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Ward: App No.: Address: Proposal:

Abbey 08/01729/FUL Former Kodak and Ventello site, Kenavon Drive Proposed redevelopment of site to provide for a mixed-use development comprising 333 no. residential units and 509sqm commercial floorspace, together with associated car parking, access, open space and landscaping.

RECOMMENDATION As per the main report with the following additional reasons for refusal: The Daylight Calculation Report-Rev B demonstrates that a first floor flat in block D1 and an upper ground floor flat in block A2 would not receive sufficient daylight, detrimentally impacting upon the amenity of the future occupants of these units. Additionally, the proposal fails to demonstrate that all other units would receive sufficient daylight and that there would not be a detrimental impact upon the amenity for occupants of other units. The proposal would therefore conflict with the requirements of policy HSG5 of the Reading Borough Local Plan.SG5H

The application fails to demonstrate that the commercial element of the development could achieve a BREEAM level of ‘Very Good’. The application therefore fails to meet the requirements of policy CS1 of the Core Strategy and adopted SPD Sustainable Design and Construction.

1. ADDITIONAL CONSULTATION RESPONSES RECEIVED Non-statutory consultation Building Control: A Sustainability Report has been submitted, which details two options for carbon reduction. Details of the two options as shown in the Sustainability Report are outlined below: ‘Option 1: 150kW biomass boiler. This option results in a carbon saving of 34.01% with 26.84 saved through renewables. Option 2: 75kW biomass boiler and 70kWe CHP. This option results in a higher carbon saving of 37.12% but does so using the CHP engine, therefore reducing the percentage saved through renewables to 12.38%.’

Building Control has confirmed that option 1 is satisfactory, however, option 2 is not satisfactory and would not achieve the target of a 20% carbon reduction as required by policy. The assessor has only stated his qualifications and written proof that he is a credited registered assessor is required.

Policy and Sustainability Manager: Residential development The developer provided a Sustainable Homes Code pre-assessment evaluation estimating that this development may achieve a total credit score of 65.53. There is concern that the pre-assessment has been calculated for the whole development without giving consideration to the diversity of dwellings on the site. In addition, the pre-estimator assessment is very general and does not provide any detail about how the development will achieve sustainability in the construction of the dwellings. If permission is granted, a condition regarding the submission and approval of a Design Stage Report and BRE Certificate for the development prior to development commencing is required. Additionally, a condition requiring the development will take place in accordance with the approved Design Stage Report and also that a Post Construction Review Report is submitted by a licensed assessor after completion of the buildings would be required. Non-Housing (Commercial) development The Sustainability Statement provided by the Developer is very general and does not provide sufficient detail. RBC Core Strategy expects commercial development of the scale proposed in this application to achieve the BREEAM ‘Very Good’ rating. A bespoke BREEAM assessment is available from BRE for core and shell developments. All parts of mixed use schemes should be assessed i.e. Sustainable Homes Code applied to residential uses and BREEAM guidance applied to all other uses. In particular on the energy side the Building Regulations Part L method also applies. Energy used for processes, appliances etc has not been included in the overall energy assessment. All main energy uses should be specified and can be enforced when the scheme is completed; Building Regulations will control future changes. For speculative ‘shell’ developments where most energy services are not provided, efficiency measures should focus on the building fabric and energy estimates will be based on industry best practice benchmarks reduced by a % in recognition of the improved Part L standard.

Valuation The Applicant has not appropriately demonstrated how all relevant costs will be dealt with in the Viability submission.

2. ADDITIONAL RESPONSES RECEIVED One additional response has been received from Thames Valley Police. previously submitted comments. Additional comments are outlined below:

They have

Designing out crime and disorder will not remove all such activity, and there remains a key role for the Police to play in both crime and disorder prevention, for example through neighbourhood policing, and reacting to incidents. Policing is a population based service. With an increase in Officers there will be a need to expand the infrastructure required to support them. The provision of infrastructure associated with delivery of the Police service satisfies the relevant tests in Circular 05/05: Planning Obligations on the basis that safer/ sustainable communities require the delivery of infrastructure in addition to incorporating Secured by Design measures. Whilst the application is being recommended for refusal, TVP would like to be involved in future discussions with the Council and the development given that the site’s redevelopment is likely to have a direct impact on the delivery of the Police service in this area. Officer comment: As per the main report, whilst the comments from TVP have been noted, in the absence of any reasonable and detailed justification to the contrary, it is considered that the proposal acceptably addresses crime and security issues through the design of the scheme and the contributions sought under the Heads of Terms outlined in the main report.

3. APPRAISAL Quality of living environment Overshadowing The document entitled, ‘Site layout planning for daylight and sunlight, A guide to good practice’ by P.J. Littlefair dated 1991 provides guidance on the average daylight factor that is acceptable in habitable rooms. There are recommendations for dwellings to achieve an average daylight factor of 2% for kitchens, 1.5% for living rooms and 1% for bedrooms. The document entitled, ‘Daylight Calculation Report-Rev B’ has been submitted by the Applicant. This report assesses two units only which are considered to be worst case scenarios. The two units are: 1) a first floor flat within Block D1 and 2) a flat on the upper ground floor of Block A2. The daylight factor calculation for the unit in the D1 block is 0.67% for the open-plan kitchen/ living room and 0.48% for the bedroom. The daylight factor calculation for the unit in the A2 block is 0.56% for the open-plan kitchen/ living room and 0.41% for the bedroom. It is therefore clear that neither of these rooms meet the relevant criteria required in the P.J. Littlefair document. Given the location of the units that have been selected, there is concern that other rooms may not receive appropriate levels of daylighting. The failure for these particular rooms to meet the relevant standards and the failure to demonstrate that all other rooms will receive appropriate levels of daylighting, therefore forms a recommended reason for refusal. To address the lack of appropriate levels of daylighting, three measures are proposed to overcome this issue: 1. reduce the depth of the balcony to 50cm (from 1.2m). 2. increase the size of the windows. 3. change the window frames to metal (from UPVC).

All of these measures have visual implications and reducing the depth of the balcony could also have amenity implications. No information has been submitted to confirm whether it is proposed to actually implement these measures and therefore it is not possible at this stage to assess whether they would be acceptable.

Housing mix and affordable housing Viability The applicant has not submitted a satisfactory viability assessment to support the amount of affordable housing and level of S106 contributions they are proposing.

Sustainability and energy efficiency Code for Sustainable homes Given the total Code for Sustainable credit score that is anticipated (65.53), how close this is to achieving a Code Level 4, commitment that 10% of the total units will achieve a Code Level 4 and comments from the Policy and Sustainability Team, on balance it is considered this approach would be acceptable. Sustainability statement for non-domestic accommodation The Sustainability Statement submitted by the Applicant does not demonstrate that the commercial element of the development could achieve a BREEAM ‘Very Good’ minimum standard. This aspect of the proposal therefore fails to comply with policy and forms a recommended reason for refusal. Carbon emissions The Sustainability Report which details the carbon emissions demonstrates that if option 1, of the 2 options outlined in the above report, were implemented, the 20% reduction in carbon emissions as required by policy would be achieved. Had the application been recommended for approval, it could therefore have been conditioned that the development would be required to comply with the details set out in option 1 of the above report. Waste The applicant has confirmed all the requirements of the Waste Management Team, as set out in the main report, could be addressed. This aspect of the proposal could therefore have been dealt with by condition had the application been recommended for approval. Other information A screening opinion has been carried out by the LPA. The LPA has adopted a screening opinion to the effect that an Environmental Statement is not required to accompany an application for this development. 4. SUMMARY: As per the main report, it is recommended that the application is refused.

Case Officer:

Julia Mountford

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