croydon gateway report by 3gL5jKbP

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									                                                          planning report PDU/0459b/01
                                                                              23 February 2005

               Croydon Gateway (Stanhope/Schroders)
                                                      in the London Borough of Croydon
                               planning application nos. 04/04777/P & 04/4778/P


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

The proposal
Demolition of existing buildings (including Wettern House, Warehouse Theatre, retail
premises forming Station approach and storage and maintenance yards) for the development
of a 26 storey landmark office building and a further three office buildings ranging in height
from 10 to 15 storeys, residential development comprising 560 residential units (private,
affordable housing and live-work units), a replacement 200 seat theatre, ground floor café and
restaurant uses, health and fitness club, landscaped public realm including a winter garden
and associated parking.

Strategic issues
Overall, the proposals respond positively to the provisions of the London Plan and the
designation of Croydon Town Centre as an Opportunity Area. The scheme would deliver a
striking addition to the Croydon skyline, setting new standards of design for the town centre.
The architecture and urban design is both coherent and convincing and a masterplan-led
approach has produced a rich and varied building composition. The main outstanding
strategic concerns relate to affordable housing and health impact and these need to be
addressed in full along with the other detailed access and transport issues raised elsewhere in
this report if the scheme is to be acceptable in strategic planning terms. In view of the
strategic importance of this site and its history, the applicant should also demonstrate further
that the key elements of the scheme, notably the high quality offices and the public realm and
facilities can be delivered, subject to statutory approvals, and that the full potential of this site
to make a significant contribution to the regeneration of Croydon town centre can at last be
realised.

Recommendation
That Croydon Council be advised that subject to the outstanding strategic issues raised in this
report being addressed fully the application is supported in strategic planning terms.

Context
1      On 17 November 2004 Croydon 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.


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2     The application is referrable under Categories 1B, 1C, 3E and 3F of the Schedule of the
Order 2000:

       1B - “Development (other than development which only comprises the provision of houses, flats, or
       houses and flats) which compromises or includes the erection of a building or buildings – c)
       outside Central London and with a total floorspace or more than 15,000 square metres.”
       1C – “Development which comprises or includes the erection of a building in respect of which
       one or more of the following conditions is met – c) the building is more than 30 metres high
       and outside the City of London.”
       3E – “Development which does not accord with one or more provisions of the development
       plan in force in the area in which the application site is situated and – a) comprises or includes
       the provision of more than 2500 square metres of floorspace for a use falling within – class
       A1, A2 and A3.”
       3F - “Development for a use, other than residential use, which includes the provision of more
       than 200 car parking spaces in connection with that use”..”

3      If Croydon 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.

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       This is a 3.4 hectare site immediately adjacent and to the west of East Croydon Station
about 450m to the east of Croydon Central Shopping Area, and bounded by George Street,
Dingwall Road, Lansdowne Road and the mainline railway into London. George Street is the
main linking route from East Croydon Station to the main cultural and shopping area. The
northern and central parts of the site are occupied as a car park by NCP and the Post Office.
The southern – eastern part of the site comprises mostly vacant land, but contains the disused
British rail ticket office. The south-western part of the site contains the Warehouse Theatre
and Wettern House, a ten-storey office building. Fronting George Street are single storey
buildings in use as an employment agency and a travel agency. To the north of Lansdowne
Road are various public and private car parks. The site is characterised by its under-use.

Details of the proposal
7       Two (duplicate) applications seek detailed planning permission for the development of
the site comprising the demolition of existing buildings and the construction of four office
buildings (10 to 26 storeys), six residential buildings (11 to 31 storeys), replacement theatre,
restaurant and cafe uses, health and fitness, public realm and associated landscaping and
parking. The residential element of the scheme proposes 560 new residential units, including
40% affordable units and live/work units. The total gross external area of all buildings stands
at 154,789sq.m. A large linear shaped ‘urban park’ is also proposed extending northwards
through the site which incorporates a winter garden and events space. The residential units
also have access to a private garden. Seven of the buildings will have parking at lower ground

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and ground floor levels. 35 ancillary spaces are proposed for commercial, leisure and theatre
uses. The proposed development would provide 655 car parking spaces and 840 cycle spaces.
The total floorspace is disaggregated as follows:


                        LAND USE                          AREA (sq.m.)

                         B1 Offices                        102,193sq.m.

                     A3 Food and drink                      5,323sq.m.

                          Theatre                            951sq.m.

                       Winter garden                        1,242sq.m.

                   D2 Health and Fitness                    2,779sq.m.

                         Live/work                           883sq.m.

                         Residential             43,541sq.m. (including live/work)

8      Three of the office buildings are designed by Fosters and Partners, including a 24-
storey tower adjacent to East Croydon station (see below) together with two lower office
buildings at 13 and 19 storeys. A fourth commercial building is proposed at the junction of
Dingwall Road and Lansdowne Road and is designed by Faulkner Browns. The residential
element is sited in the north eastern part of the site, comprising 560 homes including affordable
units and live-work units. The six buildings, also designed by Foster and Partners, are sited in
a curved configuration which wraps around a private garden. Two of these six buildings are
residential towers which would provide views across the London skyline. The application also
proposes a new 200-seat theatre which will replace the Warehouse Theatre currently located
on Dingwall Road. A series of restaurants and cafes are also proposed at ground level within
the colonnade area at the bottom of the office buildings.

9      The planning applications have been submitted by Croydon Gateway L.P., Cardwool
Limited (in administrative receivership) and BRB (Residuary) Limited (‘the applicant’). The
masterplanners are Foster and Partners.
Case history
10     There is an extensive and complex planning history relating to this site. The site has
been largely vacant for thirty years. There have been a number of applications submitted, none
of which have been formally approved. The site is the subject of a planning brief, approved by
Croydon Council (1998).

11     This detailed planning application is a further refinement of a previous outline planning
application which was submitted on 24 October 2001 and subsequently dismissed on appeal by
Secretary of State in July last year. On 21 May 2003 the Mayor considered a planning report
on the previous case (reference PDU/0459/01) and again on 18 June 2003 (PDU/0459/02).
Following the Secretary of State’s decision and also in response to the Mayor’s concerns the
applicant has revised the proposal to form the application scheme considered here. This
revised scheme has been the subject of a full environmental impact assessment including wind
tunnel testing.


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

    Economic development             London Plan; London’s Economic Development Strategy
    World city role                  London Plan
    Tourism/leisure                  London Plan; PPG21
    Affordable housing               London Plan; PPG3; draft Housing Provision SPG; draft
                                      Affordable Housing SPG
    Density                          London Plan; PPG3
    Urban design                     London Plan; PPS1
    Mix of uses                      London Plan
    Transport                        London Plan; the Mayor’s Transport Strategy; PPG13
    Parking                          London Plan; the Mayor’s Transport Strategy; PPG13
    Retail                           London Plan; PPG6; PPG13
    Biodiversity                     London Plan; the Biodiversity Strategy; PPG9
    Access                           London Plan; SPG “Accessible London: achieving an inclusive
                                      environment”
    Equal opportunities              London Plan
    Culture                          London Plan; the Culture Strategy; PPG21
    Tall buildings/views             London Plan; RPG3A
    Ambient noise                    London Plan; the Ambient Noise Strategy; PPG24
    Air quality                      London Plan; the Air Quality Strategy; PPG23
    Health                           London Plan

13     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 1997 Croydon Unitary Development Plan and
the 2004 London Plan. The replacement Croydon UDP is approaching public inquiry stage.

14      The replacement Croydon UDP contains a site-specific policy relating to this
application site. Policy LR4 states that “when determining any application for the redevelopment of
the Croydon Gateway site, the Council will have regard to how the proposals contribute to the general
achievement of the objectives of the Croydon 2020 Vision and to the specific of securing a 10,000-seat
(with a capacity of 12,500) covered Arena which must be of genuine strategic significance and capable of
hosting a variety of sports and entertainment events”. It goes on to say that “it [the Council] will
make full use of its planning powers to bring this regionally important site into beneficial use”.

15       In July 2004 the Mayor made representations on the replacement UDP to advise the
Council on the general conformity of the proposed plan with the published London Plan. In
relation to this policy the Mayor commented, “the London Plan does not oppose the provision of an
Arena in Croydon per se. However, paragraphs 15.12 – 14 indicate that such provision will require an
element of cross subsidy and that it should be built on the Gateway site. This site has been vacant or
underused for a long period and its re-development for more viable uses should not be constrained when
these could also contribute to the Mayor’s objective for Croydon as a Metropolitan Centre, Opportunity
Area and as a strategic office centre.” This corresponds with the Secretary of State’s conclusions
in relation to the applicant’s appealed scheme in which it is stated “the Secretary of State does not
attach so much weight to it as to rule out the possibility of a scheme for this site which does not include an
arena…” and, furthermore “that there is no justification for turning away the appellants’ proposals on
the basis that they do not include an arena” (paragraph 17).


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16     As time progresses, and should the policy remain unchanged following the forthcoming
Public Inquiry then the policy will acquire greater weight. It can still be considered in relation
to planning applications of strategic importance that are referred by the Council to the Mayor
but the weight that can be attached to it for the purposes of this planning report, and the
immediate future, is limited.

World city role, economic development
17        One of the Mayor’s principal purposes, under section 30 of the GLA Act 1999, is
promoting economic development and wealth creation in the capital. The London Development
Agency’s Economic Development Strategy acknowledges the ever increasing mobility of
increasingly global businesses and the impacts on London that could arise from a reduction in
its attractiveness to both new and existing business investors. London has a unique role in
providing headquarters functions for large UK, European and global companies. This part of
the wider services sector is a crucial element of London’s economy and fundamental to its
World City role. It is especially necessary for businesses, both UK and global, to have an
environment where they can expand. Both rents and the availability of suitable floorspace will
be leading considerations in this.

18     Croydon is recognised as London’s largest ‘Metropolitan’ centre and one of the capital’s
two strategic office centres outside central London. The London Plan indicates that Croydon
town centre, south London’s only Opportunity Area, could accommodate a minimum of 5,500
new jobs and 2,000 new homes to the end of the plan period (2016). Supporting information
indicates that the current application would generate approximately 323 full time jobs during
the construction phase and approximately 5,446 jobs upon completion, which almost matches
the Mayor’s minimum target for the entire Opportunity Area for the remainder of the London
Plan period. The proposals also include 560 new residential units and in both respects the
applicant’s response to the London Plan targets is laudable and, if fully implemented, would
make a considerable contribution towards achieving these targets.

19      There are some significant geographic mismatches in the London office market,
underscored by low rents achieved in the suburban London second-hand office market, which
provide little incentive for new investment. The London Plan recognises that Croydon can still
have a significant role in the office market. The London Plan also states that the sustainability
of the suburban market requires that “Any rejuvenation ……can only come about by consolidating its
current strengths and potential attraction. Renewal of the stock and new development should therefore
focus on a few types of key location where a market can be established for new and existing occupiers”.
The applicant states that the calibre of the existing office stock in Croydon is increasingly
outmoded such that some corporate firms have been unable to find suitable office
accommodation. The applicant also states that there is latent demand in excess of 1,300,000 sq
ft based upon lease expiries over the next seven years in Croydon and that the imminency of
break clauses within the borough has further condensed office requirements.

20      Research commissioned by the Greater London Authority1 suggests that relatively low
rents currently render new build offices unviable in Croydon. Nevertheless, the research also
indicates that speculative office development is considered ‘likely’ in the medium-term (2007-
2011) by promoting offices on the most efficient and accessible sites with residential-led mixed
use elsewhere with an overall emphasis on improving the image and vitality of the town centre.



1
    GLA Mixed Use and Affordable Housing Study (March 2004); London Office Policy Review (August 2004).

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21      The London Plan anticipates that Croydon will develop its unique new role as one of
only two named strategic office centres outside Central London and as an Opportunity Area as
well as a Metropolitan centre. The application proposals are broadly consistent with this
strategy and, if fully implemented, could make a valuable contribution to the rejuvenation of
the suburban office market.

Affordable housing, density
22      London has an acute shortage of affordable housing. One of the Mayor’s strategic
objectives is to increase substantially London’s supply of affordable housing and the London
Plan sets out an overall strategic target that 50% of new housing provision (supply from all
sources) should be affordable housing. The Mayor’s stated position in the London Plan is that
councils should seek the maximum reasonable amount of affordable housing, taking into
account individual site costs, the availability of public subsidy and other scheme requirements
(Policy 3A.8).

23       Of the 560 residential units provided, 40% are designated as ‘affordable’. In view of
the magnitude of the gap between current provision of affordable housing and estimated
need, and the serious potential consequences for London’s sustainable development and
economic competitiveness, the overall provision of 40% affordable housing is welcomed
although this still falls short of the London Plan strategic target. It is not currently clear
from the information submitted why at least 50% affordable housing cannot be achieved on
this site. Assessing the appropriate level of affordable housing should involve undertaking a
full financial viability assessment of the proposal, which evaluates a range of variables, in
addition to the availability of public subsidy. Other factors include the individual site costs,
economic viability, and the cumulative package of S106 benefits. Further information can be
found in the Mayor’s draft Affordable Housing SPG. The applicant should provide this
information before the application is determined so that the GLA and Croydon Council can
test the key financial assumptions behind the proposed level of affordable housing.

24      It is also not currently clear what definition of ‘affordable housing’ the applicant has
used or the probable tenure split. Affordable housing provision should take account of the
London-wide objective that 70% should be social housing at or below target rents and that 30%
be as intermediate housing affordable by households in the annual household income range of
£15,000 to £40,000 and take account of the Mayor’s draft Housing Provision SPG. The
applicant needs to provide this information before the application is referred back to the Mayor
for a decision. Any deviation from this strategic guide needs to be justified against borough-
wide housing need.

25     The applicant also needs to identify the mix of unit sizes (measured by the number of
bedrooms). This should be disaggregated for each category of affordable housing provision
within intermediate and social housing. In line with Policy 3A.4 the mix of affordable
housing provision should reflect the needs of the households for which it is being provided in
terms of number of bedrooms and other rooms, design, location and internal standards and
must adequately respond to the full range of differential housing needs within the diverse
community, in terms of location and appropriate social and physical infrastructure with
community support networks.

26       The London Plan density matrix range indicates a range of 240 to 345 units per hectare
for a site in this location with an accessibility index of 4-6. The scheme achieves a density of
approximately 160 units per hectare for the whole site, well below the density range. However,
in practice, a much higher density is achieved commensurate with the accessibility of the site

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based on the residential component alone. The density of the development is a key determinant
of the unit size mix, however, the applicant should take into account the Mayor’s draft
supplementary planning guidance on Housing Provision. This outlines the preferred housing
mix for market, social and intermediate housing tenures, based on the results of the GLA’s
housing requirements study.

Urban design, tall buildings and mix of uses
27        Considerable attention has been paid to delivering design excellence and the overall
masterplan-led approach to a site and development of this scale and nature is welcomed. The
masterplan has been led by Foster and Partners with significant input from Space Syntax and
West 8 for layout and landscape issues. The layout and landscape is inspired partly from
predictions of pedestrian flows to and from the major magnets including flows from projected
developments in the vicinity of the station and wider area. The resulting masterplan concept
focuses on the most likely movement pattern which is predicted to be northerly from East
Croydon Station and eastwards via George Street following the advice of Space Syntax. Over
half of the master plan site area is devoted to public space and this ambitious plan will provide
an urban park twice the size of Leicester Square but with its north-western corner enclosed
fully by a residential building. The new landscape will be laid out following a well-developed
landscape strategy.

28     The proposal is a group of five buildings of varying heights sandwiched between the
railway lines and Dingwall Road. The chosen arrangement of a series of linked buildings set
behind a new linear shaped urban park is, again, a direct response to the need for light
penetration at the lower levels in the new buildings and the desire to lessen their
overshadowing impact. The development is anchored by a 30-storey office block adjacent to
East Croydon Station on George Street.

29      The urban form of the new square will be of a cup handle shape with one southern
principal entrance and two northern connections with Lansdowne Road. As such, it will be
physically permeable allowing pedestrian flows to reach their likely destinations without major
interruptions. The most significant challenge to permeability is the hard edge created by the
railway line. This presents major difficulties by preventing significant east west movement.
To address this, there is an obvious gap between the office buildings that indicates a likely
future connection with land to the east of the station and this is strongly supported. If the
heavy engineering problems associated with the pedestrian link can be overcome, any east-west
connection provided here will be a significant urban design benefit and may presage future
improvements to east west links in adjacent blocks. Every effort should be made to bring this
forward at the earliest opportunity.

30      The three office blocks adjacent to the railway line are designed by Fosters and have a
similar architectural language, a series of modernist glass curtain wall buildings with repetitive
diagonal aerofoils providing a new and striking style for Croydon. The residential building
proposed for the north east corner of the site is designed by CZWG and the office and theatre
building facing Landsdowne Road is designed by Faulkner Brown. The submitted information
shows a pleasing contract of architectural styles with considerable attention paid to providing
varied buildings heights that will create an attractive and bold sequence of tall buildings on the
Croydon skyline. There is policy support for tall buildings in Croydon town centre in the
London Plan. A restaurant facility will be provided in the top floor of the tallest building
which will provide public access and stunning views of Croydon, also in accordance with the
London Plan. Public access should be secured in perpetuity through an appropriately worded
legal agreement.

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31      The proposal will be a landmark development that will reinforce Croydon as a regional
centre. By redeveloping a currently under used site which is adjacent to public transport, it
will re-use scarce urban land and optimise urban capacity in a phased manner and in line with
transport accessibility.

32      The application masterplan is design-led and is a direct response to the site’s
characteristics and environment. It contains a pleasing mixture of contrasting but high quality
architectural styles in a masterplan layout that responds well to the prevailing public realm and
improves on this by providing improvements to connectivity that could be significantly
enhanced if the pedestrian link across the railway lines is provided. The design concept
provides every reassurance that design quality will be central to the masterplan’s future
implementation. As such, it is likely to meet the London Plan’s very high standards for design
quality.

33     The Commission for Architecture and the Built Environment (CABE) has expressed the
view that the proposal is generally acceptable and has provided detailed design review from its
Panel. It has expressed concern over the assumptions on which the landscape strategy and
layout are based and in particular, the pedestrian flows and how these would relate to the
landscape strategy. CABE has also pointed to areas where the landscape plans are misleading,
correctly in our view. We also support CABE’s criticisms of the level of design development
and visual information for the ground planes of the buildings that will face the public space.

34     These are legitimate concerns but, in our view, they could be satisfactorily addressed by
appropriate planning conditions. The design concept itself is sufficiently robust to provide
reassurances that the perceived shortcomings reported by CABE’s panel can be resolved with
further development of the concept at a later stage in the project.

35     In particular, we support CABE’s assertion that significant further work on the design
development of the individual buildings is required. There is a need to integrate this work with
the extensive analysis of micro-climatic issues, the landscape strategy and wider town centre
urban design issues.

36      Nonetheless, the quality of the design concept and the evidence base upon which it has
been derived has, in our view, produced an urban redevelopment project of the standard that
will rank in the top quarter of comparable schemes in London and is therefore likely to meet
the London Plan’s very high standards for design. The residential element of the scheme
includes private gardens for residents and incorporates safe play space for children, which is
welcomed.

37      The proposals provide for a genuine mix of uses, and should present opportunities for
natural surveillance, particularly if all the live-work units are successfully implemented and
managed. The Warehouse Theatre currently operates from a building on the south-western
part of the site. The current application includes a proposal to accommodate bespoke premises
for the Theatre Company within a prominent part of the site and set within a landscaped area.
This would ensure the retention of an important community facility within Croydon and would
enhance the town’s cultural offer in line with the Mayor’s aspirations for Croydon as a major
Metropolitan and Opportunity Area, and is therefore supported by strategic planning policy.

38     The success and employment benefits of the live/work units and aspirations to create a
broad employment base will only be realised through a properly planned and managed
approach to avoid the prospect of either vacant units at ground level or the formal conversion
or gradual use of the work element for residential at a later date. The local authority should
ensure that such measures, including the provision of a management and layout plan, are
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secured through the s.106 agreement or sufficiently robust planning conditions. A key factor
is likely to be the tenure arrangements – the live/work units are most likely to be successful in
generating employment opportunities on the site if they are rented units rather than in freehold
ownership.

39       London Plan policy 3B.4 states that within Opportunity Areas, wherever increases in
office floorspace are proposed, they should contain a considerable amount of residential
floorspace (proportions defined in the to-be-completed sub-regional frameworks). The current
proposal complies with this requirement.

Ambient noise
40     From the evidence presented in the Environmental Statement there are no strategic
ambient noise concerns relating to this proposal. Croydon Council should require the
submission of suitable acoustic design details and can use its powers under the Control of
Pollution Act to control potential construction noise and vibration impacts.

Air quality
41      From the evidence contained within the Environmental Statement there would be some
operational impacts on air quality resulting from the development. However, these impacts do
not raise any significant strategic planning concerns that require the Mayor’s intervention.

42      However, for the construction phase, it is essential that best practice mitigation be in
place to avoid adverse PM10 impacts. It is recommend that the applicant consider further
monitoring of PM10 during construction to assess effectiveness of dust mitigation measures.
Given the location of the site, the applicant should also consider moving materials by rail, to
avoid impacts associated with road vehicles on the road network.

Health
43       London Plan Policy 3A.18 states “UDP policies should support the provision of additional
healthcare within the borough as identified by the strategic health authorities and primary care trusts.
The preferred locations for hospitals, primary healthcare centres, GP practices and dentists should be
identified in appropriate locations accessible by public transport and with particular reference to policies
3A.17, 3A.5 and 3D.1.”

44      The London Plan is clear that planning can contribute towards addressing such
disparities by ensuring the provision of primary care facilities as part of new residential and
commercial developments (including through Section 106 agreements), encouraging additional
provision in areas identified to be in need of additional primary care facilities and recognising
locations such as town centres as appropriate areas for healthcare facilities.

45       Croydon Primary Care Trust (PCT), working with the NHS London Healthy Urban
Development Unit, has expressed considerable concern that there is no capacity for the PCT to
adequately provide primary care for the projected population increase associated with the
commercial, residential and leisure activities proposed for this and other town centre schemes
and that the application does not adequately address identified need for additional primary care
facilities. The PCT advises that further discussions with the applicant, as a matter of urgency,
to address this important issue would be welcome.

Biodiversity

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46     The application site has not been identified as a Site of Importance for Nature
Conservation, and is not known to have significant biodiversity interest.

47      The site lies within an Area of Deficiency in accessible wildlife habitat, as defined in
Appendix 1 of the Biodiversity Strategy. Policy 3D.12 of the London Plan states “Priority for
habitat creation should be given to sites …. within or near to areas deficient in accessible wildlife sites”.
This site should therefore be seen as a priority site to obtain biodiversity enhancements
through landscaping and design, including features for wildlife on buildings, such as green
roofs. Green roofs are indeed included in the plans, although it is not clear whether these are
“brownfield” type green roofs, which could provide habitat for black redstarts and other
wildlife, or more formal roof gardens. The landscaping also includes significant green
elements, including trees. Overall, there may be small biodiversity gains from the
development.

Sustainable design and construction
48       The London Plan indicates that the Mayor expects future developments to meet the
highest standards of sustainable design and construction, including measures to: conserve
energy (see energy comments below); materials, water and other resources; to be bio-
climatically designed; ensure that developments are comfortable and secure for user; with the
provision of suitable waste and recycling storage facilities in all new developments; and, the
inclusion of energy efficient and renewable energy technology and design.

49      The London Plan also seeks to improve the sustainability and environmental
performance of London’s built environment by requiring a reduction in carbon dioxide
emissions through improvements in energy efficiency and securing renewable energy
technologies in development (Policies 4A.7-4A.9), in support of the Mayor’s Energy Strategy.
Under these policies, applicants should submit an energy demand and carbon dioxide emissions
assessment for the proposed development, investigate the feasibility of a range of energy
efficient and renewable energy technologies, incorporating those that are feasible, and
demonstrate the proportion of carbon dioxide emissions that have been offset by the
incorporation of energy efficient and renewable energy technologies. Applicants should also
select heating systems in line with the Mayor’s hierarchy in Policy 4A.8.

50     The proposed development takes account of the principles of the energy hierarchy as
recommended in the London Plan and the Mayor’s Energy Strategy. The large mixed-use
nature of the site allows for the efficient application of a centralised community heating scheme
with combined heat and power generation. This enables the future uptake of renewable
sources of energy, such as bio-energy CHP, boilers and solar heating. The building energy
consumption of the proposed development has been targeted to improve upon the proposed
Part L of the Building Regulations, which are due to come into force in 2005 and would amount
to 5% improvement on Part L 2005; and 32% better than Part L 2002.

51     The completed development would include a sustainable drainage system (SUDS) that
would as far as possible reinstate natural drainage processes on the site through infiltration and
attenuation techniques. Opportunities would be maximised to reduce the total volume of water
discharged from the site by allowing it to soak into the ground by way of permeable pavements,
swales, ponds and soakaways. This is consistent with strategic planning policy.

52      The office building design includes louvres attached to the facade to limit incident of
solar radiation. Energy savings are to be achieved by the implementation of a number of
technologies and design features including but not limited to:

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   High efficiency motors, fans, pumps and condensing boilers.
   High performance facade controlling heat gains and losses.
   Heat recovery on air and water systems.
   A building energy management system (BEMS) to provide enhanced energy use
    monitoring
    and to improve plant performance.
   Energy efficient lighting and controls.
   Combined heat and power with community heating.
   Variable volume systems to meet demand accurately, with variable speed fans and pumps.
   Low specific fan and pump powers.

53     The completed BREEAM ‘Design and Procurement Assessment Prediction Checklist’
undertaken for the proposed development rated the office buildings as achieving ‘Very Good’.
The completed EcoHomes prediction checklist rated the residential dwellings within the
proposed development as achieving ‘Very Good’.

Transport for London (TfL)
54       TfL has commented and worked extensively on the various development proposals for
this site and more detail of the issues can be found in the Stage 1 reports for the previous office
based application (18th June 2003) and the arena based application (19th Nov 2003).

55      In summary, this site is of key importance, being one of the few sites in outer London
with a PTAL approaching that of central locations. It is directly adjacent to East Croydon
station, which is the hub of an extensive network of national rail, bus and tram services that
serve much of south London. As such it is suitable for high density, high trip generating mixed
use development.

56       The roads surrounding the site are critical to the operation of public transport.
Dingwall Road and George Street are very busy bus and tram corridors with relatively little
traffic at the moment. Croydon town centre itself is prone to peak hour traffic congestion,
particularly on the nearby A232, a TfL road. Wellesley Road is proposed to be on the Strategic
Road Network.

57     East Croydon station is operating near capacity at peak hours due to a constrained
concourse and ticket gate line. It would benefit from an additional northern entrance or a
complete rebuild, though both of these options have significant operational and financial
implications.

58      The level of parking for the office is in accordance with the London Plan. It is however
questioned why 35 spaces are proposed for the leisure element in a location where it would be
expected that there would be little or no provision for this, bar disabled parking, and where
there is an adjacent public car park.

59     The amount of residential parking proposed, at around 80% provision of spaces
compared to units, is higher than could be achieved at such as high PTAL, town centre
location. The arena based scheme on the same site proposes a 50% provision with a car club
and thus it is questioned why this application, also with a car club, cannot achieve the same.

60     In the Inspectors report of 13 October 2003 following the inquiry into the previous
application, reduced parking provision for the residential element was supported. Indeed, the
Inspector suggested that should the Secretary of State be minded to approve the scheme, that

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the condition covering parking be amended to allow only 50% provision for the residential
element (page 83).

61      The TA states that 69 visitor parking spaces are provided as ‘inadequate provision would
mean visitors might not be able to park in a safe and secure manner or would seek to park in unsuitable
locations’. This statement is questioned as there are ample opportunities for legal parking
either in the adjacent multi-storey car park or on street. The development proposals
themselves will provide for a safer and more vibrant environment in the vicinity.

62     The level of cycle parking for the offices is low, as the target for mode share by bicycle
is 10%. The amount of parking should therefore better reflect the LCN standard, as advocated
by the London Plan, of 1 space per 125m2 floorspace.

63      The impact on the surrounding highway network is estimated in the TA to be relatively
low, partly because there is already a 450 space surface commuter car park on the site that will
be removed. The main site access is away from the Dingwall Road bus corridor and this will
reduce the direct impact of development traffic on this road. However, the applicant proposes
to signalise the Dingwall Road/Lansdowne Road junction, which may impact on buses. It is
therefore essential that the detailed design of this is developed with TfL and Croydon Council
to optimise the operation of the new junction and minimise delay to buses. This will likely
entail selective vehicle detection being incorporated to give priority to the eastbound
Lansdowne Road arm.

64      There is also concern over the predictions for the George Street/Wellesley Road
junction, which will be over capacity in the AM peak, and the George Street/Dingwall Road
junction, which the TA suggests will have an additional 13% traffic in the evening peak. The
scope for altering signal timings at these junctions is very limited due to the priority given to
Tramlink, which is a requirement of the Tramlink Act. There is little if any more green time
can be given to right turning traffic from Wellesley Road to George Street and from George
Street to Dingwall Road, both movements which cross the tram lines. If the proposed
Tramlink extension to Crystal Palace goes ahead it is possible that tram flows will increase,
reducing the available green time to traffic further. These junctions also have large bus and
pedestrian flows.

65     Additional traffic queuing on the approach to the Wellesley Road/George Street
junction could back up onto the dual carriageway, creating a potential accident risk as well as
the potential for increased congestion. The TA dismisses the impact in the AM peak at this
junction, but a 2% increase in traffic at an already over-saturated junction could have
implications for safety and congestion.

66      Managing traffic routes through signing would be difficult due to the nature of the
development. Thus, if the additional traffic causes delay to buses in George Street or results in
safety and congestion implications on Wellesley Road, TfL would seek the closure of Dingwall
Road at the George Street junction to general traffic. If the level of parking is reduced, the risk
of adverse traffic impact will be reduced further and may not require such a step and as such
the application would be more acceptable.

67     The applicant outlines proposals to increase capacity at East Croydon Station through
the s106 agreement, for example by moving existing retail units to the new development,
freeing up concourse space and providing extra ticket gates. A phased approach is also
advocated, which accords with Policy 3C.2 in the London Plan.



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68      Additional benefits to public transport, such as greatly improved waiting environment
for bus passengers on Dingwall Road is welcomed and expected with a large development such
as this. The applicant should work with London Buses and Croydon Council to determine the
optimum location and facilities for these stops and provide them through the s106 agreement.

London Development Agency (LDA)
69      The LDA has been closely involved in discussions on both schemes for this site. It
seeks a development that will realise the full potential of the site to contribute to the
rejuvenation of Croydon and to enable the town to enhance its part in London’s world, national
and regional roles. It is also important that any scheme is viable and deliverable such that the
site, one of the three key opportunities in the town and of significance strategically but which
has vacant and underused for so may years, will be developed out over the near future.

70       The Agency would expect the applicant to commit to local employment and training
initiatives and to addressing other barriers to work. In addition consideration should be given
to ensuring that local businesses can benefit from the opportunities that will arise both during
construction and subsequently. Given the significance of the site within the town centre the
applicant is also asked to identify means by which its development could support development
and improvements elsewhere in the town centre e.g. through contributions to wider area
planning and to management and marketing initiatives perhaps via a BID.

Access and equal opportunities
71      Policy 4B.5 of the London Plan expects all future development to meet the highest
standard of accessibility and inclusion. The applicant has commissioned an access consultant
to act as an adviser to ensure that access issues are properly considered and resolved. This
is a welcome concept that should ensure that inclusive design is a key consideration
throughout the detailed development stages.

72     The applicant has also submitted an access statement in support of the application
which explains the overall approach to design and the principles that have been applied to
ensure an inclusive environment and provides a ground floor plan showing how all users of the
development would move around the site and use the buildings contained therein. The overall
approach to inclusive design is supported by strategic planning policy.

73      It is not currently clear from the access statement how the development responds to the
requirements of Policy 3A.4 of the London Plan (all new housing should be to ‘Lifetime Homes’
standards and 10% to be wheelchair accessible or easily adaptable). This should be clarified
before the application is referred back to the Mayor for a decision.

Local planning authority’s position
74     Officers’ recommendation is unknown.

Legal considerations
75     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 Croydon
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

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intentions regarding a possible direction, and no such decision should be inferred from the
Mayor’s comments unless specifically stated.

Financial considerations
76     There are no financial considerations at this stage.

Conclusion
77      This is a key site in south London’s only Opportunity Area that could make a valuable
contribution to the Mayor’s objective for Croydon as a Metropolitan Centre, Opportunity Area
and as a strategic office centre, yet has remained largely vacant and under-used for thirty years.
This revised application has evolved into a high-quality scheme and has the potential to fulfil
all the objectives of the London Plan. There is also little doubt that it would deliver a striking
addition to the Croydon skyline setting new standards of design for the town centre. The
architecture and urban design is both coherent and convincing and a masterplan-led approach
has produced a rich and varied building composition. Contrary to the appealed scheme, the
detailed nature of the application allows a full and proper assessment of the impact of the
development and addresses ambiguities previously left unresolved. The proposed designs
exploit the site’s excellent public transport accessibility level, and despite a high-density, the
reconfiguration of the site has allowed for the incorporation of improved and generous public
spaces. It has also produced an urban redevelopment project of a standard that will rank in the
top quarter of comparable schemes in London, and subject to the detailed design issues raised
elsewhere in this report being addressed fully, meets the London Plan’s very high standards for
design. The applications demonstrate a commitment to the highest standards of sustainable
design and construction, also in line with the aspirations of the London Plan.

78       Notwithstanding the above benefits, the main strategic outstanding concerns relate to
the provision of affordable housing and the health impact of the development. It is not
currently clear from the information submitted why 50% affordable housing cannot be achieved
on this site. Assessing the appropriate level of affordable housing should involve undertaking a
full financial viability assessment of the proposal, which evaluates a range of variables, in
addition to the availability of public subsidy. It is also not currently clear what definition of
‘affordable housing’ the applicant has used, the probable tenure split or the unit size mix.
These should take account of London-wide housing requirements and the Mayor’s draft
supplementary guidance to accord with London Plan policy. The applicant should provide this
information in full before the application is referred back to the Mayor for a decision. The
applicant also needs to work with Croydon PCT to address the health impact of the
development and identified need for additional primary care facilities arising from the
development.

79        In view of the strategic importance of this site and its past history it is important that
its full potential to make a significant contribution to the regeneration and rejuvenation of
Croydon town centre and to contribute to London’s world city, national and regional roles are
at last realised. The applicant should further demonstrate that their scheme will successfully
achieve this outcome and that the public realm and community facilities proposed will be
delivered and secured through appropriately worded conditions or s.106 legal agreement.

80     Improvements to public transport facilities and interchange are welcomed. However,
the applicant needs to work with TfL to address the outstanding detailed transport issues,
particularly highway impact and car parking.


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81      There are also a number of other detailed strategic issues contained within this report
that need to be addressed so that the full potential of this site to make a significant contribution
to the regeneration of Croydon town centre can at last be realised.




for further information, contact Planning Decisions Unit:
Giles Dolphin, Head of Planning Decisions
020 7983 4271 email giles.dolphin@london.gov.uk
Colin Wilson, Planning Decisions Manager (Development Planning)
020 7983 4783 email colin.wilson@london.gov.uk
James Farrar, Case Officer
020 7983 6589 email james.farrar@london.gov.uk




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