planning report D&P/3517/01 28 September 2015 Primary School Expansion, Junction, London in the planning application no. C2015/72418

Strategic planning application stage 1 referral Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008.

The proposal Erection of a new two storey primary school for 420 pupils for education and part community use incorporating soft and hard play area, car and cycle parking, pedestrian accessed and a vehicular access with raised table crossing onto London Road.

The applicant The applicant is the London Borough of Sutton. The agent and architect is Architype.

Strategic issues The proposed school development is supported in principle, in particular due to the need of school places in Hackbridge. However, the applicant is required to demonstrate very special circumstances, including an alternative site analysis report. Outstanding strategic issues with regards to urban design, inclusive design, climate change and transport should, nevertheless, be resolved before the application is referred back to the Mayor.

Recommendation That Sutton Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 57 of this report; but that the possible remedies set out in the same paragraph could address these deficiencies. The application does not need to be referred back to the Mayor if the Council resolves to refuse permission, but it must be referred back if the Council resolves to grant permission.

Context

1 On 20 August 2015 the Mayor of London received documents from Sutton 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 30 September 2015 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

page 1 information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Category 3D of the Schedule to the Order 2008:

Category 3D 1. Development which comprises or includes the alteration of an existing building where— (a) the development would increase the height of the building by more than 15 metres; and (b) the building would, on completion of the development, fall within a description set out in paragraph 1 of Category 1C.

3 Once Sutton 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 or allow the Council to determine it itself, unless otherwise advised. In this instance if the Council resolves to refuse permission it need not refer the application back to the Mayor.

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 The 1.7 hectare application site is located on land to the north of the BedZed housing project in Hackbridge. It is bounded to the west by London Road and to the east by the Victoria to Sutton railway line. A culvert surrounds the site to the north and west and also divides it from north to south.

4 The proposed site which is currently vacant/unused is situated in the south-west corner of part of a large area of Metropolitan Open Land (MOL) that is also part of the Wandle Valley Regional Park. The site is also recognised as a site of importance for nature conservation (SINC) with safeguarded minerals underneath part of it.

5 In terms of transport, the nearest section of the Road Network (TLRN) is the A232 Croydon Road approximately 2 kilometres to the south, whilst the nearest section of the Strategic Road Network (SRN) is the A236 Croydon Road, over 1.5 kilometres to the north. Hackbridge Railway Station lies approximately 650 metres to the south of the site, with and stop is approximately 960 metres to the north. Bus routes 127, 151 and S1 can all be accessed from the site, with the nearest located less than 100 metres to the west on London Road. Considering the above, the site generates a Public Transport Accessibility Level (PTAL) of 2 (on a scale of 1 to 6b where 6b is the most accessible).

Details of the proposal

6 The proposed development seeks to construct a two form entry primary school for 420 pupils aged 5-11 years old (with 50 staff) with a GIA of 2,446 sq.m. to form an expansion site for Hackbridge Primary School, Hackbridge Road, Wallington SM6 7AX.

7 The propose building is two storeys and comprises of classrooms, halls, offices, learning resources, storage and toilets, together with new grass pitches, habitat area and soft and hard play spaces. The proposals also include a new vehicle entrance/exit from London Road and car park for staff and deliveries only as well as improvements to pedestrian accessibility to the site.

8 The proposals also include potential for community use (out of hours) of some areas of the building and external areas, such as the proposed grass pitches and car park.

page 2 Case history

9 The planning application and site have no strategic planning history.

Strategic planning issues and relevant policies and guidance

10 The relevant issues and corresponding policies are as follows:

 Education London Plan: Social infrastructure SPG  MOL London Plan;  Playing fields London Plan;  Urban design London Plan; Housing SPG  Access London Plan; Accessible London SPG: Achieving an Inclusive Environment  Minerals London Plan;  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy  Transport London Plan; the Mayor’s Transport Strategy; Land for Transport Functions SPG

11 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 Sutton Core Panning Strategy DPD and Proposals Map (December 2009), the Sutton Site Development Policies DPD (March 2012), and the 2015 London Plan (Consolidated with alterations since 2011).

12 The National Planning Policy Framework and Planning Practice Guidance to the National Planning Policy Framework, the London Plan Parking Standards Minor Alterations to the London Plan Consultation Draft (April 2015), the Mayor’s Social Infrastructure SPG, and the draft Hackbridge SPD (2009) are also relevant material considerations.

Principle of development - Education facility on Metropolitan Open Land

13 London Plan Policy 3.18 supports developments which enhance education and skills provision, including new build, expansion of existing or change of use to educational purposes. It also supports the multiple use of education facilities for community use. Whereas, London Plan Policy 7.17 accords protection to London’s Metropolitan Open Land (MOL) and resists inappropriate development, except in very special circumstances.

14 As mentioned in paragraph 4 above, the application site is on Metropolitan Open Land as designated in the Council’s Site Development Policies DPD (reference BW14) with Area A allocated for education/community use and Area B for playing fields/regional park. The proposals are located on Area B. Policy DM15 of the Council’s Site Development Policies DPD protects MOL and encourages its retention. At the national level, the National Planning Policy Framework (NPPF) accords the same protection to MOL as land within Green Belt land and regards the construction of new buildings in MOL as inappropriate, except for the construction of some buildings as set out in paragraph 89, unless very special circumstances that outweigh the harm to the MOL are demonstrated and provided the openness of the MOL is preserved.

15 In the present case, of the 16,745 sq.m. site area that is on Metropolitan Open Land, it is proposed that 13,435 sq.m. is used for the new two form entry school and 3,310 sq.m. for grass pitches. As per the NPPF definition of inappropriate development, the proposed grass pitches that form part of the proposals can be considered as an exception to inappropriate

page 3 development on MOL as appropriate facilities for outdoor sport and recreation. However, the remaining areas, where the new two form entry primary school will lie, are classified as ‘inappropriate development’ and are therefore harmful to the MOL and should not be approved, except in very special circumstances, in accordance with the NPPF.

16 The applicant accepts that the development of the new school on the site is inappropriate, and to respond to this, has presented some ‘very special circumstances’ (VSC) to justify the proposals. The applicant argues that the principle planning consideration for the application and the most critical is the fact that the ability to provide primary school places in the borough depends upon development in the MOL. The VSCs given by the applicant can be summarised as follows:

 Demand for additional school places: With the London’s school places crisis, the proposals address the current and projected shortage of primary school places in Hackbridge. A number of other schools have already expanded to meet the demand but there is still insufficient capacity. The applicant has included evidence provided by the Council which shows that at local, neighbourhood and borough levels there is little capacity in the area at present. The evidence provided takes account of the advice given to the applicant by GLA officers at pre-application stage.

 The lack of alternative suitable sites outside of the MOL: The Council has undertaken a site search and evaluation, which concludes that the proposed site is the most suitable, available and achievable to provide some of the required school places in the borough. However, no alternative site analysis has been provided. The applicant is required to provide a report on this before the application is referred back to the Mayor at stage two. The applicant should refer to the advice provided by GLA officers at pre-application stage on the sequential methodology.

 Enabling access to the MOL: the current site has no official access to the MOL for the public. The proposals for the new school open up an area of the MOL to the public (which to date has been inaccessible) through the provision of a number of new pedestrian access points. The applicant argues that this provides an improvement to the MOL and allows people to access it and benefit from it.

 Multi-functional use of building and grass pitches: The proposals will maximise the multifunctional use of the school for community and recreational use. Some areas of the school and the grass football pitches will be available for hire by the local community out of school hours.

 The school will seek to become an exemplar sustainable school, alongside the BedZed zero energy housing development next to the site.

17 As advised at pre-application stage, given the London’s school places crisis, London Plan Policy 3.18 strongly supports development proposals which address the current and projected shortage of primary school places. The principle of providing a school in an area of need in Hackbridge would therefore be supported in principle in strategic terms. However, as the proposed development lie on Metropolitan Open Land and as London Plan Policy 7.17 gives a strong protection to London’s MOL, very special circumstances should be demonstrated to justify the proposed school development on Metropolitan Open Land. At this stage and as stated above, this has not yet been demonstrated and further information is required.

18 The impact of the proposed development on the openness of the MOL is dealt with in the urban design section of this report.

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Community use

19 London Plan Policy 3.18E encourages development proposals for schools to maximise the multiple use of educational facilities for community or recreational use. As mentioned above, it is the applicant’s intention to provide out-of-hours community hire in part of the school. A community use plan has also been submitted showing how the school has been designed to make it possible. This is welcomed and should be secured by the Council.

Minerals

20 The matter of minerals was discussed at pre-application stage as there are mineral reserves under Area B. The Mayor no longer considers that Sutton Council is an authority with significant mineral reserves and accordingly the Council no longer has a minerals apportionment figure in the London Plan. There are no strategic mineral issues and the existence of mineral reserves under Area B does not raise any strategic issues in terms of developing the site for a school.

Urban design

21 Good design is central to all objectives of the London Plan. The principle strategic concern is the need to safeguard the openness of the MOL, in accordance with London Plan Policy 7.17.

22 As advised at pre-application stage, the applicant has included a diagrammatic study to demonstrate how the most appropriate location and layout configuration of the school building has been reached to mitigate the impact of the development on the openness of the MOL. The applicant has also provided key views of the building in context from the point of view of the approach to the site from London Road, from the main expanse of MOL to the north and from the BedZED residential development to the south, as requested at pre-application stage.

23 The positioning of the building towards the south west corner of the MOL helps to optimise open views from London Road, and reads as an addition to the established grouping of buildings along the eastern edge of London Road. It is also recognised that there is a significant level of screening along the western edge of the site which currently limits views across the MOL to the east. However, the Council should secure details of perimeter fencing to the east and north to make sure there is no impact on the openness of the MOL, while maintaining security for the school.

24 The new pedestrian accesses to the MOL that the applicant proposes to introduce are welcomed. However, clarity on the pedestrian linkage into the BedZed development should be provided.

25 The proposed layout is broadly supported with a well-defined street facing frontage and main entrance area. Teaching spaces are positioned away from London Road to mitigate noise impacts from London Road, which is welcomed. The applicant has referred to BB103 design guidance to develop the accommodation schedule, which is welcomed. In line with BB103, the simple L-shaped layout provides a good level of enclosure to the KS1 play area that is close to the classrooms and some passive surveillance.

26 The form and massing strategy is broadly supported. The submitted drawings put forward a simple and refined building form, with high quality timber facing materials and

page 5 planting integrated with the architecture (including green roofs) designed to meet Passivhaus standards which is welcomed. The introduction of trees is also welcomed.

Inclusive design

27 The aim of London Plan Policy 7.2 is to ensure that proposals achieve the highest standards of accessibility and inclusion. Inclusive design principles if embedded into the development and design process from the outset help to ensure that people, including children and young people, mothers with pushchairs, disabled and Deaf people, older people can use the places and spaces proposed comfortably, safely and with dignity.

28 The applicant has indicated that the building would be designed to comply with Part M of the current building regulations, however, there are concerns that the design guidance found in this document may not, in places represent the ‘highest standard’ of accessible and inclusive design, and is seen as more of a minimum standard. The BS 8300:2001 guidance that the applicant used has also been replaced. The applicant should therefore demonstrate that all aspects of the development will meet the latest best design guidance on specific areas, which may come in the form of the British Standard BS8300:2009 + A1:2010, as referenced in the London Plan.

29 The design and access statement should show how disabled people access each of the entrances safely, including details of levels, gradients, widths and surface materials of the routes/paths.

Climate change adaptation

30 The applicant is seeking to achieve an exemplar sustainable school building and it is proposed that the school will be zero carbon and Passivhaus Certified. This is strongly supported.

31 The site is mainly within flood zone 1 with a small area in flood zone 2, and has no significant surface water flood risk. The principal of the proposals is acceptable in terms of London Plan Policy 5.12. The flood risk assessments state that the proposals will achieve a greenfield run-off rate up to the 1 in 100 year + climate change (CC) storm. The details of the drainage system are yet to be worked out and the following techniques have been suggested: Infiltration/soakaways, permeable pavements, swales, ditches and a retention pond.

32 Given the nature and location of the proposals this approach is considered to comply with the sustainable drainage hierarchy contained within London Plan Policy 5.13.

Climate change mitigation - energy

Energy efficiency standards

33 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 low energy lighting with controls and mechanical ventilation with heat recovery. In addition, the applicant has stated that the project aspiration is to achieve the Passivhaus standard, this is fully supported.

34 The demand for cooling will be minimised through external shading (brise-soleil and vertical fins), blinds and mixed mode ventilation. The applicant has undertaken dynamic thermal

page 6 modelling using Building Bulletin 101 and CIBSE TM52 methodologies and produced a separate overheating report. The report shows that that the criteria will be met for the large part of the school including the teaching spaces, however overall the proposed measures were found not to satisfy either the BB 101 or CIBSE TM52 overheating requirements. The report presents recommended measures that could be incorporated to meet the criteria such as lower g-values and increased air flow rates. However, it is not clear whether these measures will be incorporated into the design. The applicant should commit to including the recommended measures.

District heating

35 The applicant has carried out an investigation and there are no existing or planned district heating networks within the vicinity of the proposed development. The applicant has identified that the development is situated within a district heating opportunity area. The applicant should therefore commit to ensuring that the development is designed to connect to district heating in the future.

36 The applicant is proposing to install a site heat network. Further information on the energy centre should be provided, including floor area and location.

Combined Heat and Power

37 The applicant has investigated the feasibility of CHP. However, due the intermittent nature of the heat load, CHP is not proposed. This is accepted in this instance.

Renewable energy technologies

38 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install Ground Source Heat Pumps (GSHP) to provide space heating. The applicant should provide further information on the proposed system, including size in kW of the heat pumps, GSHP type i.e. closed or open loop and explain how the system will be compatible with connection to a future network. The applicant should review Appendix 3 in the GLA guidance and provide the information required for GSHP. https://www.london.gov.uk/sites/default/files/GLA%20guidance%20on%20preparing%20ene rgy%20assessments%20April%202015.pdf

39 The applicant is also proposing to install 900m2 roof mounted Photovoltaic Panels (PV). The applicant should provide an indicative roof layout demonstrating that there is sufficient capacity for the proposed system.

Summary

40 A reduction of 32.1 tonnes of CO2 per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected, equivalent to an overall saving of 100%. The carbon dioxide savings significantly exceed the target set within Policy 5.2 of the London Plan, this is welcomed. In addition, the applicant also states that the proposed strategy will also ensure that the development is net zero carbon i.e. including unregulated emissions, this is fully supported.

page 7 Transport

Site access

41 The main pedestrian, cyclist and vehicular access to the school will be from London Road. A controlled secondary access located north of Seymour Road would be for deliveries, servicing and staff parking and in special circumstances the drop off and pick up of pupils.

Car parking

42 It is noted that there would be only facilities for coach, mini bus and disabled drop off and pick up on site. It is understood that 20 car parking spaces including one Blue Badge space, will be provided for staff and community uses outside of school hours, within Phase 1. This equates to 0.8 spaces per member of staff. An area has also been set aside to increase provision to 40 spaces once phase 2 of the school has been built out. To encourage sustainable travel, TfL suggests the car parking provision is reduced for phase 1. The usage of these spaces should be monitored as part of the travel plan, and parking Phase 2 should only be provided if it can be demonstrated that there is a requirement.

43 Notwithstanding this, the provision of electric vehicle charging points is welcomed and in line with the London Plan. This and the disabled parking should be secured by condition. In addition, a parking and on site vehicles management condition should be considered.

44 Given the absence of on site drop off and pick up facilities and parking for parents/carers and to support sustainable travel by staff, consideration should be given to on street parking controls.

Cycle

45 The current proposals for cycle parking provision are in line with the London Plan. Consideration should be given to the provision of scooter parking for pupils. The school travel plan should also include measures to increase cycle usage, and could incorporate cycle safety sessions. The applicant should also consider cycle parking for the intended out of school hours community uses. TfL would expect sufficient spaces to be provided to meet London Plan standards within both Phases 1 and 2. Therefore, the plans should be updated to reflect this and clarify the location and style of the parking spaces.

46 The applicant has confirmed cycle parking will be located in a covered, lit and secure area. Shower lockers and changing facilities should also be provided for staff to accord with London Plan policy.

Public transport

47 The multi-modal trip generation surveys which have been carried out are welcomed. However, there are concerns about the potential impact on the public transport network along London Road. Contributions towards additional bus capacity may be required to mitigate this impact together with a robust school management plan to spread arrivals and departures from the school.

Pedestrian environment

48 The Pedestrian Environment Review Survey (PERS) which has been undertaken is welcomed. Any identified improvements, such as walking routes to Hackbridge Station and

page 8 footway conditions around the site, should be agreed with the Council and secured through the section 106 agreement.

Travel planning

49 The school has an existing travel plan, which should be updated to reflect the proposed expansion. The final version of the travel plan, including all agreed measures therein, should be secured, enforced, monitored and reviewed as part of the section 106 agreement.

50 The submission of a framework delivery and servicing plan (DSP) is welcomed, and the applicant’s commitment to submitting a construction management plan (CMP). The DSP along with a CMP which should include logistics and specific consideration of cycle safety and on site conflicts management should be secured by condition.

Community Infrastructure Levy (CIL)

51 It is understood the development will only be used for educational use and therefore it should be noted that the Mayor’s Community Infrastructure Levy (CIL) will not apply, as defined in the Education Acts.

Summary

52 In summary, the applicant should clarify the car parking spaces for each phase, the travel plan should be updated to reflect the application and secured through the legal agreement, with a DSP and CLP secured by condition for the proposals to comply with the transport policies of the London Plan.

Local planning authority’s position

53 The application was discussed with the Council at a GLA pre-application meeting on 20 November 2014. However, at this stage, the position of the Council’s planning officers is unknown. Legal considerations

54 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.

55 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

56 There are no financial considerations at this stage.

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Conclusion

57 London Plan policies on the principle of development on MOL, urban design and inclusive design, climate change and transport are relevant to this application. The application does not yet comply with London Plan policy and further information should be provided to make the application compliant:  Principle of development: The principle of a school expansion to meet the shortage of school places in Hackbridge is supported in strategic terms. However, the alternative site analysis report should be provided to justify the proposed school development on MOL, prior to the case being referred back to the Mayor at stage 2.

 Urban design: Details of perimeter fencing to the east and north of the site should be secured by the Council to ensure there is no impact on the openness of the MOL. The layout approach to the site and form and massing strategy is supported in strategic terms as it will, subject to fencing details, have a minimal impact on the openness of the MOL. Clarity on the pedestrian linkage into the BedZed development should be provided.

 Inclusive design: The development should be designed in accordance with the highest standards of accessible and inclusive design and the latest design guidance.

 Climate change mitigation - energy: Further information should be provided on overheating, the proposed energy centre and the proposed GSHPs. It should also commit to ensuring the development is designed to connect to district heating in the future.

 Climate change adaption: the proposed approach is supported.

 Transport: the applicant should clarify the car parking spaces for each phase, the travel plan should be updated to reflect the application and secured through the legal agreement, with a DSP and CLP secured by condition for the proposals to comply with the transport policies of the London Plan.

For further information, contact GLA Planning Unit (Development & Projects Team): Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Hermine Sanson, Senior Strategic Planner 020 7983 4290 email [email protected]

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