crittalls corner report

							                                                             planning report PDU/0844/01
                                                                                 21 January 2004

                                                    Crittalls Corner, Sidcup
                                                          in the London Borough of Bexley
                                                 planning application no.03/03926/FUL


Town & Country Planning Act 1990 (as amended); Greater London
Authority Act 1999; Town & Country Planning (Mayor of London) Order
2000 – strategic planning application stage 1 referral

1) Demolition of existing Coca Cola Enterprises Ltd warehouses and
industrial building; erection of new highbay warehouse (8,225sq.m),
lowbay warehouse (3,499sq.m) and gatehouse; associated loading bays,
lorry marshalling zone and holding area, 90 space secondary car park;
alterations to vehicular access; servicing and landscaping. 2) Erection of
two storey DIY retail warehouse, trade sales area and garden centre
(11,826sq.m), 500 car parking spaces, new vehicular accesses to Edgington
Way and Cray Road, servicing and landscaping.

Context
1      On 23 September Bexley Council consulted the Mayor of London on a proposal to
develop the above site for the above uses. Under the provisions of the Town & Country
Planning (Mayor of London) Order 2000 the Mayor has the same opportunity as other
statutory consultees to comment on the proposal. This report sets out information for the
Mayor’s use in deciding what comments to make.

2      The application is referrable under Category 1C, 3E and 3F of the Schedule of the
Order 2000:
“…the building is more than 30 metres high and outside the City of London”.
“Development which does not accord with one or more provisions of the development plan in force in
the area in which the application is sited and comprises or includes the provision of more than 2,500
sq.m of floorspace for...Class A1 retail”.
“Development for a use, other than residential use, which includes the provision of more than 200 car
parking spaces and in connection with that use.”

3     If Bexley Council subsequently decides that it is minded to grant planning
permission, it must first allow the Mayor an opportunity to decide whether to direct the
Council to refuse permission.

4       The environmental information for the purposes of the Town and Country Planning
(Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken
into account in the consideration of this case.



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5      The Mayor of London’s comments on this case will be made available on the GLA
website www.london.gov.uk.

Site description
6      The application site lies within an area of land to the north of the Sidcup Bypass
(A20) and north-east of Crittall’s Corner roundabout. The wider industrial area is defined
by Edgington Way (A223) to the south and Cray Road to the west. It is bounded by a
narrow strip of open land to the north and east, through which the River Cray flows,
although there is further industrial and residential development beyond. Land use to the
western side of Cray Road is primarily residential. To the south there is an area of open land
between Edgington Way and the A20. The majority of the site is occupied by current
warehouse infrastructure for Coca Cola Ltd, providing the following key operations:
manufacturing, bottling, warehousing and distribution. The existing B&Q superstore is
located immediately opposite on Watery Lane, Crittalls Corner.

Details of the proposal
7       The proposals are two-fold. Firstly, the application proposes the demolition/partial
demolition of the existing Coca-Cola Enterprises Ltd warehouses, demolition of industrial
building adjoining No.24 Powerscroft Road and replacement with a new highbay warehouse
(8,225sq.m), lowbay warehouse (3,499sq.m) and gatehouse, the provision of 11 loading bays,
vehicle marshalling zone for 46 lorries, lorry holding area for 9 vehicles and 90 space
secondary car park. Secondly, the erection of a two storey B&Q DIY retail warehouse, trade
sales area and garden centre (11,826 sq.m), 500 car parking spaces, new vehicular access to
Edgington Way and Cray Road, servicing and landscaping. The joint applicant’s are Coca
Cola Enterprises Ltd and B&Q Properties Ltd.

Strategic planning issues and relevant policies and guidance
8      The relevant issues and corresponding policies are as follows:

 Employment Land               draft London Plan; LPAC Revised Advice on Planning for
                                Industry in London; draft SPG Industrial Capacity; PPG4
   Retail                      draft London Plan; PPG6; PPG13; RPG3
   Urban design                draft London Plan: PPG1
   Biodiversity                draft London Plan; the Mayor’s Biodiversity Strategy
   Transport                   draft London Plan; the Mayor’s Transport Strategy; PPG13
   Parking                     draft London Plan; the Mayor’s Transport Strategy; PPG13

Strategic employment land
9      The draft London Plan identifies Strategic Employment Locations as a means of
protecting industrial and storage/distribution uses as set by the LPAC Strategic
Employment Sites Framework 2000. The draft London Plan is designed to reconcile
demand and supply and take account of industry’s needs in terms of clustering, capacity,
environment, accessibility and cost requirements. Within this context the application site
(within Foots Cray Business Area) has been identified as a Strategic Employment Location
(Industrial Business Park).

10.     Policy 3B.6 of the draft London Plan states: “With the LDA, boroughs and other relevant
partners the Mayor will promote and manage the varied industrial offer of the Strategic Employment
Locations (SEL) set out in map 3B.1….as London’s strategic reservoir of industrial capacity”. On

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17 July 2003 the Mayor of London received the Panel’s Report following the Examination in
Public of the draft London Plan in March-April 2003. The protection afforded to Strategic
Employment Locations was supported by the Panel during the Examination in Public. In
reference to SELs the Panel report: “The designated locations seem to be generally accepted. Their
strategic nature means that their future development, transport links and connecting them with skills
and economic development programmes will be of sub-regional importance. While policy will be
primarily for the Boroughs, we consider that there is a sub-regional dimension which requires that the
SELs at least be identified in SRDFs”.

11.      The draft London Plan, together with the supporting draft SPG “Industrial Capacity”,
reaffirm the effective policy approach to sustain the strategic reservoir of industrial capacity
in designated Strategic Employment Locations (SELs), subject to regular review of changing
demand and supply. In accordance with the overall approach to ‘planning, monitoring and
managing’ development, changes to the SEL framework should therefore only be undertaken
in the light of strategic and local reviews of industrial demand and supply. Furthermore,
departures from this will send confused messages to developers and tend to increase the
‘hope value’ of land making it uncompetitive for industry or even lead to it being kept vacant
and out of productive, industrial use.

12.     A review of Primary Employment Areas was recently undertaken by Bexley Council
based on past uptake rates entitled “Take Up of Industrial Land in Primary Employment Areas”.
The assessment concludes that there is only sufficient land for between 5 and 8 years supply,
and that the most recent take-up rates suggest a 5-year supply. The review also finds that
requirements for office and warehousing up to 2006 will be significantly greater than was
anticipated when the adopted plan was prepared. Furthermore, this assessment was recently
tested by an Inspector during the Inquiry into Bexley’s Unitary Development Plan Review.
In summary, the Inspector stated: “In my view this does not represent an overly generous supply of
land within the Primary Employment Areas such as would justify its use for non-employment
purposes”. The inspector goes on to say: “All of these factors strongly suggest that allocated sites
should not be lost to other uses unless there are over-riding reasons to justify the loss”. As such the
proposal for retail development in this location is contrary to established and emerging UDP
policy.

13.     Whilst the draft London Plan and supporting draft SPG do not preclude the
possibility of mixed and more intensive forms of development on Strategic Employment
Locations where there is no significant net loss of industrial employment capacity many
industrial firms do not need and cannot afford a high quality environment and would not
benefit from being mixed with other activities. Furthermore, good public transport access is
an essential pre-requisite for such intensification. These conditions do not, and are unlikely
to, exist in future on this application site. Nor would the characteristics of the site lend itself
to more sensitive uses such as housing. As such, lower density, single use areas with
adequate vehicle access offers the greatest scope for viability in this location if industrial
firms are to remain competitive. In these locations re-development must not compromise
their offer as the main strategic and local reservoir of industrial capacity, particularly where
(as in this instance) there is a limited supply of industrial capacity.

14.     As the applicant states, a further consideration in determining the planning
application, will be whether the proposed quantity and quality of jobs will deliver greater
benefits to the community than retaining the site for warehousing and industry. Due
consideration is therefore given to the potential employment generated by the proposals and
the regenerative benefits. The supporting material indicates that the proposed B&Q
warehouse would create 240 jobs and that this is greater than would be created by either

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warehousing or industrial redevelopment on the vacant part of the application site.
However, PPG6 states clearly that “retail development must not simply be used as a mechanism to
bring vacant or derelict sites into development, unless it would support the vitality and viability of
existing centres. Developments, especially those out of centre, may compete with town centres which
may need investment for their own regeneration”.1 It goes on to say: “the local job creation benefits
from retail proposals should be carefully assessed as there may be off-setting losses elsewhere in the are
when trade is diverted”.2 With these consequences in mind the net gain of jobs would not be
dissimilar to the number that could be generated by an alternative industrial or warehousing
development on this part of the application site. Even omitting these consequences the
applicant calculates that a redevelopment on the whole of the site would generate
employment levels as follows: 377 manufacturing jobs or 279 distribution jobs.

15.     The applicant has not provided any information to demonstrate that there is no
industrial demand for the whole site. In line with the draft SPG “Industrial Capacity” this
should include evidence that the site has been adequately marketed at realistic prices for a
reasonable period of time (normally at least two years) and whether the site has been vacant
for a considerable period (normally at least two years, and up to five years in areas of
generally strong demand) without realistic prospect of industrial re-use.

16.     In strategic planning terms, distribution functions comprise a significant element of
much general industrial activity in London and are expected to become more important.
This is diminishing traditional differences in employment density between production and
distribution. More specifically distribution facilities, such as large warehouses, also provide
a key economic service for the capital, even though they usually have low employment
densities. Distribution serving a city region of over seven million people performs a vital
economic function as well as providing modern, economically sustainable employment
opportunities.3

17.     The consolidation and expansion of existing production and distribution (i.e. Coca-
Cola) within this Strategic Employment Location is strongly supported by strategic
planning policy and will continue to provide a key economic service for the capital. The
application indicates that this investment will enable the centre to maintain it’s viability as
one of two key manufacturing and distribution centres for London and the south of England.
Furthermore, the expansion of the existing site would obviate the need for ‘double handling’
(the practice of products being stored off-site and then transported back on-site) and would
therefore, be in the interests of sustainable development. Conversely, the related proposal
for a B&Q warehouse on part of the Strategic Employment Location is contrary to national,
regional and local planning policy. Furthermore, the applicant has not supplied supporting
evidence to demonstrate that the application site has been marketed for employment uses
without success and that development for these purposes would not be viable.

Retail
18.       In terms of new retail and leisure development, policy 3D.2 in the draft London Plan
states that “Where need for additional development is established, capacity to accommodate such
development should be identified within the UDP following a sequential approach; relate the scale of
retail, commercial and leisure development to the size and role of centres and encourage appropriate
development on sites in town centres. If no town centre sites are available, provision should be made on


1 PPG6, 3.24
2 PPG6, 3.25
3 draft London Plan, Industrial Capacity: draft Supplementary Planning Guidance, September 2003.


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the edge of centres and failing that within or on the edge of appropriate centres elsewhere in the
network. Out of centre development should be resisted in all but the most exceptional circumstances”.

19.     The draft London Plan does not support the principle of a redevelopment, which
would establish and intensify a pattern of activity that is highly dependent on mass car-use
and excludes many Londoners from access to the jobs and facilities they provide. The
strategic policy direction is to channel new retail activity into the existing network of town
centres through a rigorous application of the sequential test to all retail proposals. This
approach is supported in PPG6 and Bexley Council’s emerging UDP (Review). In line with
PPG6 the applicant must: demonstrate that there is a need for the development; having
established that such a need exists, adopt a sequential approach to site selection; consider the
impact on nearby centres; and provide evidence on the site's accessibility by a choice of
means of transport, as demonstrated by a transport assessment (see PPG13), the likely
changes in travel patterns over the relevant catchment area, and any significant
environmental impacts.
20.     In strategic terms, the proposal for a DIY store in this location is in conflict with
emerging and established national and regional policy by virtue of its location relative to the
established district centre. Overall, the application does not adopt the general policy
approach of established and emerging planning policy. In strategic planning terms, the
application raises a number of significant concerns, each addressed in turn here. Firstly, the
proposals would have a negative impact on the emerging and established development plan
strategy (Bexley UDP): the proposal entails retail development on land allocated for other
uses in the Bexley UDP and draft London Plan; the supporting material does not give due
consideration to alternative retailing formats in accordance with national and regional
planning policy; in calculating the number of jobs created the proposals have not taken
account of either the loss of jobs from the existing store, or the offset of jobs through
competition with other stores.
21.     In relation to the first two concerns raised, the adopted Bexley UDP identifies the
Foots Cray Business Area as a Primary Employment Area. Policy E6 states: “….planning
permission will not normally be granted for purposes other than business use (Class B1) in the Foots
Cray Business Area. Exceptionally B2 or B8 developments may be permitted to meet the needs of
existing industrial or commercial occupiers”. In the same vein, the ongoing review of the UDP
has reinforced this designation. The review of the Bexley UDP is now at an advanced stage,
having being considered at Public Inquiry and modified to reflect the Inspector’s
recommendations. The Council intend to adopt the plan shortly. The proposals are
contrary to the adopted and emerging policies of the Bexley UDP. Given that the Inspector
concluded that there was no justification for the loss of Primary Employment Areas for non-
employment purposes and this followed a recent review of employment capacity in the
borough it is likely the proposal for retail development on land allocated for other uses
would have a prejudicial and negative impact on the implementation of the development
plan.
22.    In providing evidence that they have complied with established planning policy
guidance, applicants must demonstrate flexibility and realism in terms of the format, design
and scale of their development, and the amount of car parking, tailoring these to fit local
circumstances. To accord with the London Plan and urban renaissance objectives of
achieving sustainable patterns of development, it is incumbent on retail operators to adopt a
more innovative and flexible approach to the location, size and trading format of new stores
and demonstrate that a majority of their goods cannot be sold from town centre stores. This
evidence has not been produced with the application and the application is therefore contrary


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to the draft London Plan, RPG3, PPG6 (together with subsequent clarifications) and PPG13
in respect of the development of an out-of centre retail facility.
23.       The emerging London Plan strongly supports the application of a sequential test to
the location of trip-generating developments such as DIY stores. This rigorous approach to
site selection has not been adopted by this application and is therefore contrary to
established national, regional and local planning policy. This needs to assess, for instance,
the availability of other out-of-centre sites with greater public transport accessibility or the
prospect of expanding the existing store in it’s current location. The car-orientated nature
of bulky goods stores is largely because their typical trading format reflects an over-
emphasis on display and a lack of flexibility on the part of operators to adapt to the more
sustainable patterns of activity advocated in PPG6. Neither the firm nor the applicant’s
planning consultants have given consideration to a more innovative and sustainable
approach.

Urban design/development quality
24.     Policy 4B.1 on design in the draft London Plan states that the Mayor should
encourage, support and require new development to, amongst other things, enhance the
public realm; be accessible and permeable for all users; be sustainable and durable; and be
inspiring, exciting, practical and legible. The current layout for the DIY store is largely
dictated by excessive car parking. A less hostile approach could have been created by
locating the car parking to the rear of the store, which would also produce a more acceptable
road frontage.

25.     There is no objection to a distribution/manufacturing building of this scale at this
location, but the quality and sustainability of the finish materials and the immediate setting
of the building should be appropriately high because of its significant presence in the
surrounding area. Essentially, the distribution building would function as a large box and
the functional/operational needs for a structure of this scale (to accompany the existing
buildings) are accepted.

26.     That said the visual prominence of the 36m high distribution buildings is significant
by virtue of the adjoining arterial road into London. The proposed buildings would be
particularly pronounced in long-distance views from the A20. The ‘box’ like appearance of
the building (particularly on the eastern elevation) could be modulated through a greater
vertical emphasis such as the use of recesses with an element of glazing where stairwells are
located to give the structure a more human scale. Further work on using lighting (subject to
ecological constraints) to enliven the elevations is encouraged and could be secured through
condition.

Biodiversity and Blue Ribbon Network
27.    The application proposes the replacement of part of a culverted watercourse, which
ultimately discharges into the River Cray. In line with Policy BR2 “the Mayor will and the
boroughs should protect and enhance the biodiversity of the Blue Ribbon Network by: taking
opportunities to open culverts and naturalise river channels”. Where possible the opportunity to
open culverts should be seized, particularly as the site is located adjacent to a Site of
Metropolitan Importance for Nature Conservation immediately to the east of the site.
Furthermore, any redundant ancillary buildings proposed to be demolished under these
proposals should be surveyed for bats.

Transport for London (TfL)
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Access to Public Transport
28.     The site is relatively inaccessible by public transport; it has a PTAL of 2. Three bus
routes operate along Cray Road stopping relatively close to the site. These routes provide
links to Woolwich, Orpington, Eltham and Sidcup Station operating an average frequency of
5 buses per hour. The closest rail station is St Mary’s Cray, which is situated 4.5km from
the site and is therefore unlikely to be used by B&Q customers. The site would become more
accessible and visible to pedestrians/cyclists and those using public transport if the store
was sited adjacent to the road with the car parking at the rear.


Impact on TLRN and car parking
29.     The proposed 500 car parking spaces for the retail development is far in excess of the
standards set out in the draft London Plan which has now been subject to an examination in
public. The draft London Plan states that a maximum ratio of 1/41 sqm (warehouse retail)
and 1/29 sqm (garden centre) should be used for areas with a PTAL of 2. Using these
standards the maximum level of car parking provided should be 307.

30.     TfL would expect to see a significant reduction in parking provision to comply with
the draft London Plan standards. Also the site is directly adjacent to the A20 which is a key
component of the TLRN. As such TfL is concerned that the significant increase in traffic
resulting from the high level of parking provision could lead to safety and operational
problems on this road.

31.     TfL are concerned that the Traffic Assessment does not include traffic generation
caused by other permitted developments in the area. There is also a concern that the TA
may have underestimated the amount of traffic likely to be generated by the developments
and as a result the capacity of both the circulatory lanes of the roundabout and the off slips
to the A20 may be exceeded. The applicant should therefore provide the required
supporting evidence and sensitivity testing before the full impact on the TLRN can be
assessed.

32.      The following assumptions will also need substantiating:
     That the expansion of the Coca-Cola enterprises will allow for rationalisation of the
      operation of the site and there will only be limited increase in traffic movements;
     That data relating to an existing modern store is more appropriate than TRICS. More
      detail is therefore required about the Sutton B&Q store to see how comparable it is, in
      addition to a sensitivity run with the TRICS data to see what that indicates;
     That new retail facilities result in a redistribution of existing trips rather than generate
      new trips. TfL needs sensitive testing on the 72% primary trips and 25% pass by trips by
      using, for example, 82% and 15% respectively.
Buses
33.     The increase in traffic generation could potentially cause substantial delays to buses
travelling westbound along Cray Road. The eastbound and westbound bus stops are
situated directly opposite each other on Cray Road as a result of the proposed development
the increase in road traffic is likely to create capacity problems during the peak periods.

London Development Agency (LDA)


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34.     The LDA would support a proposal that would bring this key site in Bexley back into
use following the period of vacancy as a result of proposals for retail development. It
welcomes the proposed expansion of the Coca Cola premises. However, the Agency is aware
that there is not a surplus of land for business, industrial and warehousing development in
the borough and indeed if anything there is an undersupply. This point has been tested and
confirmed at the recent Inquiry into the UDP. The applicant furthermore has not yet
supplied appropriate supporting evidence to demonstrate that the application site has been
marketed for employment uses without success and that development for these purposes
would not be viable. Nor have the details they have provided so far on employment
generation by the proposed B&Q store satisfied us that there would be a net benefit in jobs
terms from accepting retail compared with development of the site for employment purposes
as allocated in the UDP. Unless or until this evidence has been presented and the retail
element of the development fully justified the loss of part of this employment site should, in
the Agency's view, be resisted. The Agency would also suggest that the applicants are asked
to confirm the future of their existing store on the site on the opposite side of the road and in
particular whether it was to be retained in retail use or be made available for alternative
potentially more acceptable purposes.
Sustainable design and construction
35.     In line with Policy 4B.6 of the draft London Plan the Mayor expects all future
developments to meet the highest standards of sustainable design and construction. The
local authority should ensure that the scheme incorporates measures to conserve energy,
materials, water and other resources.

Equal opportunities considerations
36.    The draft London Plan does not support the principle of a redevelopment which
would establish and intensify a pattern of activity that is highly dependent on mass car-use
and excludes many Londoners from access to the jobs and facilities they provide. TfL
welcomes the measures outlined in the travel plan promoting the use of public transport and
green travel modes. However, it is essential that this document is enforced and monitored
over time.

Local planning authority’s position
37.    Officers’ recommendation is not yet known.

Legal and financial considerations
38.     Under the arrangements set out in article 3 of the Town and Country Planning
(Mayor of London) Order 2000 the Mayor has an opportunity to make representations to
Bexley Council at this stage. If the Council subsequently resolves to grant planning
permission, it must allow the Mayor an opportunity to decide whether to direct it to refuse
planning permission. 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 comments unless specifically stated.

39.    There are no financial considerations at this stage.

Conclusion


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40.     The consolidation and expansion of existing manufacturing, bottling, warehousing
and distribution (i.e. Coca-Cola distribution centre) within this Strategic Employment
Location is strongly supported by strategic planning policy and will continue to provide a
key economic service for the capital. However, there are a number of transport and design
issues identified in this report, which require further consideration.

41.     In strategic planning terms, the retail element of the application raises a number of
significant concerns. Namely, the proposals would have a negative impact on the emerging
and established development plan strategy (Bexley UDP): the proposal entails retail
development on land allocated for other uses in the Bexley UDP and draft London Plan and
would prejudice the designation of the entire site as a Primary Employment Area and
Strategic Employment Location respectively; the supporting material does not give due
consideration to alternative retailing formats in accordance with national and regional
planning policy; the applicant has not provided evidence to indicate that there is no
industrial demand for the entire site; and, in calculating the number of jobs created the
proposals have not taken account of either the loss of jobs from the existing store, or the
offset of jobs through competition with other stores. This part of the application also raises
significant transport issues, including car parking spaces far in excess of the standards set
out in the draft London Plan.

42.    The strategic policy direction is to resist such forms of retail development and to
channel large new retail activity into the existing network of town centres through a
rigorous application of the ‘sequential test’ to all out-of-centre retail proposals, an approach
not adopted in this application. The overall approach adopted in the draft London Plan and
supporting draft SPG “Industrial Capacity” to ‘planning, monitoring and managing’
development has not been applied to this application and no over-riding reasons have been
provided to justify a net-loss of employment capacity.



for further information, contact Planning Decisions Unit:
Giles Dolphin, Planning Decisions Manager
020 7983 4271 email giles.dolphin@london.gov.uk
Colin Wilson, Acting Team Leader Development Control
020 7983 4493 email colin.wilson@london.gov.uk
James Farrar, Case Officer
020 7983 6589 email james.farrar@london.gov.uk




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