"loughborough park estate report"
planning report PDU/0783a/01 30 November 2010 Loughborough Park Estate, Brixton in the London Borough of Lambeth planning application no. 10/03653/OUT Strategic planning application stage 1 referral (new powers) Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008 The proposal This is a hybrid application seeking part outline and part full planning permission: 1. Outline planning permission for phased redevelopment of the estate comprising demolition of existing 390 residential units and community centre and erection of 525 new residential units within six blocks ranging in height from five to nine storeys. A new community centre, CHP plant, and associated landscaping and public realm are proposed. Approval is being sought for the scale, layout and access, with appearance and landscaping as reserved matters for future consideration. 2. Full planning permission for ‘Phase 1’, which relates to demolition of 98 dwellings within five of the buildings and erection of 116 new residential units in two 5-6 storey blocks, together with landscaping works, parking and associated works. The applicant The applicant is Guinness Trust and the architect is BPTW Partnership. Strategic issues The principle of the redevelopment of the estate to provide a better quality standard of accommodation is supported. The replacement of the existing level of affordable housing units is welcomed, as is the introduction of intermediate housing. Further clarification is required regarding how the affordable housing level and housing mix were arrived at before it can be agreed that the scheme is compliant with the London Plan. The design is appropriate to its context, subject to clarification in relation to the public realm. Further work is also required in relation, play space, transport and climate change before the scheme can be considered to be acceptable with respect to London Plan policy. Recommendation That Lambeth 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 106 of this report; but that the possible remedies set out in paragraph 108 of this report could address these deficiencies. page 1 Context 1 On 1 November 2010 the Mayor of London received documents from Lambeth Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 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 of the Schedule to the Order 2008: ”Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.” 3 Once Lambeth Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself. 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 Loughborough Park Estate is a roughly rectangular 2.5 ha site bounded by Loughborough Park (road) to the west, properties fronting Shakespeare Road to the east, railway lines to the south/south-west and to the north and immediate west, Lambeth Council depot sites. Further to the north is the recently constructed Evelyn Grace Academy. 6 The estate was built in the 1930’s and comprises a series of blocks of five storey brick clad buildings containing 390 flats. A distinctive two-storey community centre and housing office are located in the centre of the site, with a small play area and ball court adjoining it. There is a vehicle access located off Loughborough Park, with on-site parking, playspace and an allotment area. 7 The nearest Transport for London Road Network (TLRN) is the A23 Brixton Road, 800m to the north-west of the development. The site has a public transport accessibility level (PTAL) of 3-4, on a scale of 1 to 6 where 6 is most accessible. The site is within walking distance of Brixton London Underground and National Rail station and Loughborough Junction Rail station. The site is served by bus route P5, with stops directly outside the site entrance on Loughborough Park Road. Figure 1: Photograph of existing estate (source: submitted design and access statement) Details of the proposal 8 The planning application comprises a hybrid application, including outline planning permission for the redevelopment of the estate and a detailed planning application for phase one of the scheme. 9 The outline planning permission is sought to determine the principle of development for the scale, layout and access for a phased development (five phases) comprising erection of six blocks ranging in height from five to nine storeys to contain 525 residential units and an 800 sq.m. community centre. The scheme also proposes a combined heat and power plant, page 2 new streets, pedestrian routes, landscaped communal areas, together with ground floor and basement parking. 10 Details of the external appearance of the buildings and landscaping are reserved for later determination, except in relation to phase one of the scheme where full detailed planning permission is sought for demolition of 98 dwellings and erection of two 5-6 storey buildings to contain 116 residential units, together with associated works, highways, parking, energy centre and landscaping. Figure 2: Proposed layout plan (source: submitted Design and Access Statement) Case history 11 This application follows pre-application discussions, including a meeting held on 18 March 2010 with GLA officers, to discuss the redevelopment of the estate. The applicant was advised that the principle of the proposed estate renewal and, in particular, the intensification of development to provide additional housing and a higher proportion of larger units was supported. Further work in relation to design and architectural quality; the sizes, mix and tenure of the affordable housing; children’s play space; climate change mitigation and adaptation; sustainability, and access issues was requested. 12 Prior to this, the applicant submitted two outline planning applications for an estate regeneration schemes in 2005 and 2007. Neither application was referred to the GLA, and both applications were withdrawn prior to being determined. Strategic planning issues and relevant policies and guidance 13 The relevant issues and corresponding policies are as follows: Regeneration London Plan; the Mayor’s Economic Development Strategy; draft replacement Economic Development Strategy Housing/affordable housing London Plan; PPS3; Housing SPG; Housing Strategy; Interim Housing SPG; Housing SPG EiP draft Density London Plan; PPS3; Housing SPG; Interim Housing SPG; Housing SPG EiP draft Urban design London Plan; PPS1 Inclusive Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM) Children’s play space London Plan; Providing for Children and Young People’s Play and Informal Recreation SPG Ambient noise London Plan; the Mayor’s Ambient Noise Strategy; PPG24 Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG Transport/parking London Plan; the Mayor’s Transport Strategy; draft replacement Transport Strategy; PPG13 page 3 14 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 2007 Lambeth Council Unitary Development Plan and the London Plan (Consolidated with Alterations since 2004). 15 The following are also relevant material considerations: The Lambeth Council Core Strategy (Submission Stage) The Lambeth Council Site Allocations document (issues and options stage). Draft replacement London Plan. Principle of development 16 London Plan policy 2A.7 encourages regeneration in areas where there is substantial deprivation, requiring boroughs to “set out integrated spatial policies that bring together regeneration, development and transport proposals with improvements in learning and skills, health, safety, access, employment, environment and housing.” This policy is reinforced under policy 2.14 of the draft replacement London Plan. 17 London Plan policy 3A.29 ‘supporting neighbourhood plans’ states “The Mayor will encourage communities and neighbourhood-based organisations to prepare planning frameworks or neighbourhood plans based upon identifying local economic, social, physical and environmental needs and opportunities to strengthen local Neighbourhood Renewal Strategies”. The Mayor encourages boroughs to adopt locally prepared frameworks or plans including those prepared by housing association-led estate regeneration schemes, Development Trusts and Urban Regeneration Companies as supplementary planning documents. 18 Loughborough Park is within the Coldharbour Ward of Lambeth, one of the most deprived areas in the borough. Guinness Trust is a housing association and as the applicant and owner of the estate (the sixth largest estate in Lambeth), it has been pursuing various options for refurbishment and redevelopment for several years in order to improve the quality of the accommodation on the estate, which at present does not meet Decent Homes standards. The aspirations of the housing association, as applicant in undertaking a regeneration scheme in consultation with the local community, meets the objectives of policy 3A.29. Housing – affordable housing 19 The London Plan, in seeking to increase London’s housing supply and maximise the potential of individual sites, focuses on securing housing choice and the maximum reasonable amount of affordable housing (policies 3A.1, 5 and 10). The corresponding policies are set out in Chapter 3 of the draft replacement London Plan. 20 The approach employed by the GLA when assessing estate renewal is to take into account the regeneration benefits to the local community, the proportion of affordable housing in the surrounding area, and the amount of affordable housing being, or planned to be, provided elsewhere in the borough. 21 Policy 3A.15 of the London Plan provides guidance to boroughs preparing DPDs regarding the loss of housing including affordable housing. It states that DPDs should prevent the loss of housing, including affordable housing, without its planned replacements at existing or higher densities. This is re-iterated in policy 3.15 of the draft replacement London Plan, which goes on to state that at least equivalent floorspace should be provided in housing redevelopments. 22 Paragraph 3.75 of the London Plan notes that “where redevelopment of affordable housing is proposed, it should not be permitted unless it is replaced by better quality accommodation, providing at page 4 least an equivalent floorspace.” Section 20 of the Housing SPG provides further guidance on this matter, stating that estate regeneration schemes should be undertaken on the basis of no net loss of housing or net loss of affordable housing. Paragraph 20.2 of the Housing SPG notes that “Replacement of social rented units by intermediate provision may be acceptable where this can be justified by a requirement to achieve a wider range of types of provision in a neighbourhood”. 23 The existing buildings on the site the following units: Secure and Assured assured shorthold Studio 1 bed 2 bed 3 bed 4 bed 5 bed 6 bed Total tenant tenancy Total 20 116 142 108 0 2 2 390 223 157 Bed spaces 1,160 25 The proposed scheme is made up of the following: Unit Tenure Housing Unit Type Market Affordable Total by Total by SPG Unit Unit Type Intermediate Social Type (%) Studios 0 0 0 0 0 1% 1-bed 84 40 117 241 46% 31% 2-bed 42 50 99 191 3-bed 0 0 52 52 46% 38% 4-bed 9 0 30 39 30% 5-bed 0 0 2 2 8% Total by Tenure 135 90 300 525 100% 100% Total habitable rooms 321 230 985 1536 Total by Tenure (%) 26% 17% 57% Total by habitable rooms (%) 21% 15% 64% Tenure split 23% 77% Re-provision of affordable housing/tenure split 26 As noted in table 1 above, there were previously 390 homes on the site of which all were social rented units. The scheme proposes 525 housing units, of which 74% would be affordable housing with a 77:23 split between social rented and shared ownership. 27 The proposal retains the same number of affordable housing units as existing, with an increase of 188 in the number of bed spaces. The replacement of affordable housing with better quality accommodation of higher density is in accordance with London Plan policies. 28 The introduction of shared ownership units to the scheme is acceptable and in accordance with London Plan policies, which enables the introduction of mixed tenure in estate renewal schemes, so as to provide mixed and balanced communities. The mix has altered since discussions at pre-application stage but is understood to be the result of the need to accommodate the decanting of existing tenants, and to make the redevelopment financially viable. Further discussion is required with the Council before the application is referred back at Stage 2, to establish to what extent the determined tenure split reflects local needs, noting that that the split differs from the London Plan and Lambeth Council targets, and that there is the possibility of the tenure being altered further if grant funding is not secured. Viability 29 London Plan Policy 3A.10 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mix-use page 5 schemes. In doing so, each council should have regard to its own overall target for the amount of affordable housing provision. Policy 3A.9 states that such targets should be based on an assessment of regional and local housing need and a realistic assessment of supply, and should take account of the London Plan strategic target that 35% of housing should be social and 15% intermediate provision, and of the promotion of mixed and balanced communities. In addition, Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain residential development, and to the individual circumstances of the site. Targets should be applied flexibly, taking account of individual site costs, the availability of public subsidy and other scheme requirements. The corresponding policies are set out in Chapter 3 of the draft replacement London Plan. Lambeth Council in its adopted Unitary Development Plan sets an overall affordable housing borough target of 50%. 30 Policy 3A.10 of the London Plan is supported by paragraph 3.52, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified. This is reinforced under policy 3.13 of the draft replacement London Plan. 31 In relation to estate renewal, where private housing is needed to support replacement of affordable housing provision in estate renewal schemes, the net gain in total provision need not achieve the usual proportion of affordable housing provision, where this is necessary to cross subsidise redevelopment. Where this is the case, the applicant is expected to demonstrate that the maximum reasonable amount of affordable housing is being provided by way of an open book appraisal. 32 The scheme proposes an equal amount of affordable housing, with no net gain, although there are additional bed spaces proposed. The proposed development would comprise 79% affordable housing (based on habitable rooms) which exceeds Lambeth Council's affordable housing targets, however in order to comply with the London Plan, it is necessary to demonstrate that the scheme delivers the maximum reasonable amount of affordable housing. In this respect, the applicant has joined with a private house builder, which would act as contractor to construct the affordable housing units and developer of the private units. The applicant has undertaken financial appraisals of the scheme in order to arrive at the proposed tenure mix and in this respect, it has submitted details of its appraisal model to the HCA as part of its application for a grant funding to the HCA. Without funding it would not be able to provide the level of affordable housing that is proposed. The applicant has submitted a Housing/Decanting Statement with the application, setting out the phasing strategy for the scheme, noting that existing residents would need to be decanted and re-housed in phase 1 of the development. 33 At the time of writing, the Council had not confirmed whether further scrutiny of the financial appraisal would take place, or whether further section 106 financial obligations would be required (which may impact upon the level of affordable housing). At this stage, it is also unknown as to whether the scheme would attract grant funding from the HCA, noting that the HCA is currently considering the funding application, but has yet to make a final decision. As noted above, without funding, the redevelopment scheme as submitted could not proceed and nor could refurbishment works proceed without letting homes at market rents or selling them. Such an outcome would most likely result in a net loss in affordable housing, and would not address the fundamental problems with the estate with respect to the mix and size of units, accessibility and Decent Homes standards, for example. 34 Given that there remains uncertainty over the availability of grant funding, and that the level of funding would impact upon the amount of affordable housing that could be provided, further discussion with the Council will be required in order to understand what the fall back page 6 position would be if grant funding is not secured, and how different tenures would be delivered at different stages in the life of the scheme. It is most likely that a phasing strategy with review mechanisms secured within a section 106 agreement may be required as part of any planning permission, and further discussion in this respect will be necessary in order to be satisfied that the maximum reasonable amount of affordable housing will be achieved over the life of the scheme. Mix of units 35 London Plan Policy 3A.5 requires new development to offer a range of housing choices in terms of the mix of unit sizes and types, taking into account the housing requirements of different groups. In support of this policy, the Mayor’s Housing Supplementary Planning Guidance (SPG) seeks to secure family accommodation within residential schemes, particularly within the social rented sector, and sets strategic guidance for councils in assessing their local needs. 36 The scheme proposes a range of unit types, however, the largest number of units proposed are one-bed flats. The applicant states that the mix is based on Guinness Trust’s Housing Needs Survey, including those who require decanting from the existing blocks on the estate. Officers recognise that the offer reflects an increase in the levels of four-bed plus family housing when compared with the previous housing on the site, which is welcomed. However, only 10% of social rented units are four-bed units or larger (the Housing SPG sets a target of 42%) and there is a significant reduction in three-bed plus compared to the existing buildings on the site. Before the scheme can be considered to comply with the London Plan and Housing SPG, further discussion is required with the Council, to establish to what extent the determined mix reflects local needs and the Council’s housing requirements. Residential quality 37 The Mayor has recently published his draft interim Housing Design Guide and Housing SPG EiP draft. Aspects of this, notably the minimum space standards for dwellings, are also reflected in the draft replacement London Plan. 38 The applicant has provided details of the floor plans for each of the unit types in phase 1, which shows that all units meet the minimum unit areas set out in the Mayor’s guidance. Units are for the most part, regular-shaped and there would be no solely north-facing units. This is welcomed. The applicant has confirmed its commitment with respect to the future phases, which is welcomed and the Council will need to ensure that the approved plans ensure that the units meet relevant criteria set out in the Mayor’s guidance, including minimum widths, storage, dual aspect, as well as the housing association’s and HQI standards. Confirmation that this would be the case would be welcomed. 39 The scheme avoids northerly facing single aspect units and most of the proposed building blocks would have an east-west facing orientation. This arrangement is supported as it would maximise the benefit of natural light and minimise the chances of solar overheating during summer months. All the living rooms will overlook streets to maximise natural surveillance with balconies or terraces accessed directly off them and this is welcomed. 40 In terms of amenity space, in phase 1, each unit would have its own private outdoor amenity space in the form of either a private balcony or outdoor terrace, which are sized in accordance with the Mayor’s Housing Design Guide. All ground floor units would have a page 7 private patio garden. The intention that that these design principles are carried through in later phases, and as such, it will be important for the Council to ensure these commitments are secured for when considering the reserved matters. The replacement allotment gardens are also welcomed, and would contribute towards the amenity values of the site, as well as encourage food growing. These commitments should be secured by way of condition, so as to ensure that there is no loss of facilities for any extended period. Density 41 Policy 3A.3 of the London Plan aims to maximise the potential of a site taking account of local context, London Plan design principles and public transport capacity. Table 3A.2 of the London Plan provides a framework for assessing density based on habitable rooms and dwellings per hectare. The consultation draft replacement London Plan policy 3.4 and Table 3.2 moves away from ‘maximise’ to ‘optimise’ taking into account all those matters in existing policy but with greater emphasis on local context and the design principles set out in Chapter 7 of the draft plan. 42 Paragraph 20.3 of the Housing SPG notes that “to achieve 100% replacement of demolished social rented units, development at significantly increased density may be necessary to generate sufficient value from market development to support replacement of affordable housing provision or to achieve a mixed and balanced community objective.” 43 The density of the site at present is 458 habitable rooms per hectare, and the proposal would result in a density of 640 habitable rooms per hectare. The site currently has a medium level of public transport accessibility (Level 3-4) and noting the proximity of the site to Brixton Town Centre and urban setting, the proposed density is likely to be acceptable in principle, being in line with the density range of 200 – 700 habitable rooms per hectare. This is also on the basis that the scheme retains amenity space and landscaping and achieves satisfactory internal layout and orientation. Urban design 44 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B, which address both general design principles and specific design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to specific issues. London Plan policies 4B.9 and 4B.10, which set out specific design requirements relating to maximising the potential of sites, the quality of new housing provision, tall and large-scale buildings, built heritage, views, and the Blue Ribbon network. 45 The draft replacement London Plan reinforces these principles, with new development required to have regard to its context, and reinforce or enhance the character, legibility and permeability of the neighbourhood (Policy 7.1). In addition, as noted above, whilst having limited material weight, the interim Housing Design Guide and Housing SPG EiP draft set out principles which should help schemes to demonstrate consistency with London Plan strategic design principles. 46 As noted previously, the Mayor has published his London Housing Design Guide (Interim Edition). Although this is not supplementary planning guidance, the principles within it should help the scheme to demonstrate consistency with London Plan strategic design principles. This should be used to inform a comprehensive design code for the outline planning application. The design code should cover all aspects of design including urban, passive (for mitigating climate change) and inclusive design. page 8 Layout, scale, massing and design 47 In terms of layout, the design and access statement shows that various options have been tested and a linear block approach would be most suited for this site. Whilst officers would have preferred a perimeter block approach, the architect has provided sufficient information to demonstrate the constraints of the site in this respect. On the basis that the proposed linear block layout addresses sunlight, daylight and overshadowing issues, poor internal circulation and poor delineation of private from public space in the existing estate, this approach is supported. 48 In terms of space hierarchy, the buildings are designed with clearly defined public fronts and semi-private and private backs. Where residents and visitors arrive by foot or by vehicle, block entrances are highlighted with bold canopies and glazed stair cores. Lighting and surface treatment will also help to signal the transition from public to semi-private building interiors. 49 The revised layout of proposed linear blocks are arranged to have an east-west orientation and to define public and private spaces. It would also provide individual blocks with corners and a central landscaped space for the development. 50 The heights of the new buildings have been kept close to existing building heights where they are adjacent to estate boundaries. The overall scale and heights of buildings proposed for the scheme are considered broadly acceptable. Where buildings adjoin Loughborough Park (road) the scheme presents three gable ends that face directly onto the street providing a varied and well-articulated frontage. These gables are 6-storey in height and spaced to provide two pedestrian and one vehicular entry point into the site. 51 A community centre and associated management offices will be located on the ground and first floor of the central block. These facilities are well positioned to provide good access for the public from the street and also for residents from within the development. 52 Two outer ‘blocks’ have centrally positioned residential entrances to accommodation above and both these entrances and living room windows will face Loughborough Park maximising natural surveillance and active frontages. 53 In relation to phase 1, details of external materials have been discussed with existing residents with a preference given for facing brickwork, in contrasting white with red. Soft blue/grey cladding is proposed for key corner features, and grey cladding for the recessed top floor. Given the phasing of the scheme, a cohesive approach to elevation treatment will be required, and the Council will need to ensure that the facade treatments details are carefully considered at reserved matters stage for each phase. Parking 54 The applicant has accepted GLA officers advice at pre-application stage raising concerns about the domination of car parking. The scheme now proposes 120 car parking spaces to the fronts of residential blocks along landscaped shared surface routes within the development, and 60 parking spaces in basement parking located under block E. This approach is welcomed and minimises the visual and amenity impacts of street parking. 55 The design and access statement states that visitor cycle parking will be provided in well-overlooked areas, however, it is not clear where these cycle parking areas will be located. These details should be confirmed by the Council and secured by way of condition. Open space and landscaping page 9 56 The proposed landscaping plan shows that the private and communal external spaces respond well to the estate’s location, and take advantage of the orientation. The communal gardens between the residential blocks will benefit from the sun penetrating from the south, and this has also informed the arrangement of the building blocks and external spaces. Communal landscaped spaces will be located to the rear of the buildings where residents can enjoy outdoor space in safety and privacy, and this is welcomed. 57 As noted above, the new buildings are arranged around generous communal landscaped spaces providing opportunity for play and other outdoor activities. 58 The rationale of retaining as many of the existing trees on site is supported. The design and access statement also states that planting will be used to provide seasonal colour and interests around the development and this is welcomed. 59 The scheme proposes to reuse the Guinness Clock, currently located on the community building, and incorporate it into a new sculptural element. This feature can be viewed from both the entry points of the development, aiding orientation and identity. 60 The current design shows a much-improved western archway entrance, which has been enlarged and designed with the colour and texture of the shared surface external routes in mind. There are concerns, however, that the design of the bollards located along this western entrance route is not satisfactory and this aspect should be revised. Bollards in sculptural forms would be preferable. 61 The success of the new open spaces will be dependent on their design and quality and how they will be managed in the long run. The Council will therefore need to ensure that suitably worded conditions covering the materials and maintenance of these public green spaces are secured. 62 To summarise, the principle of estate renewal is generally supported and will revitalise the Loughborough Park Estate and its environs, establishing a new presence for the area and the wider Brixton area. However, there still remain issues relating to public space design and further work is therefore required to ensure that the proposal fully complies with the London Plan. Access and inclusive design 63 London Plan policy 4B.5 and the corresponding draft replacement London Plan policy 7.2 seek to ensure that proposals achieve the highest standards of accessibility and inclusion (not just the minimum), and this and all developments should seek to better minimum access requirements. Policy 3A.5 requires that 10% of new housing is designed to be wheelchair accessible, or easily adaptable for residents who are wheelchair users. Design and access statements should explain the design thinking behind the application and demonstrate how the principles of inclusive design, including the specific access needs of people with disabilities, have been integrated into the proposed development and how inclusion will be maintained and managed. 64 The applicant has committed to ensuring that all of the housing is designed to Lifetime Homes Standards and has provided details of how these would be achieved. A typical layout of two unit types has also been provided to show how phase 1 of scheme meets Habinteg’s Wheelchair Housing Design Guide principles. Entrances would have level thresholds, with canopies, and suitably sized door widths. Circulation space is indicated on plan, together with storage space. Confirmation that the applicant has referred to the July 2010 revised Lifetime Homes standards should be provided. page 10 65 The accommodation schedule indicates that 52 of the units would meet wheelchair accessibility standards, equating to 10%, and a commensurate amount of blue badge parking would be provided. The wheelchair accessible units would be allocated across tenures and mixes, and in phase 1, would be located at ground and first floor. Two lifts are provided to the cores where such units are on upper levels. The commitments that the applicant has made in relation to phase 1 are welcomed, and it will be important for the Council to secure these as part of future phases. 66 In terms of the external environment, the applicant has indicated how the landscaping and access routes throughout the scheme have embodied the principles of inclusive design. The site is level, and priority would be given to pedestrians and cyclists on the shared surface streets, by using traffic calming measures and external treatments. The applicant’s commitment to providing level access to the gardens, community centre, and main block entrances is welcomed. Given that landscaping in future phases is to be considered as a reserved matter, as well as details of the community centre, and that these applications will not be referred to the Mayor, the Council will need to ensure that the shared spaces are fully inclusive, paying attention to the needs of visually impaired people, in order toe ensure that the scheme is fully compliant with London Plan policies 3A.5 and 4B.5. Children’s play space 67 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”. This is reinforced under policy 3.6 of the draft replacement London Plan. 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 320 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 3200 sq.m. of playspace, of which approximately 990 sq.m. should be provided on-site for under 5 year olds. 68 The design and access statement includes a play strategy, which assesses the child yield of the development and identifies existing local play provision in accordance with the Mayor’s SPG. The scheme includes communal landscaped spaces around the buildings, with the existing ball court being re-provided in the centre of the site, all indicated on plan. The applicant confirms that a total of 4,320 sq.m. of communal gardens and play areas would be provided in the development. A more detailed scheme for the central area and spaces between the buildings is also indicated, showing landscaped areas and play space for different age groups. Given the outline nature of the application, this detail is welcomed, and indicates the applicant’s commitment to providing useable communal amenity space for residents. 69 The strategy confirm that a total of 3,198 sq.m. of play space would be required to meet the child yield of the development, of which 996 sq.m. for under-5’s should be provided. This accords with the Mayor’s SPG. However, earlier in the report, the applicant suggests that only 800 sq.m. of doorstop play for under-5’s is proposed, with 800 sq.m. for 5-11 year olds and 800 sq.m. for 12 plus. These figures differ from the child yield/10 sq.m. requirements and as such, clarification is required in relation to the actual amount of dedicated play space for each age group that would be provided. A more detailed plan shown the allocated playspace for each age group, and its size should be provided before the application is reported back at Stage 2, in order to be clear that the scheme is in accordance with the Mayor’s SPG. 70 The close proximity to Loughborough Park is such that it would provide a useful amenity space for residents of the scheme, however further discussion is required with the page 11 Council before the scheme is reported back at Stage 2 in order to establish whether the park is adequate to cater for the needs of existing and future residents, including active play equipment for children of all age ranges and abilities, including the requirement for any financial contributions towards its improvement. Ambient noise 71 London Plan policy 4A.20 ‘Reducing noise and enhancing soundscapes’ requires that noise sensitive development should be separated from major sources of noise wherever practicable. The corresponding policy within the draft replacement London Plan is policy 7.15. The advice contained in Planning Policy Guidance note 24 (PPG24): Planning and noise is also relevant. 72 The dominant noise sources in the area of the proposed development is railway traffic and the applicant’s noise assessment indicates that monitored noise levels places the site into the NEC C, as defined by PPG24. The guidance states that “Planning permission should not normally be granted. Where it is considered that permission should be given, for example because there are no alternative quieter sites available, conditions should be imposed to ensure a commensurate level of protection against noise.” 73 The noise assessment demonstrates that high noise levels from trains would affect the development, and that the facade of the proposed development would be required to provide sufficient attenuation to ensure that the guideline internal noise levels conditions are met. Particular attention will need to be paid to glazing which faces the railway, with provision made for secondary glazing, and ideally bedrooms being located away from these facades. The Council should ensure that appropriately worded conditions are imposed in this respect, including a requirement that maximum noise levels are not exceeded. Sustainable development 74 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. The corresponding policies within the draft replacement London Plan are set out in chapter 5. Climate change mitigation 75 Policies 4A.2 to 4A.8 of the London Plan focus specifically on how to mitigate climate change, and the carbon dioxide emissions reduction targets that are necessary across London to achieve this. Developments are required to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions (be lean), adopting sustainable design and construction measures and prioritising decentralised energy (be clean), including renewables (be green). Energy efficiency standards 76 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include mechanical ventilation with heat recovery, minimising the use of thermal bridging and low energy lighting. page 12 77 The development is estimated to emit 1,140 tonnes of carbon dioxide emissions per annum after the application of passive design and energy efficiency measures. Based on the information provided, the proposed development does not appear to achieve any carbon savings from energy efficiency alone compared to a 2010 Building Regulations compliant development. 78 The applicant should commit to exceeding 2010 Building Regulations compliance through energy efficiency measures alone. District heating 79 It is stated in the documents that there are no district heating networks within the vicinity of the proposed development. The applicant has, however, provided a commitment to ensure that the development is designed to connect to future district heating networks should one become available. 80 A communal heat network is being considered for the proposed development. The applicant should confirm that both the residential units and community centre will be connected via a site wide heat network. 81 An energy centre, measuring 204 sq.m. would be located within Block A2,, and would be built in phase 1 to supply the whole development. This is welcomed. A drawing showing the layout of the energy centre has been provided. The commitment to the single energy centre should be secured as part of the planning permission, ideally by way of section 106 obligation. Combined Heat and Power 82 The applicant is proposing to install a 131kWe CHP unit to provide domestic hot water and part of the space heating. Load profiles have been provided. During the phased build out, a gas boiler plant is proposed to be used to supply the heat network until sufficient heat load is reached in Phase 3 to introduce the CHP unit. 83 The development is estimated to emit 912 tonnes of total carbon dioxide emissions per annum after the application of CHP. A reduction in carbon dioxide emissions of 228 tonnes per annum (20%) will be achieved through this second part of the energy hierarchy. Cooling 84 The applicant proposes that the balconies would act as shading devices for the glazed sliding doors, thus limiting heat gain. The applicant suggests that no mechanical cooling is necessary and this is supported by SAP modelling. Renewable energy technologies 85 The applicant is proposing to install photovoltaic panels (PV) on the roof of the buildings. In total, 29kWp PV array would provide a renewable contribution for the proposed development. The applicant estimates that approximately 24,364kWh will be generated per annum. A drawing showing indicative PV array placement has been provided. The PV should be secured by condition of any planning permission. 86 A reduction in carbon dioxide emissions of 13 tonnes per annum (1.5%) will be achieved through this third element of the energy hierarchy. Summary 87 Taking into account the comments above, the applicant should provide an estimate of the overall regulated carbon dioxide emissions. In addition, the carbon savings, expressed both page 13 in tonnes carbon dioxide per annum and percentages, compared to a 2010 Building Regulations compliant development, should be provided. Further discussion would also be appropriate, should the Council recommend approval, in relation to clauses and obligations in any section 106 agreement, or conditions imposed on the planning permission. Climate change adaptation 88 The London Plan promotes five principles in Policy 4A.9 to promote and support the most effective adaptation to climate change. These are to minimise overheating and contribute to heat island effects; minimise solar gain in summer; contribute to flood risk reduction, including applying sustainable drainage; minimising water use; and protect and enhance green infrastructure (the corresponding draft replacement London Plan policy is policy 5.3). There are specific policies covering overheating, living roofs and water. Further guidance on these policies is given in the Mayor’s SPG Sustainable Design and Construction. 89 Policy 4A.11 and draft London Plan policy 5.11 seek major developments to incorporate living roofs and walls where feasible. Policy 4A.14 of the London Plan and Policy 5.13 of the draft replacement plan seek to ensure that surface water run-off is managed as close to its source as possible and sets out a hierarchy of preferred measures to achieve this. Policy 4A.16 of the London Plan and policy 5.15 of the draft replacement plan seek to ensure that new development has proper regard to the impacts on water demand and existing capacity by minimising the use of treated water and maximising rainwater harvesting. 90 The applicant has submitted a sustainability statement, which includes an assessment against the Mayor’s essential standards. The applicant states that it is intended that all homes be designed to meet Code for Sustainable Homes Level 4 and the community centre would achieve BREEAM ‘Very Good’. The energy strategy employs a number of techniques to reduce energy consumption and cut carbon emission, using low energy lighting, energy efficient appliances, metering, high levels of insulation, and by maximising solar gain. Low water use sanitary-ware and fittings will be specified in order to meet target water consumption levels, and a sustainable urban drainage system is proposed, including permeable paving, attenuation measures and rainwater harvesting. Green roofs are proposed for Blocks B-E, to regulate surface runoff and enhance biodiversity (Block A would contain PV panels). Lambeth Council should secure these commitments as part of any planning permission. Transport 91 Officers note that the transport assessment submitted with the application utilises the TRICs database for trip generation calculations. However, in line with the TfL Transport assessment best practice guidance (April 2010), the TRAVL database should be used for sites within London. In order to establish a robust trip generation for the proposed development, these modal splits should be calculated using appropriate sites from the TRAVL database. 92 Furthermore, the transport assessment fails to accurately assess the mode splits for non-vehicular modes. In order to establish a robust trip generation for the proposed development, these modal splits should be calculated using appropriate sites from the TRAVL database. It is appreciated that the trips generated from the proposed 135 additional units are unlikely to have a significant traffic impact on the highway network, but these corrections are expected. 93 The proposed development is intended to be accessed via a priority junction off Loughborough Park, located approximately 50 metres further south of the existing access point. This approach is accepted in principle but there will need to be further discussion in relation to relocating the P5 bus stop adjacent to the site. Any works associated with page 14 relocating the bus stop must be fully funded by the applicant, and be secured by way of legal agreement. 94 Furthermore, in relation to buses, the transport assessment does not clearly illustrate bus trips generated by the proposed development. However, given the scale and existing use of the site, it is not expected that the development would have any significant impact on bus capacity, which is welcomed. 95 In terms of parking, the scheme proposes 180 car spaces on site, including 120 at surface level and sixty spaces in the basement of Block E. This would replace the existing 191 spaces that currently serve the existing residents, and would reduce the parking ratio from 0.49 spaces per unit to 0.34 spaces per unit. To accord with the London Plan (2008) policy 3C.23, and the draft replacement London Plan policy 6.13, a car parking management plan will be necessary to monitor and manage parking on site. 96 Before the application is reported back at Stage 2, the number of disabled spaces needs to be clarified. It is recommended that 10% of the residential spaces be allocated for disabled users to support the proposed 10% accessible residential units. In addition, there should be a disabled space provided for visitors to the community centre. 97 The applicant’s proposal to provide car club spaces and electric vehicle charging points within the scheme is welcomed. However, in order to comply with the draft replacement London Plan policy 6.13 a total of 20%, or 36 spaces, should be equipped with ‘active’ electric vehicle provision with an additional 20% ‘passive’ provision which allows for further spaces to be accessed when demand dictates. 98 Currently there is no controlled parking zone (CPZ) surrounding the estate, although the applicant has stated that it is the Council’s intention to extend Zone B within the next 1-2 years. On this basis, it is recommended that residents be excluded from the right to parking permits for existing and future CPZ’s in order to reduce the impact of overspill parking on the surrounding streets. 99 With regards to cycle parking, a total of 618 spaces are proposed for the residential units. This level of provision is welcomed and is consistent with the draft replacement London Plan cycle parking standards. It is noted that the London Housing Design Guide (Interim Edition) recommends one cycle parking space for one and two-bedroom units, and two spaces for three or more bedroom units. The cycle storage would be accommodated within each building core, which is also welcomed. It is recommended that at least 20 additional cycle spaces for visitors to the residents and community centre be provided. These spaces should be sheltered, secure and easily accessible. This would ensure general conformity with the London Plan (2008) policy 3C.22 and the draft replacement London Plan policy 6.9. 100 The residential travel plan submitted as part of this application is welcomed, however, the plan has failed the ATTrBuTE assessment used by TfL to assess the content. Therefore, further work is required before the travel plan can be considered to be in general conformity with the London Plan (2008) policy 3C.2 and draft replacement London Plan policy 6.11. The travel plan should be secured, enforced, funded, monitored and reviewed as part of any section 106 agreement. 101 It is noted that there will be a dedicated access point for maintenance, emergency and refuse vehicles to the north-west of the estate from Loughborough Park and that this will be controlled and gated. There are no objections to this. page 15 102 A construction logistics plan and a delivery and servicing plan will be required, in line with the London Plan (2008) policy 3C.25 and draft replacement London Plan policy 6.14. These should be secured by use of planning conditions. Local planning authority’s position 103 It is understood that Lambeth Council will be considering the planning application in January 2010, but as yet, officers have yet to form a view on the application. Legal considerations 104 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations 105 There are no financial considerations at this stage. Conclusion 106 London Plan policies on regeneration, housing, density, urban design, play space, inclusive design, sustainability and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons: Principle of development: The principle of estate renewal with an increased housing provision is supported by London Plan policy. Housing: The re-provision of existing affordable housing, and the introduction of intermediate housing is in accordance with London Plan policies. Further information is required to demonstrate that the maximum reasonable amount of affordable housing will be provided, and that an appropriate housing mix will be achieved in order to comply with the London Plan. Standard of residential accommodation: The applicant has committed to providing a satisfactory residential environment for its occupiers in terms of size and layout of the units, in accordance with the draft interim Housing Design Guide. Density: The proposed residential density is in accordance with the guidance range set out in the London Plan for this urban location. Urban design: The proposal is broadly consistent with the design principles of the London Plan, subject to further clarification and information. page 16 Children’s play space: A play strategy has been submitted, however further clarification and details are required to demonstrate that the scheme complies with London Plan policy 3D.13 and relevant planning guidance. Inclusive design: The applicant has committed to meeting Lifetime Homes standards, together with provision of 10% wheelchair accessible units. Sufficient detail has been provided in relation to the location and layout of the wheelchair accessible units and the quality of the landscaping to ensure compliance with London Plan policies 3A.5 and 4B.5, details of which should be secured by way of condition. Energy: the applicant has broadly followed the energy hierarchy. Sufficient information has been provided to understand the proposals as a whole. Further revisions and information is required before the proposals can be considered acceptable and the carbon dioxide savings verified. Climate change adaptation: The applicant has given consideration to the Mayor’s SPG on sustainable design and construction, with details of green roofs and other measures proposed in order to achieve Code for Sustainable Homes Level 4. These commitments should be secured by way of condition. Transport: The scheme is broadly acceptable from a transport and parking perspective subject to clarification and further information being provided. 107 Whilst the application is broadly acceptable in strategic planning terms, on balance the application does not comply with the London Plan. 108 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan: Housing: Further discussion with the Council is required before the scheme is reported back at Stage 2, so as to ensure that the maximum reasonable amount of affordable housing is secured over the life of the scheme (in light of its dependence on grant funding) and that the housing mix is reflective of local housing needs. Urban design: Further information and discussion is required before the scheme is reported back at Stage 2, in relation to the public realm and entrance routes. Children’s play space: Further discussion and information is required in relation to the levels of play space provision and an assurance that nearby parks have sufficient capacity for this and recently constructed schemes in the vicinity. Energy: The applicant should provide an estimate of the overall regulated carbon dioxide emissions. Additionally, the carbon savings, expressed both in tonnes carbon dioxide per annum and percentages, compared to a 2010 Building Regulations compliant development should be provided. Transport: Further information is required in relation to the travel plan, disabled and electric vehicle car parking, dedicated visitor cycle parking spaces, together with a commitment to submitting a delivery and construction logistics plan, and discussion regarding the possible relocation of the P5 bus stop. for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email email@example.com page 17 Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email firstname.lastname@example.org Samantha Wells, Case Officer 020 7983 4266 email email@example.com page 18