boundary, is used for a range of community facilities.
7 The site is located to the east of Gooshays Drive, approximately 700 metres north of the
A12 Colchester Road which forms part of the Transport for London Road Network. Within
400 metres, the site is served by 3 bus routes, with the nearest bus stops located on Gooshays
Drive and Petersfield Avenue. It has been demonstrated that the site records a low public
transport accessibility level of 2, on a scale of 1-6, where 1 is the lowest.
Details of the proposal
8 This is an outline planning application submitted by Havering Council. The details of
appearance, layout, landscaping and scale will be determined as reserved matters. The
proposed masterplan layout is indicative only. This application seeks to establish the principle
of residential development on this site.
9 The outline application does set out the following development parameters;
242 residential units, with 194 houses and 48 flats
A maximum building height of 3 residential storeys
Vehicular access point from Gooshays Drive and from Petersfield Avenue
375 car parking spaces, equivalent of 1.55 spaces per unit
Cycle parking at a ratio of 1 space per dwelling and 2 for larger dwellings
Minimum of 1,660 sq.m. of child play space
10 There is no relevant strategic planning case history for this site. However, a pre-
application meeting between the GLA and applicant was held on 2 August 2010 and a formal
pre-application report and letter were issued to the applicant on 17 August 2010.
Strategic planning issues and relevant policies and guidance
11 The relevant issues and corresponding policies are as follows:
Land use principle London Plan; PPG17, draft PPS Planning for a Natural and
Housing London Plan; PPS3; Housing SPG; Providing for Children and
Young People’s Play and Informal Recreation SPG, Housing
Strategy; Interim Housing SPG; Housing SPG EiP draft
Urban design London Plan; PPS1
Access London Plan; PPS1; Accessible London: achieving an inclusive
environment SPG; Planning and Access for Disabled People: a good
practice guide (ODPM)
Energy and climate change 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;
Flooding London Plan; Mayor’s draft Water Strategy; PPS25, RPG3B
Biodiversity London Plan; the Mayor’s Biodiversity Strategy; PPS9; draft PPS
Planning for a Natural and Healthy Environment
12 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 2008 Havering Council Core Strategy and the
London Plan (Consolidated with Alterations since 2004).
13 The following are also relevant material considerations:
The draft replacement London Plan, published in October 2009 for consultation.
Land use principle
14 Havering Council’s 2008 proposals map identifies the site as land for ‘Parks, open space,
playing fields and allotments’. The site is not designated as Metropolitan Open Land or Green
15 The existing site is 5.69 hectares and is largely comprised of open space and sports
pitches. The applicant proposes to build 242 new homes on the site, which would result in a
loss of the existing open space and sports pitches. The applicant proposes to reprovide 0.8
hectares of open space on site as part of this application, and to also provide 2.66 hectares of
new sports pitches and open space at a new site at Boxhill, which is 1.1 miles walk from the
site. This leaves a shortfall of 2.23 hectares of open space.
16 PPG 17 states that ‘existing open space, sports and recreational buildings and land should not
be built on unless an assessment has been undertaken which has clearly shown the open space, or buildings
are surplus to requirements.’ The applicant is required to demonstrate that any loss of open space
caused by this application is based on a detailed review of local open space needs and is in line
with PPG 17 requirements.
17 Policy 3.20 of the draft replacement London Plan states that ‘Proposals that result in the
net loss of sports and recreation facilities, including playing fields should be resisted.’ Also, the
supporting text (paragraph 7.48) for policy 7.18, states that the loss of local open space should
be resisted unless equivalent or better quality provision is made in the local catchment area.
18 Havering Council Core Strategy policy DC18 expands on this stating, that the Council
will seek to retain this type of land and that ‘Any loss of open space to a non recreation/leisure use
must be accompanied by an improvement to the quality of open space in the vicinity or to remedying
qualitative and quantitative deficiencies in open space elsewhere in the Borough.’
19 In line with the above policy requirements, the applicant has prepared a detailed open
space report, which looks at the provision of allotments, natural and semi natural green space,
public parks, play space and sports pitches in the wards of Gooshays, Heaton and Harold
Wood. The report concludes that within this area there is a deficiency in the provision of sports
pitches and allotments and that there is a surplus provision of open space, play space and
natural and semi natural green space.
20 The Council is proposing to address this deficiency in allotments by providing a new
allotment at the former Ingrebourne Primary School. This approach is acceptable, however,
further detail on this is required to ensure that this approach does adequately address this
deficiency in allotments. Subject to this additional information, the key outstanding issue to be
addressed is the proposed loss of sports pitches.
21 PPG 17 allows the exchange of one ‘open space’ site for another. However, for this to be
acceptable the new site must be accessible for use by the same local people and also the new site
should be equivalent in terms of size, usefulness, attractiveness and quality.
22 Paragraph 13 of PPG17 states that ‘Wherever possible, the aim should be to achieve
qualitative improvements to open spaces, sports and recreational facilities’, while paragraph 15 states
that ‘planning permission for such developments should not be allowed unless…. the playing fields that
would be lost as a result of the proposed development would be replaced by a playing field or fields of
equivalent or better quality and in a suitable location’. In response the applicant is proposing;
To reprovide 0.8 hectares of open space within the application site
To provide 2.66 hectares of new open space and sports pitches at a new site at Boxhill.
The Boxhill site is a 1.1 mile walk or a 1.3 mile drive from the application site. This is a
long distance from the site and the applicant should confirm that there are no
alternative suitable locations closer the application site. The new open space and sports
pitches would provide a better quality facility with a larger number of sports pitches
than the existing site. The applicant should confirm how many additional sports pitches
would be provided and should also provide additional design detail as to how an
improved facility would be achieved and secured as part of this application.
The sale of the Gooshays Drive site would also help to fund physical and access
improvements to Central Park
23 In summary, there is a surplus provision of open space, natural space and play space
within PPG17 study area. There is a deficiency in allotment space provision in this area,
however, this is set to be addressed by the Council and further information on this is required.
There is a deficiency in sports pitches however, the applicant is proposing to provide
additional, better quality pitches at a nearby location. The overall loss of open space is
disappointing, however, subject to the provision of additional detail on the new sports pitches
and the views of Sport England, which are not known at the time of writing this report, this
approach could be acceptable in this case.
24 The application proposes a total of 242 new residential units, including 194 houses and
25 A total of 36 affordable housing units would be provided, which equates to 15%. All of
these units would be intermediate with no social rented housing proposed.
26 The applicant (Havering Council) has stated that the low level of affordable housing is
as a result of the Council’s ambitions to sell this site with the benefit of a residential planning
permission, and to use the sale receipts to fund regeneration programmes elsewhere in the
Harold Hill ambitions area, which total £13 million. These projects include;
Improvements to open space facilities at Central Park
New library at Hilldene
Provision of a youth centre
Improvements to Hilldene shopping precinct
Improvements to road and pavements in the area
Improvements to Dagnam Park
27 The applicant has submitted a detailed financial appraisal to justify this approach. The
appraisal includes four assessments that allows for a comparison between different levels of
affordable housing i.e. 50%, 30% and 15%. These models also include variations in the levels of
social rented and intermediate housing.
28 Based on a review of the financial appraisals, there are a number of detailed questions
that need to be addressed in greater detail before this approach can be supported, including;
Confirmation that the proposed 17% developers profit is sufficient for a private
developer to secure the necessary finance lending.
Further discussions on the identified £400,000 section 106 financial contribution for
Justification as to why the sq.m. build costs for the houses exceeds the toolkit
Further discussion as to the ability to secure HCA grant funding.
The applicant should clarify who would provide the affordable housing payment of
£3,829,710 as set out in scenario 3.
Has the cost of constructing wheelchair units been factored into the build costs?
Clarification should be provided as to the residual value achieved in scenario 1 (30%
affordable housing), which as presented in the toolkit appears higher then the residual
value for scenario 3.
29 The toolkits demonstrate a sliding level of sale receipts based on the varying level of
affordable housing and tenure split, from a deficit of £3.2 million for the 50% affordable
housing scheme, to a profit of £4.8 million for the 15% affordable housing with 100%
intermediate housing. The applicant is proposing the later option as the affordable housing
offer for this application.
30 Given the regeneration benefits and social infrastructure that these monies would
deliver in this deprived outer London area, the principle of this approach can be supported.
However, to ensure the profit from this scheme is used to deliver these regeneration benefits
there is a need to have a further discussion around the ability to secure this as part of a legal
agreement with this application, and the appropriateness of this compared to the tests in
Circular 5/05 and regulation 122 of the CIL Regulations. This issue will need to be
satisfactorily resolved before this application is reported back to the Mayor.
31 London Plan policy 3A.9 identifies a London wide tenure split of 70:30 social rented:
intermediate housing. Draft replacement London Plan (2009) policy 3.12 identifies a London
wide need to provide 60% social rented and 40% intermediate housing. Havering Council’s
Core Strategy identifies a tenure split of 70:30 social rented: intermediate, based on local
32 This application proposes that all of the affordable housing units be provided as
intermediate units and that no social rented units are included, which is not line with London
33 However, London Plan Housing SPG (paragraph 18.9) notes that in areas with
significantly above the London average proportion of existing social rented provision (25% as
of 2005), it may be appropriate to provide a level of intermediate housing higher then the norm.
In this case the surrounding ward of Gooshays has 42% social rented housing and less than 1%
34 Given this very high proportion of existing social rented units in the surrounding area,
the approach presented in this application would help to create a mixed and balanced
community and can be accepted in this instance.
35 The application includes a mix of one, two, three and four bed units, with a detailed
breakdown shown in the able below;
36 The Mayor has published his statutory Housing Strategy. Policy 1.1C of this strategy
identifies a demand for more family sized homes in London, particularly affordable homes. The
policy states that 42% of social rented homes and 16% of intermediate homes should be three
bedrooms or more.
37 In addition, Havering Council Core Strategy policy requires that 35% of private housing
should be provided as 3 bed+ family units.
38 As evident from the table above this application does have a broad mix of housing types.
Across all tenure types 50% of all units are 3 bed+ units, and within the affordable element 55%
of units are 3 bed + units, which is acceptable.
39 The application proposes 242 residential units, on a site that is 5.69 hectares in size, in a
suburban location with a public transport accessibility level of 2. The application achieves a
residential density of 43 units per hectare, or 152 habitable rooms per hectare.
40 The London Plan density matrix table 3A.2 recommends an appropriate residential
density of between 35 and 75 units per hectare, or between 150 and 200 units per hectare. In
this regard the proposed density is acceptable.
41 The application is a mixture of houses and flats. All of the houses, and the majority of
the flats would be dual aspect units. However, as this is an outline application detailed plans
have not been provided. It is recommended that the applicant provide further detail on the
number of single aspect flats and further detail on this should be secured as part of the design
parameters to minimise the number of single aspect units, particularly north facing. A further
discussion on this issue is required.
42 The applicant has not provided a detailed space standards breakdown for the residential
units. It is strongly recommended that this should be secured as part of the outline parameters
or as part of a design code. These space standards should be in line with the Mayor’s minimum
space standards as set out in table 3.3 of the draft replacement London Plan.
Connections with the wider area
43 The design rationale seeks to better integrate the site into the surrounding area, which
is generally supported. The layout proposes two new diagonal routes that cross the site and
help achieve this integration and are broadly welcomed. However, there is a concern with the
detailing of these diagonal routes, and it is recommended that further design detail be secured
at this outline stage to ensure the delivery of high quality streets and public realm.
44 The diagonal routes are heavily dominated by car parking. This serves to reduce
legibility and impacts on the character of these routes, making people less inclined to want to
use them. The overall level of car parking is high and, as set out in paragraph 74 it is
recommended that this be reduced. A reduction in the level of car parking along these main
routes would also help to improve the use of these streets and the general character of this area.
45 The applicant has not sought to include a new bridge connection from this site to
Central Park. An improved connection would offer better permeability across the site and
improve access to park for the residents. However, there are already two existing access points
into the park located immediately to the north and south of the application site. The southern
access point opens directly onto Petersfield Avenue, whereas the northern access point is in an
‘out of the way’ location and is distance from the main road. The proposed layout of the scheme
helps integrate the northern access point into the surrounding area and would provide
sufficient access to the park for future residents of this site.
Central open space
46 The location and size of the central open space is welcomed. It has the potential to
provide a focal point for residents within the scheme. Located along the main diagonal routes it
could also become a well used area for local people in the surrounding area. However, the
success of this open space is highly dependent on its detailed design and as this is an outline
application limited information as to its detailed design has been provided. It is recommended
that the applicant provide an indicative section through the open space to show how the design
of the open space would accommodate the level change on site.
Image 1: Aerial image of proposed scheme, showing massing and layout of buildings
Entry / exit points
47 The location of the majority of the entry/exit points into the site is understood. The
entry points have a mixture of planting, parking and landmark buildings that help to create
interesting gateways into the site.
48 There is a concern that the new connection point between the site and the community
centre is poorly defined and could result in a lack of clarity between residential area and the
community area. The applicant should more fully explain how this route will be used i.e. is the
route a fully public route, is it a pedestrian/vehicle route.
49 The scheme proposes building heights of between 2 and 3-storeys, which does not raise
any strategic planning policy concerns.
50 Policy 3D .13 of the 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 and Young People’s Play and Informal Recreation’ it is anticipated that
there will be approximately 73 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 730 sq.m. of
51 The scheme includes 1,660 sq.m. of child play space within the site and this level would
be secured as part of the outline permission which is acceptable. However, it is recommended
that the application should provide further detail on the potential type and location of child
place space within the scheme.
52 This is an outline and the design information provided is only indicative. The principle
of an outline application on this site is acceptable and as set out above the proposed design and
layout of the indicative scheme is broadly acceptable.
53 As part of the outline application, the applicant has proposed some development
parameters that relate to the design and layout of the site, including;
Maximum building height of 3 residential storeys
80% houses and 20% flats
1,660 sq.m. of play space
54 The inclusion of these parameters are welcomed, however, they are limited and it is
recommended that additional design parameters be included. In particular, as the Mayor will
not be involved in any of the detailed design or reserved matters applications. It is
recommended that further information on;
Mix of units
Materials and elevation treatment
Key building frontages
Street widths, planting and materials
55 A further discussion on securing additional design parameters as part of this outline
application is required.
56 Inclusive design principles should be embedded into the development and design
process from the outset to help 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 London Plan Policy 4B.5 and draft replacement London Plan
(2009) policy 7.2 is to ensure that proposals achieve the highest standards of accessibility and
inclusion (not just the minimum). The appointment, at this early stage, of an access consultant
is welcomed and close collaboration between the access consultant and the design team has
helped ensure that inclusive design principles are embedded into all aspects of the design
57 The applicant has provided an outline commitment that 100% of units would be design
to meet the design requirements of the ‘Lifetime Homes’, which is acceptable and this should be
secured by an appropriate planning condition.
58 The applicant has also provided an outline commitment that 10% of units would be
wheelchair accessible, which is acceptable and this should be conditioned as part of a planning
permission. In addition, however, the applicant should provide indicative plans demonstrating
how the proposed range of housing types would be designed as accessible units.
59 The applicant must demonstrate how the level changes across the central open space
have been addressed, and how this open space could be successfully designed as a fully inclusive
60 The applicant must ensure that all 10% of the wheelchair accessible units are provided
with blue badge accessible parking spaces, which would equate to 24 blue badge spaces and
should be secured by planning condition. Any variation from this should be justified with
robust local evidence. This should be secured by an appropriate planning condition.
Energy and climate change
Energy efficiency standards
61 The applicant has not provided any information on the proposed energy efficiency
measures to be adopted. Further information on this will need to be provided including
envisaged air permeability and heat loss parameters, etc… is required.
62 Given the outline nature of the proposal, the applicant should provide an estimate of the
tonnes of regulated carbon dioxide emissions per annum after the application of passive design
and energy efficiency measures.
63 The applicant should commit to adopting measures that enable the development to
exceed 2010 Building Regulations compliance through energy efficiency alone and this should
be secured by an appropriate planning condition.
64 The applicant states that they have consulted the LDA Heat Map which found that
there are no available district heating networks within the vicinity of the proposed
development. There is an existing combined heat and power plant in the leisure centre to the
north of the site but the distance is likely to make connection prohibitive.
65 The applicant is proposing to use communal heating for the apartment blocks. It is
accepted that the individual houses will not be communally heated due to the higher heat
distribution losses incurred.
Combined Heat and Power
66 The applicant envisages using three 12.5 kilowatt gas-fired combined heat and power
plants for the apartment blocks, which is acceptable.
67 Micro combined heat and power plants are proposed for the individual houses. The
applicant should provide further information on these units, including an explanation of how
these units would operate effectively given the small heat demand of the new houses.
68 The applicant should provide an estimate, of the tonnes of regulated carbon dioxide
emissions per annum after the application of combined heat and power plants, as well as the
savings in carbon dioxide achieved. This should also be expressed on a whole energy basis.
Renewable energy technologies
69 The use of centralised biomass boilers to supply the heating load for the development is
also being considered. If the use of biomass is to be pursued, further details on the proposed
biomass boilers should be provided including, air quality impact, source of fuel, storage
70 The application proposes the use of 720 sq.m. of solar thermal panels and 2,000 sq.m of
photovoltaic is suggested as a possible option for the development. The applicant estimates that
this would provide a 21.83% carbon dioxide reduction from renewables. The applicant should
provide roof drawings showing the roof area available for the proposed solar technologies. An
estimate of the electricity generation from photovoltaic panels should also be provided.
71 The applicant should confirm the renewable technologies that would be adopted and
provide an estimate of the reduction in tonnes of regulated carbon dioxide emissions per annum
that will be achieved through this third element of the energy hierarchy. This should also be
expressed on a whole energy basis.
Climate change mitigation measures
72 In line with London Plan policy 4A.14 the application proposes to utilise a sustainable
urban drainage system. The site is in a flood zone and so the sustainable urban drainage system
would be used to attenuate increased surface water run off. The proposed measures would
include the use of a swale, balancing ponds, detailed landscaping and underground storage. The
applicant has provided very limited detail on the proposed system. The council should impose a
planning condition to ensure that the recommendations set out in the Flood Risk Assessment
are followed and that detailed drainage designs maximise the use of SUDS in line with London
Plan Policy 4A.14 and policy 5.13 of the draft replacement London Plan.
73 The site lies in flood zones 1 and 2. According a Flood Risk Assessment has been
undertaken. The proposal and mitigation measures are acceptable in principle. The Flood Risk
Assessment mentions that some reaches of the Brook contain significant urban trash,
particularly adjacent to road crossings. The cleaning of the Paine’s Brook on the site should be
74 The applicant is not proposing the use of any green or brown roofs on site. In line with
London Plan policy 4A.11 the applicant should seek to include these roofs where feasible and as
such the applicant should provide additional justification for not including any on this site.
75 The proposed level of car parking exceeds the maximum London Plan car parking
standards and is unacceptable. At present 375 car parking spaces are being proposed for 242
units, and based on the current split of 1-4 bedroom units the maximum number of spaces
permissible would be 308. TfL would therefore request that the car parking level be reduced
accordingly to comply with London Plan policy 3C.23 ‘Parking strategy’ and draft revised
London Plan policy 6.13 ‘Parking’. The applicant should also clarify the amount of accessible
Blue Badge parking spaces proposed.
76 40% of the car parking spaces would be provided as a passive provision of electric
vehicle charging points, which is welcomed, however at least 20% of these spaces should be
fitted with active provision prior to occupation on site, in line with policy 6.13 ‘Parking’ of the
draft replacement London Plan. This should be secured by planning condition. TfL also
supports the applicant’s intention to investigate the feasibility of a local car club to serve this
development and would encourage that this is pursued through the travel plan to decrease the
need for car ownership and overall car use.
77 It is accepted that the proposed development would attract a relatively low level of
traffic to the A12 Colchester Road / Gooshays Drive / Gubbins Lane junction, it would
however further increase traffic pressure on this already congested junction, particularly taking
into account other committed developments in the area. Based on the approach taken for
nearby developments, a contribution of £350 per residential unit is sought for highway
improvements, and hence would request £85,000 to be secured by planning obligation towards
A12 junction improvements. This contribution would help to relieve traffic congestion on the
A12 in line with London Plan Policy 3C.2 Matching development to transport capacity and draft
London Plan Policy 6.3 Assessing transport capacity and improve the pedestrian and cycle
environment in line with London Plan policies 3C.21 ‘Improving conditions for walking’ and
3C.22 ‘Improving conditions for cycling’ and draft revised London Plan policies 6.10 ‘Walking’ and
78 This proposed development would also generate additional trips on the 496 bus route,
which would result in an over-capacity. A contribution of £70,000 is therefore sought to
provide an additional school day journey on the bus network, in order to mitigate the impact of
this development, in line with London Plan policy 3C.20 ‘Improving conditions for buses’ and
draft revised London Plan policy 6.7 ‘Buses, bus transits, trams’.
79 The submission of a Pedestrian Environment Review System (PERS) audit is welcomed
and advises that Havering Council (as highway authority for Gooshays Drive) should consider
the outputs, and secure mitigation measures where necessary in line with London Plan policy
3C.21 ‘Improving conditions for walking’ and draft revised London Plan policy 6.10 ‘Walking’.
80 The proposal to provide a minimum of one cycle parking space per one / two bedroom
unit and two spaces per 3+ bedroom unit, although clarification is required on the specific
number of provision proposed. The provision of CCTV coverage should also be considered for
81 The submitted travel plan has failed its assessment and therefore further information,
as outlined in TfL’s initial detailed letter to the borough dated 5 November 2010, is required
before it is considered in line with London Plan policy 3C.2 ‘Matching development to transport
capacity’ and draft revised London Plan policy 6.3 ‘Assessing transport capacity’. The travel plan
should be secured, managed, monitored and enforced through the section 106 agreement.
82 A delivery and servicing plan and a construction logistics plan should be secured by
condition, in accordance with the London Plan policy 3C.25 ‘Freight strategy’ and draft revised
London Plan policy 6.14 ‘Freight’.
83 In summary, an overall reduction in the level of car parking is required along with the
provision of active electric vehicle charging points. Contributions of £85,000 towards highway
improvements and £70,000 towards local bus capacity enhancements should also be provided.
In addition, further information is required in the travel plan and whilst a delivery and
servicing plan and a construction logistics plan should also be secured by condition.
Local planning authority’s position
84 The view of the local planning authority is not known at the time of writing this report.
85 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.
86 There are no financial considerations at this stage.
87 London Plan policies on open space and sports pitches, housing provision and affordable
housing, urban design, access, transport, energy and climate change and flood riskare relevant
to this application. The application complies with some of these policies but not with others,
for the following reasons:
Open space and sports pitches: The surrounding area has a surplus provision of open
space; however, there is a deficiency in sports pitches. The applicant is providing new
sports pitches on an alternative site, however, additional information on the new facility
and legal agreement to secure this is required.
Affordable housing: The scheme has a low level of affordable housing and no
intermediate housing, the reason being that Havering Council are proposing to use the
sale receipts from this site to fund a number of other regeneration projects in the area.
While the principle of this may be acceptable, further information on the submitted
financial appraisal and legal agreement is required.
Housing mix and design standards: There is no information on the required housing
mix and design/space standards for the new residential units.
Urban design: The design of the scheme is acceptable, however, all of the information
provided is indicative and there is no design code that would secure a sufficiently high
standard at the detailed design stage.
Access: There is no provision of blue badge accessible car parking, and there is limited
design information on the possible layout of wheelchair accessible rooms
Transport: The proposed level of car parking is too high. There is a need to provide
financial contributions for bus and junction improvements to mitigate the impacts of
this development, the travel plan is insufficient and no information on a delivery and
servicing plan or construction logistics plan has been provided.
Energy and climate change: There is no information on energy efficiency measures,
there is limited information on the proposed micro combined heat and power plants, a
firm feasible renewable strategy is required and there is limited information on this. In
addition, the applicant has not assessed the potential to include green or brown roofs.
88 Whilst the application is broadly acceptable in strategic planning terms, on balance, the
application does not comply with the London Plan.
89 The following changes might, however, remedy the above-mentioned deficiencies, and
could possibly lead to the application becoming compliant with the London Plan:
Open space and sports pitches: The applicant is required to provide additional
information on the design of the new facility and the number of new pitches to ensure it
achieves a higher standard of design. In addition, there is also a need for further
information on the legal agreement to secure this approach.
Affordable housing: Further information on the submitted financial appraisal is
required as well as a further discussion on the ability to ensure that the profit from the
sale of this site would be used to deliver the objectives of the Harold Hill Ambitions
Housing mix and design standards: It is recommended that a housing mix and further
information on space standards for the residential units be secured.
Urban design: It is recommended that a more detailed design code be secured as part of
Access: The scheme must include provision for blue badge accessible car parking. In
addition, further design information on the layout of wheelchair accessible units is
Transport: The proposed level of car parking should be reduced. Financial
contributions for bus and junction improvements are required, a more comprehensive
travel plan is required along with a delivery and servicing plan and a construction
Energy and climate change: Information on energy efficiency measures are required,
along with information on the proposed micro combined heat and power plants, as well
as a firm commitment to a feasible renewable strategy. In addition, the applicant should
further assess the potential to include green or brown roofs.
for further information, contact Planning Decisions Unit:
Colin Wilson, Senior Manager - Planning Decisions
020 7983 4783 email email@example.com
Justin Carr, Strategic Planning Manager (Development Decisions)
020 7983 4895 email firstname.lastname@example.org
Michael Mulhern, Case Officer
020 7983 6535 email email@example.com