Development and Environment Directorate City Hall
The Queen’s Walk
London SE1 2AA
Switchboard: 020 7983 4000
Minicom: 020 7983 4458
Our ref: PDU/ LDF27/LDD05
Environmental Policy Manager
Date: 18 March 2011
London Borough of Richmond upon Thames
44 York Street
LONDON TW1 3BX
For the attention of: Evie Bissell
Dear Ms Cornforth,
Planning and Compulsory Purchase Act 2004; Greater London Authority Acts 1999 and
Stag Brewery Supplementary Planning Document
Thank you for consulting the Mayor of London on the above draft supplementary planning
document. The Mayor has afforded me delegated authority to make comments on his behalf on
draft supplementary planning documents. The GLA welcomes the opportunity to consider the
document at this draft stage. These comments are officer-level only and do not preclude any
further comment the Mayor may make on future consultation phases of the Council’s LDF, or on
any potential planning application for this site.
As you are aware all local development documents including supplementary planning documents
have to be in general conformity with the London Plan under section 24 (1)(b) of the Planning and
Compulsory Purchase Act 2004.
The SPD appears comprehensive and should prove to be a useful tool for both planners and
prospective developers. The overall approach to the draft document is supported from a strategic
planning perspective. Specific points are made below regarding a number of key strategic planning
policies, including comments made by Transport for London, which should be reflected in the final
Scale of development
The starting point for the key issues and principles for this site is currently stated as the need to
avoid a significant deterioration in traffic movement (paragraph 5.1). Whilst the need to ensure
traffic impacts are mitigated as part of any development would be critical, it should not be the
driving factor. Draft replacement London Plan Policy 3.4 regarding density moves away from
‘maximise’ in favour of ‘optimise,’ having regard to local context, design principles and public
transport accessibility. These principles should be better reflected when discussing the driving
factors behind the nature, amount and mix of development.
Direct telephone: 020 7983 5751 Fax: 020 7983 4706 Email:
Whilst the aspirations of the Council are supported, there are concerns that the broad range of
requirements, and the limits on the scale of development, could adversely impact on the delivery of
affordable housing. Paragraph 5.23 also recognises this issue. As stated in London Plan Policy
6A.4 and Policy 8.2 of the draft replacement London Plan, affordable housing and public transport
improvements should generally be given the highest importance with priority also afforded to
tackling climate change, learning and skills and health facilities and services and childcare
provision. In this context, it is important that the demands placed on this site do not impinge on
any future applicants ability to provide the maximum reasonable amount of affordable housing, in
accordance with London Plan Policy 3A.10 and draft replacement Plan Policy 3.13.
Reference should be made in the document to the need to provide a mix of units in accordance with
local policy and need, as well as strategic requirements. London Plan Policy 3A.5 encourages a full
range of housing choice. This is supported by the London Plan Housing Supplementary Planning
Guidance, which 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.
Policy 3.12 of the draft replacement London Plan states that within affordable housing provision,
priority should be accorded to family housing. Recent guidance is also set out in the London Plan
Interim Housing Supplementary Planning Guidance (April 2010) and draft replacement London
Plan policy 3.8, which seeks to widen housing choice. Also relevant is policy 1.1C of the London
Housing Strategy, which sets a target for 42% of social rented homes to have three or more
bedrooms. These strategic priorities should be adequately reflected in the document.
In addition, the document should also make reference to strategic requirements with regard to
Lifetime Homes and wheelchair accessible housing (London Plan Policy 3A.5 and draft replacement
Plan Policy 3.8).
The implications of the new affordable housing model, as outlined in the HCAs affordable housing
programme framework, as well as changes to funding and definitions of affordable housing, should
be reflected in the document. It will be important in developing a detailed housing schedule for any
future planning application, that the applicant take account of these changes. It may be appropriate
to consider the use of cascade and review mechanisms within the s106 agreement, in the context of
the need to provide the maximum reasonable amount of affordable housing as part of any future
development, and this should also be highlighted.
Strategic importance is increasingly being afforded to housing quality. Policy 3.5 of the draft
replacement Plan introduces a new policy on the quality and design of housing developments. Part A
of the draft policy states that housing developments should be of the highest quality internally,
externally and in relation to the wider environment. Part C of the draft policy states that new
dwellings should meet the dwelling space standards set out in Table 3.3, have adequately sized
rooms and convenient and efficient room layouts. Part E of the draft policy states that the Mayor
will provide guidance on implementation of this policy including on housing design for all tenures.
The reasoned justification provides further guidance and explanation. In particular paragraph 3.31
states that other aspects of housing design are also important to improving the attractiveness of new
homes as well as being central to the Mayor’s wider objectives to improve the quality of life of
To address these, the Mayor has produced a new draft Housing SPG on the implementation of
Policy 3.5 for all housing tenures, drawing on the Housing Design Guide. Paragraph 3.33
highlights what the proposed SPG would cover, in terms of requirements for individual dwellings.
This draft was produced for the London Plan examination in public.
The document should include reference to the need to provide the highest quality housing, and
more specifically the requirements detailed above.
The aspiration to protect and enhance the existing buildings on the site is supported, and
reference to the need to ensure the riverside area is appropriately designed to ensure it is safe and
active, particularly at night, is welcomed. Consideration should be given to whether a masterplan
covering the whole site will be required as part of any future planning application, and as part of
this, whether a design code should be developed. This approach would be strongly encouraged to
enable key design parameters to be set at the initial stage, therefore ensuring design quality is
delivered throughout the entire planning and development process.
Whilst the requirements regarding open space provision detailed in the document are supported,
this section should specifically mention the requirement to provide children’s play space, in
accordance with London Plan Policy 3D.13, draft replacement Plan Policy 3.6, and the Mayor’s
supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal
Reference should be made to the need to achieve the highest standards of inclusive design, in
accordance with London Plan Policy 4B.5 and draft replacement London Plan Policy 7.2. As
detailed in these strategic policies, the document should make clear that all future development is
expected to meet the highest standards of accessibility and inclusion, and that a design and access
statement explaining how the principles of inclusive design, including the specific needs of
disabled people, have been integrated into the proposed development and how inclusion will be
managed and maintained, will be required.
The vision for the document should include reference to sustainability. Whilst this is included
elsewhere in the document, to ensure it is given appropriate weight, it should be included as a
fundamental part of the vision for the site. Where sustainability is discussed (page 27), specific
mention should be given to energy, and particularly the need to provide a site wide heat network
linking all future buildings and users. In addition, an energy statement, as distinct from a
sustainability statement, should be required as part of any future planning application. This is not
specified in the list on page 36.
The aspiration to improve links to the Thames, the Thames frontage, and the level of activity on
the river, are all strongly supported at the strategic level and accord with London Plan policies
regarding the blue ribbon network.
Transport for London
TfL expects the transport elements and impacts of any forthcoming applications which are of a
scale requiring referral to the Mayor of London to be supported by a full Transport Assessment in
line with TfL’s best practice guidance (April 2010)
Public transport accessibility level
The site has a public transport accessibility level of two. Given the relatively low level of
accessibility, public transport and highways improvements should be identified in order to
mitigate the increased demands generated by new development and to improve the overall
accessibility of the site. The planning brief should include specific reference to this need.
TfL requests that reference is made within the planning brief to the car and cycle parking
standards set out within the London Plan including disabled parking and electric vehicle charging
points. Any future applicant should also be required to take into account the condition of and
impact on the surrounding local and strategic highway networks.
To encourage a reduction in car ownership TfL requests that the brief requests that any future
redevelopment of the site includes a car club and focuses on encouraging sustainable travel and
mode choice including provision for buses where appropriate.
TfL welcomes the proposals set out within the brief which relate to improvements for pedestrians.
However, there is no mention of way-finding. A lack of useful way-finding can significantly affect
pedestrian movement. TfL requests that reference is made to the need to provide an appropriate
way-finding strategy to aid pedestrian movement in the vicinity of the site which integrates with
TfL’s Legible London initiative.
The planning brief should set out the need for any future development on this site to fund
pedestrian improvements at the Lower Richmond Road/Mortlake Road/Sheen Lane junction and
along Sheen Lane to improve pedestrian links from the site to the railway station. This link is
important in encouraging trips to be made by sustainable modes from the site as well as
mitigating the potential impacts generated by the development.
Cycle parking must be provided to the minimum standards as set out in the London Plan. Larger
developments will need to address the needs of both long stay (staff, residents) and short (visitor)
cyclists. TfL welcomes the proposal to integrate the site within the existing walking and cycling
The requirement for a travel plan is supported and should comply with TfL’s Travel Plan
In addition to this a delivery and servicing plan and a construction logistic plan will also need to
be provided and secured by condition for the site.
Bus network development
Future planning applications should include adequate provision for bus stops and bus routeings.
The Transport assessment should consider the impact of the development on the bus network.
Where the impact of the development is such that new or extended bus routes will be required to
serve a development, the development should be expected to fund and provide suitable bus
standing space, including facilities for bus drivers.
TfL supports reference to financial obligations being required to deliver transport improvements.
However, TfL would welcome more explicit wording to reinforce the requirement of developer
funding. TfL therefore suggests that the following wording is incorporated: “Contributions will be
sought for transport infrastructure and service improvements to ensure that efficiency and capacity on the
transport network is maintained and that the impact of the development on the transport network is
mitigated. In circumstances where the combined impact of a number of developments creates the need for the
provision of additional transport infrastructure and or services, it will be appropriate to pool the
contributions from these developments having regard to the limitations on pooling arrangements imposed by
the Community Infrastructure Regulations 2010. The level of contribution, whether pooled from a number
of developments or not, may be based on a formula or standard charge which reflects the actual impact of the
A clear distinction should be made between a Community Infrastructure Levy (CIL), should the
Borough propose to raise one, and legally binding planning obligations to avoid limiting the scope
for funds. This is particularly important for bus network contributions which at present are not
considered as infrastructure under the CIL.
I trust that these comments will be of assistance to your Council in finalising the document and
that they will be incorporated within that final document. Please contact Sarah Considine (020
7983 5751) should you wish to discuss these comments further.
Assistant Director – Planning
cc Tony Arbour, London Assembly Constituency Member for Richmond upon Thames
Nicky Gavron, Chair of London Assembly Planning and Spatial Development Committee
John Pierce and Ian McNally, GOL
Colin Lovell, TfL