planning report GLA/4559 & 4559a/01 21 January 2019 Recorder House and One Station Road in the London Borough of Redbridge

planning application no. 4570/18 and 4557/18

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 Recorder House: Erection of 6 – 15 storey building, comprising 144 residential units and flexible commercial floorspace at ground floor. One Station Road: Demolition of existing building and redevelopment to provide 42 storey building, comprising 380 residential units, with retail and office floorspace at ground floor.

The applicant The applicant is Access Self Storage and the architect is Collado Collins Architect. Strategic issues summary Principle of development: Both sites benefit from good accessibility and are both locally allocated for residential-led, mixed use development, whilst One Station Road also lies within the Town Centre. As such, the principle of residential-led redevelopment on both sites is supported; however, given each sites’ allocation and designations, the balance of commercial uses on each site should be considered further and additional justification is required for the loss of over 6,000 sq.m of commercial floorspace at One Station Road and the limited commercial provision at the Recorder House. Affordable housing: It is proposed that Recorder House, which will be 100% affordable, will provide the offsite affordable housing contribution for the entirely market Build to Rent scheme at One Station Road. When the sites are considered together, the affordable housing offer would be 33% by habitable room. The provision of offsite affordable housing is only acceptable in exceptional circumstances; as such, GLA officers will robustly assess the Financial Viability Assessments for each site to ascertain whether each scheme should provide affordable housing on site and, in turn, whether the viability provides exceptional circumstances for an offsite provision. Further information is also required on the London Shared Ownership units and London Affordable Rented units.

Design: Further justification and work is required to reduce the perceived bulk of One Station Square, particularly when viewed from the north and south, and to ensure sufficient activity and good residential quality. For Recorder House, further work is also required to ensure good levels of activation and passive surveillance at ground floor.

Further information is required on energy and transport.

Recommendation That Redbridge Council be advised that the application does not comply with the London Plan and draft London Plan, for the reasons set out in paragraph 91. However, the resolution of those issues could lead to the application becoming compliant with the London Plan and draft London Plan.

page 1 Context

1 On 19 November 2018 the Mayor of London received documents from Redbridge Council notifying him of two distinct planning applications (albeit linked) of potential strategic importance to develop the above sites for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor must provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 Recorder House (GLA ref: 4559 and LPA ref: 4570/18) is referable under Categories 1A and 1C of the Schedule to the Order 2008:

• Category 1A: Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.

• Category 1C: Development which comprises or includes the erection of a building of one or more of the following descriptions - the building is more than 30 metres high and is outside the City of London.

3 One Station Road (GLA ref: 4559a and LPA ref: 4557/18) is referable under Categories 1A and 1C of the Schedule to the Order 2008:

• Category 1A: Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.

• Category 1C: Development which comprises or includes the erection of a building of one or more of the following descriptions - the building is more than 30 metres high and is outside the City of London.

4 Once Redbridge Council has resolved to determine the applications, it is required to refer both back to the Mayor for his decision on each application as to whether to direct refusal, take over for his own determination, or allow the Council to determine it itself.

5 The environmental information for the purposes of the applicable Town and Country Planning (Environmental Impact Assessment) Regulations has been taken into account in the consideration of the One Station Road scheme.

6 The Mayor of London’s statement on these cases will be made available on the GLA website www.london.gov.uk. Site description

Recorder House

7 The 0.27-hectare site is located on the north side of High Road and is bound to the north by TfL railway lines, which run between Liverpool Street and Shenfield, to the south by High Road and Ilford Cemetery beyond. Whilst the land to the immediate east of the site is presently in commercial use, a planning application is presently pending for a 9-storey residential building, comprising 94 residential units (LPA ref: 3598/18). On the land to the immediate west of the site there is an extant planning permission also for a 9-sotrey building, containing 105 residential units and a banqueting suite on the lower floors (LPA ref: 2483/10); this permission has been implemented. The surrounding land

page 2 uses are varied, with commercial uses fronting High Road and two-storey Edwardian residential terraces on the streets to the south.

8 At a local level, the site has a number of policy designations: within the Corridor Investment and Growth Area; a key retail parade; and within a tall buildings area. In addition, the site is allocated as a ‘mixed use opportunity site’ within the Local Plan, for 180 residential units and 1,300 sq.m of employment floorspace. At a strategic level, the site lies within the Ilford Opportunity Area, which has an indicative employment capacity of 800 jobs and 5,000 homes.

9 The site has a PTAL of 3, which indicates a moderate level of access to public transport, however it is well connected with several bus stops within easy walking distance as well as station within a 600 metre step-free walk.

One Station Road

10 The site is 0.27 hectares in size and lies opposite Ilford railway station, within Ilford Town Centre. The site is bound by Cranbrook Road to the west, which is a busy retail street, the TfL Rail tracks to the north and Station Road to the south. The surrounding land uses are varied and reflect the Town Centre location, with commercial uses on the adjacent sites and major roads, with residential uses beyond.

11 The site comprises numerous parts: the former Bodger’s Department Store, which fronts Station Road and Cranbrook Road, which was vacated in February 2018; retail units, with offices above, which are presently occupied by various chain retailers, including Costa Coffee; and a pedestrian link from Station Road to High Road, which is known as ‘Bodger’s Arcade’, but has been closed since the cessation of the department store use.

12 The site has a number of local planning policy designations, including: primary shopping frontages along Cranbrook Road; within the Ilford Metropolitan Centre; within an area appropriate for tall buildings; and an archaeological priority area. In addition, like Recorder House, the site is locally allocated as a ‘mixed use opportunity site’ for 295 residential units and 2,500 sq.m of retail floorspace. The site is also within the Ilford Opportunity Area.

13 The site records an excellent Public Transport Access Level (PTAL) of 6b on a scale of 1-6, where 6 is the highest. Ilford station with TfL Rail and Elizabeth Line (Crossrail) services in the future is adjacent to the site. There are several bus stops within walking distance serving 21 routes. The A118 is 300 metres away to the south of the site and is the closest part of the Strategic Road Network. The A406, , approximately 400 metres to the west of the site is the nearest part of the Road Network (TLRN). Quietway 6 runs approximately 1.2 kilometres north of the site.

Details of the proposal

14 Two distinct, standalone planning application have been submitted by the applicant; however, the applicant proposes that Recorder House will serve as the affordable housing contribution for the One Station Road site. The applicant proposes to link the sites through a s106 legal agreement.

15 Recorder House: It is proposed to develop a part 6, part 10, part 15 storey building, comprising 144 residential units, all of which would be affordable, as well as flexible commercial floorspace at ground floor level (Use Classes: A1-A3, B1 and D2).

16 One Station Road: It is proposed to demolish the existing buildings on the site and redevelop the site to provide 42 storey building, comprising 380 residential units, all of which would be let as Build to Rent units, with retail (Use Class A1) and office floorspace (Use Class B1) at ground floor.

page 3 Table 1 – Existing and Proposed land uses for both schemes

Recorder House One Station Road

Existing Proposed +/- Existing Proposed +/- sq.m sq.m sq.m sq.m

Residential - 14,287 +14,287 - 32,701 +32,701

Retail - 247 +247 6,740 659 -

Office - - - 327 1,997 +

Total - 14,534 +14,534 7,067 2,656 -4,411

Case history

17 An initial pre-application meeting was held on 23 February 2018 to discuss both development proposals with GLA officers. Following a presentation of the scheme from the applicant team, the discussion covered strategic issues with respect to the principle of development, housing, urban design and transport. Strategic planning issues and relevant policies and guidance

18 The relevant issues and corresponding policies are as follows:

• Mix of uses London Plan; • Town Centre uses London Plan; • Housing London Plan; London Housing Strategy; • Offices London Plan; • Urban design London Plan; Shaping Neighbourhoods: Character and Context SPG; Housing SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG; • Inclusive design London Plan; Accessible London: achieving an inclusive environment SPG; • Sustainable development London Plan; London Environment Strategy; • Transport London Plan; the Mayor’s Transport Strategy.

19 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area comprises Redbridge Local Plan (2018) and the 2016 London Plan (Consolidated with Alterations since 2011).

20 The following are also material considerations:

• The National Planning Policy Framework (2018) and National Planning Practice Guidance; • Draft London Plan (2017), incorporating the changes set out in the Minor Suggested Changes (published August 2018), which should be taken into account on the basis explained in the NPPF; and • In August 2017, the Mayor published his Affordable Housing and Viability Supplementary Planning Guidance. This must now be read subject to the decision in R(McCarthy & Stone) v. Mayor of London.

page 4

Principle of development

Recorder House

21 The principle of residential-led redevelopment on the allocated site, with good transport accessibility, is supported; however, as set out in paragraphs 23 and 32 below, the applicant should seek to increase and enhance the commercial and/or employment uses on the site, in line with the Council’s allocation for the site.

One Station Road

22 The principle of the residential-led intensification of a locally allocated, Town Centre site, which is opposite a railway station, is supported, subject to addressing the issues raised within this report with respect to the Build to Rent product and the loss of retail floorspace proposed as well as the proposed offsite affordable housing offer. Commercial uses

Policy context

23 Both London Plan Policy 2.15 and draft London Plan Policy SD6 recognise that town centres should be the foci for commercial development beyond the CAZ. Draft Policy SD6 states that potential for new housing should be realised where possible in town centres through higher density mixed use development.

24 London Plan Policy 4.7 and draft London Plan Policy SD7 require the scale of retail uses to be related to the size, role and function of the specific town centre, whilst also supporting a proactive approach to improving the quality of retail floorspace. Further, draft London Plan Policy E9 seeks to manage clusters of retail uses, having regard to numerous factors, including their place- making capacity or local identity, and draft Policy SD8 seeks a range of sizes of commercial units to support the diversity of the town centre

25 Draft London Plan Policy SD6 states that town centres should also be strengthened to remain the primary location for commercial activity beyond the CAZ as well as a focus for place and local identity. Paragraph 2.6.1B goes on to states that the function and character of high streets should be promoted and enhanced.

26 With regard to specific office policy, London Plan Policy 4.2 and draft London Plan Policy E1 seek to support the strengths of London’s office market, focusing new development in town centres. Over the 2016 – 2041 plan period, demand for office floorspace in outer London is expected to rise by 23%, with an increasing proportion required for micro, small and medium-sized enterprises (SMEs). The draft London Plan also introduces distinct policies on low-cost business space, as set out in Policy E2, which is considered to be of a lower specification than prime office floorspace, and on affordable workspace, as set out in Policy E3, which is let at sub-market levels.

Assessment: Recorder House

27 As discussed above, whilst the site is currently cleared and vacant, it is designated as part of a key retail parade and is allocated for residential-led redevelopment with 1,300 sq.m of compatible employment floorspace, which should activate High Road. The proposed development would provide 247 sq.m of retail floorspace on the northern part of the proposed ground floor.

page 5 28 The provision of commercial uses on the ground floor is supported, as they will ensure activity along High Road as well as contributing to the vitality of the key retail parade; however, in the context of the site’s former office use, the site’s location within a key retail parade and its local allocation, the applicant must seek to enhance the quantum of commercial and/or employment uses on the site.

Assessment: One Station Road

29 The site lies within the Ilford Metropolitan Town Centre, which is the highest order town centre after the Central Activities Zone. It is, therefore, appropriate for residential-led intensification, as set out in draft London Plan Policy SD6. Town centres, however, in addition to being appropriate for residential-led development, are also the primary locations for commercial activity in the capital. Draft London Plan Policy SD8 states that Metropolitan centres, along with International and Major Town Centres, should be the focus for the majority of higher order comparison goods retailing.

30 It is proposed to provide 657 sq.m of retail floorspace at ground floor in four retail units, which is a loss of 6,081 sq.m of commercial floorspace, when compared to the existing scheme. The loss of floorspace must be considered in the context of the London Plan and draft London Plan town centre policies, discussed above, as well as the Council’s allocation for the site, which seeks at least 2,500 sq.m of retail floorspace on the site. Whilst it is acknowledged that the proposals would retain active frontages along the roads, which are locally designated as Primary Shopping frontages and provide office floorspace on first and second floors, it is not considered that the applicant has sufficiently justified the loss in retail floorspace, particularly because several of the retail units are presently occupied.

31 In this regard, and in order to enhance the function of Ilford Town Centre and to ensure that it remains a focus for commercial activity, the applicant must explore opportunities to enhance the retail provision on the site. Furthermore, the applicant must provide commentary on any discussions that they have had with the existing retail tenants about relocation.

32 Notwithstanding the above, the provision of office floorspace on the site, as part of a mixed- use residential-led redevelopment, aligns with the aims of the town centre policies and is supported in principle. Furthermore, and more specifically, the annex to the draft London Plan provides specific guidance on Ilford Metropolitan Centre, stating that it could viably support offices as part of a mixed-use development. Once the final commercial mix of the building has been determined, the applicant should confirm the rental levels of the office floorspace, including its specification and whether they have discussed tenancies with any existing or future occupiers. Housing

Policy context

33 London Plan Policy 3.3 and draft London Plan Policy H1 seek to increase the supply of housing in the capital. Taken together, the proposed schemes would provide 524 homes, which equates to 26% of the annual monitoring target for Redbridge of 1,979 set out in the draft London Plan. The increase in the housing targets identified in the draft London Plan evidences the continued need for housing in the borough.

34 The draft London Plan introduces a specific policy on Build to Rent (BTR) schemes and states that boroughs should take a positive approach to the BTR sector, noting the positive contribution that such schemes can make to increasing housing supply in the capital, as well as contributing to Redbridge’s annual housing target.

page 6 35 Policy H13 of the draft London Plan sets out the criteria that schemes must achieve in order to be considered BTR, including: be comprised of over 50 units; held in a covenant for at least 15 years; be subject to a clawback mechanism to ensure that there is no financial incentive to break the covenant; under a unified management; and tenancies of three or more years must be made available.

Assessment

Recorder House

36 The principle of affordable residential uses on the allocated site, with good transport accessibility, is supported. In isolation, the proposed scheme would provide 100% affordable homes and this is supported; however, given the proposal to link the two schemes together, with Recorder House providing the ‘offsite’ affordable housing provision for One Station Road, further justification is required on the overall approach to affordable housing delivery. A detailed discussion is provided in the affordable housing section below in paragraphs 38 to 48.

One Station Road

37 Whilst the principle of residential uses on the site is supported, given its highly accessibly Town Centre location, the applicant has not provided any details of the BTR offer, as required by draft London Plan Policy H13, and as such it is not possible to fully assess the scheme’s acceptability as Built to Rent. The applicant should provide full commentary on how the scheme complies with draft London Plan Policy H13. In accordance with draft London Plan Policy H13, the BTR units must be held in a covenant for at least 15 years; this must be secured within the S106. A clawback mechanism must also be included within the S106. Affordable housing

Policy context

38 London Plan Policies 3.11 and 3.12 and draft London Plan Policy H5 and Policy H6 seek to maximise the delivery of affordable housing, setting a strategic target of 50% across London. The Mayor’s Affordable Housing and Viability Supplementary Planning Guidance seeks to increase the provision of affordable housing in London and embed affordable housing into land prices. The SPG introduced a threshold approach to viability, which is now incorporated within draft London Plan Policy H6; schemes that provide 35% affordable housing on site, without public subsidy, and meet the specified tenure mix are not required to submit viability information nor be subject to a late stage review. Where schemes propose an off-site affordable housing contribution, a Financial Viability Assessment must be provided, as set out in paragraph 4.6.14. At a local level, Redbridge Council’s Local Plan sets a borough-wide strategic target of 35% affordable housing.

39 With regard to BTR housing specifically, draft London Plan Policy H13 and the Mayor’s Affordable Housing and Viability SPG states that BTR schemes can provide an entirely Discount Market Rent affordable offer, where the rents proposed are at a genuinely affordable level.

Assessment of proposals: offsite affordable housing contribution

40 As set out above, it is proposed that Recorder House will provide the off-site affordable housing contribution for One Station Road. Recorder House will provide 144 residential units, whilst Station Road is proposed to provide 380 residential units, all of which would be market BTR; as such, when considered together, the affordable housing offer would be 27.5% by unit or 33.9% by hab. rooms.

page 7 41 The Mayor is clear that affordable housing should be provided on-site, with an offsite affordable housing contribution only acceptable in exceptional circumstances, as set out in the Mayor’s Affordable Housing & Viability SPG and draft London Plan Policy H5. Schemes which propose offsite affordable housing cannot qualify for the Fast Track route and must provide a Financial Viability Appraisal (FVA).

42 The primary ‘exceptional circumstances’ justification for the offsite provision is the schemes’ viability: the applicant states that One Station Road could not viably provide any affordable on site and, therefore, that the split site proposal enables a higher affordable housing offer. It is noted that the applicant’s Financial Viability Assessment is based on a counterfactual appraisal, where a policy- compliant on site affordable housing offer is assessed against the proposed development. GLA offers will robustly interrogate the viability appraisal to assess whether the purported benefits of the proposed offsite affordable housing can be considered ‘exceptional circumstances’ as well as to assess whether each site could support affordable housing independently.

43 Of the 144 units within Recorder House, 49% would be London Affordable Rent and 51% would be Shared Ownership. London Affordable Rent (LAR) is the Mayor’s preferred affordable rental product, with weekly benchmark rental values (exclusive of service charge) are set annually by the GLA. For the 2019/2020 period, the weekly rents are as follows: 1-bedroom flats, £155.13; 2- bedroom flat, £164.24; and 3-bedroom flats, £173.37.

44 No detail on the affordability of the shared ownership units has been provided and the applicant must provide these, noting the Mayor’s expectation that these should be available to households on a range of incomes below the £90,000 threshold. The LAR units and their rental levels as well as the income thresholds for the Shared Ownership units must be secured in any s106 agreement.

45 Notwithstanding the viability argument above, it is noted that the applicant also argues that the offsite solution enables a more diverse affordable housing offer than could be supported within One Station Road itself, where it is stated that the inability to insert an additional core would require any affordable on site to be DMR. As part of the review of the FVA, the applicant should evidence that it would not be possible to add a second core.

46 Both sites are allocated as opportunity sites in the Local Plan. Recorder House is identified as having an indicative capacity for 180 homes in the Site Allocations Document, yet only 144 homes are proposed on the site. In the context of the affordable housing offer and the Council’s allocation, it is considered that the density of the site has not yet been fully optimised, in accordance with London Plan Policy 3.4 and draft London Plan Policy D6, and the applicant should explore opportunities to increase the number of units on the site.

47 As the scheme cannot be assessed under the Fast Track route, due to the offsite provision of affordable housing, early and late stage viability review mechanisms must be secured within the S106 agreement in accordance with Policy H6 of the draft London Plan and Mayor’s Affordable Housing and Viability SPG.

48 The applicant has confirmed that they are engaging with a Registered Provider, Home Group, with the intention that they manage the affordable units. The applicant has also engaged with GLA Officers regarding the possibility of increasing the affordable housing offer through the use of grant.

49 The Council must publish any financial viability assessment, submitted to support a planning application, in accordance with the Mayor's Affordable Housing and Viability SPG. GLA officers will ensure that the assessment is made available, to ensure transparency of information.

page 8 Urban design

Recorder House

Layout

50 The proposed building broadly forms an ‘S’ shape across the site. Rather than building up to the eastern elevation, it is proposed to introduce an area of public realm to the east, onto which flexible commercial uses would face. Along High Road, there is a vehicular entrance into the car park in the centre of the elevation as well as two entrance lobbies and cycle parking. The applicant should maximise activity along this frontage through providing access into the flexible retail units, including exploring opportunities for inserting additional employment space, as discussed above.

Height, bulk and massing

51 The building rises to 15 storeys at the rear and a 10-storey building fronting High Road, with a 6-storey link building in between. Given the distance from any existing residential units, the adjacent planning permissions, which both rise to 9 storeys, as well as the railway lines to the north of the site, the proposed scale and massing does not raise any strategic concerns.

52 On High Road, the architectural treatment features brick cladding, with alternating fenestration and balconies in an irregular pattern. The building slightly protrudes over the ground floor, creating a partial canopy at ground floor, which aides in differentiating between the uses at ground floor and the residential uses above; however, the applicant should demonstrate that this is suitably animated and lit to ensure perceived pedestrian safety. To the rear of the site, the building design is simple, with brick cladding and regular fenestration.

Residential quality

53 The building generally has good residential quality, with all cores serving less than 7 units and a good number of dual aspect units. There is, however, one north facing unit on each floor and the applicant should seek to remove these. The applicant should confirm that all units meet the minimum internal space standards and provide sufficient amenity space.

One Station Road

Layout

54 Retail units front Cranbrook Road and wrap around the corner of Station Road, with office floorspace above these units. Residential entrances front the area of public realm on the corner of Station Road and Cranbrook Road. It is welcomed that the architect has cut away the corner of the building to the southwest to provide a more generous area of pedestrian footway / public realm on the corner of Cranbrook Road and Station Road and to provide a sightline of the tower from Cranbrook Road. The applicant should, however, maximise activity on the south eastern elevation that is proposed to be used for servicing.

Height, bulk and massing

55 The building is split into two parts: a 3-storey ‘pavilion’ building, which fronts Cranbrook Road, and curves around the corner of Station Road and Cranbrook Road; and a 42-storey tower, which sits behind the pavilion building when viewed from Cranbrook Road. It is considered that this approach respects the prevailing 3/4-storey heights along the Cranbrook Road and also aides in reducing the apparent bulk of the tower.

page 9 56 As discussed at the pre-application meeting, whilst GLA officers do not have any in principle concerns with the height of the building, it is considered that architectural refinement and further justification is required. The tower tapers twice, once at the 32nd floor and again at the 37th floor, through the removal of triangles of massing from the sides of the building, which visually appears as though the top of the building has rotated 45 degrees. Whilst this reduces the bulk to a degree, the building still appears heavy and blocky, particularly when viewed from the north or south, due to building on the entirety of the rectangular plot. The applicant should consider opportunities to ‘lighten’ and slim the block, including through considering dropping the height of shoulder, as discussed at the pre-application meeting.

Architecture

57 The buildings on the plot are different architecturally: the pavilion building features long, regular fenestration with aluminium coloured cladding; and the tower is 42-storeys tall, with a regular brick clad appearance with limited detailing. The architectures are considered to broadly correlate with the proposed land uses that are to be contained within them; however, it is considered that the two designs are disconnected and could relate to each other better. The applicant should explore opportunities to pull the design of the pavilion building into the lower floors of the tower, so that it appears as a plinth at the base of the tower. Through this process, there could also be an opportunity to reference the southern façade of the existing Bodger’s department store which is due to be demolished as a result of the proposals and, whilst it is not locally or statutorily listed, is understood to have been identified by the Council as a non-designated heritage asset. In addition, and as part of this architectural refinement process, the applicant is encouraged to present the proposals to the Council’s Design Review Panel to ensure the highest quality design and given the building’s prominence locally.

Residential quality

58 Residential units are located on floors 1 to 41, with communal facilities provided on the 4th, 32nd and 37th floors. There are a number of single aspect, north facing units and the applicant should consider opportunities to remove all north facing single aspect units. It is considered that the comments above, relating to reducing the bulk of the building, could aide in the process.

59 Due to the block form of the building, the building features an efficient internal layout with one core serving each floor of up to 10 units. The draft London Plan and Housing SPG are clear that a maximum of 8 units should be served by a single core in order to ensure good residential amenity. It is acknowledged that the applicant has sought to justify this exceedance through detailing the additional amenity space provided, as well as the occupancy of the units using the core; however, alongside exploring methods to lighten the bulk of the building, the applicant should consider opportunities for reducing the number of units per core.

60 In addition, the applicant must confirm that all units within the development meet the minimum space standards, as set out in draft London Plan Policy D4 and London Plan Policy 3.5 and confirm that each unit’s winter garden provides sufficient amenity space, in accordance with London Plan and draft London Plan standards.

Inclusive access

61 The applicant has confirmed that all of the units comply with Part M4(3) of the building regulations on wheelchair users’ dwellings, which is supported. The applicant must confirm that the landscaped area of public realm on the corner of Cranbrook Road and Station Road is fully accessible.

page 10 Heritage

62 Paragraph 197 of the NPPF states that the effect of an application on the significance of a non-designated heritage asset should be considered in determining the application, and a balanced judgement is required having regard to the scale of any harm or loss and the significance of the heritage asset.

63 It is understood that during the pre-application process the Council considered the neo- Classical southern facade of the former Bodger’s department store to be a non-designated heritage asset. The Council commissioned a review of the applicant’s heritage study, which concurred with the applicant, stating that the southern façade was of limited architectural or historic merit due to amendments and additions since its original construction in the late 1920s. In this regard, whilst GLA officers do not have any significant concerns regarding the loss of façade, the applicant should, as discussed above, consider opportunities to integrate the pavilion building into the tower and explore opportunities to reference the façade in the design. Energy

64 The applicant has broadly followed the energy hierarchy in each scheme’s energy strategy; however, to ensure compliance with London Plan and draft London Plan policies, the applicant must review their energy proposals. The applicant should use the GLA’s Carbon Emission Reporting spreadsheet, which has been developed to allow the use of the updated SAP 10 emission factors alongside the SAP 2012 emission factors. The technical energy comments for each scheme have been sent to the applicant and the Council.

Recorder House

65 With regard to the ‘be lean’ part of the hierarchy, a representative sample of DER and TER output sheets and reports of the overall Fabric Energy Efficiency, including percentage of improvement, are required. In terms of ‘be clean’, the following are required: further information on the district heating network; an alternative low-carbon heating method to the proposed CHP must be considered; and sample of SAP DER and BRUKL worksheets must be provided. The applicant is not proposing to provide any renewable energies on the site, which fails to comply with the ‘be green’ part of the hierarchy. All major developments are expected to provide renewable energies, regardless of whether the 35% on-site emission improvement target is reached through the earlier parts of the hierarchy.

66 The proposals would reduce domestic carbon emissions by 29%, which fails to meet the target set out in London Plan Policy 5.2 and draft London Plan Policy S12. In terms of non-domestic carbon emissions, the proposals reduce emissions by just 7%, which also fails to meet London Plan Policy 5.2 and draft London Plan Policy SI2. It should also be noted that draft London Plan Policy SI2 will require non-domestic buildings to be zero carbon by 2019 or provide an offset payment. Given that both elements fall short of the targets, the applicant must explore the scope for additional measures to achieve further reductions.

One Station Road

67 With regard to the ‘be lean’ part of the hierarchy, it is noted that the domestic element of the development is expected to only achieve a 6% reduction against 2013 Building Regulations, which fails to comply with the target of 10% set out in draft London Plan Policy SI2, and the non-domestic element would achieve just 4%, which fails to comply with draft London Plan Policy SI2 15% target; the applicant should, therefore, model additional energy efficiency measures and commit to higher carbon savings through energy efficiency alone. In addition, the Fabric Energy Efficiency performance should be provided. In terms of ‘be clean’ and in line with the Recorder House

page 11 comments above, the following are required: further information on the district heating network; an alternative low-carbon heating method to the proposed CHP must be considered; and sample of SAP DER and BRUKL worksheets. Again, the applicant is not proposing to provide any renewable energies on the site, which fails to comply with the ‘be green’ part of the hierarchy.

68 The proposals would reduce domestic carbon emissions by 44%, which meets the target set out in London Plan Policy 5.2 and draft London Plan Policy S12. In terms of non-domestic carbon emissions, however, the proposals reduce emissions by 14%, which fails to meet London Plan Policy 5.2 and draft London Plan Policy SI2. It should also be noted that draft London Plan Policy SI2 will require non-domestic buildings to be zero carbon by 2019 or provide an offset payment. Given that both elements fall short of the targets, the applicant must explore the scope for additional measures to achieve further reductions.

Transport

Recorder House

Trip Generation and Impact

69 The submitted trip generation and impact assessment is considered to be acceptable, as it is unlikely that the development will have a significant impact on highway or public transport capacity.

Walking and Cycling

70 The applicant proposes that the main residential access to the site will be car-free, which is supported; however, the current design of the vehicular access is unacceptable as the kerbed pedestrian area is less than 1 metre wide, which is insufficient for many users, such as people in wheelchairs, double buggies or those walking alongside their bicycle to access the cycle store. The width must be increased.

71 Whilst cycle parking is in line with the minimum provision set out in the draft London Plan, no drawings have been provided to show the layout and therefore it has not been possible to assess the cycle parking against the London Cycle Design Standards (LCDS), including whether there is adequate provision and access for larger bikes; this information must be provided.

Parking

72 The applicant proposes a total of 20 on-site parking spaces, equating to 0.14 spaces per unit, which is below the relevant maximum standard in the draft London Plan and is acceptable. There are, however, no disabled parking spaces and, as such, the current proposals are not in line with draft London Plan Policy T6. This must be addressed through revisions to provide spaces equivalent to 3% of homes at the outset. In addition, a car parking management plan should be secured by condition which should set out how further disabled parking could be accommodated, how disabled parking spaces would be allocated and how parking on these spaces by non-blue badge holders will be avoided. Finally, the Car Parking Management Plan should set out a strategy for repurposing general parking spaces if they are under-utilised, such as using for additional amenity space instead.

73 Future residents, other than Blue Badge holders, should be prevented from obtaining parking permits for neighbouring CPZs, which should be secured as part of a s106 agreement.

74 In line with the draft London Plan, all residential car parking spaces must provide infrastructure for electric or Ultra-Low Emission vehicles. Whilst 20 per cent of spaces would have

page 12 active charging facilities, only 20% would have passive provision; this passive provision should be increased accordingly.

Deliveries and Servicing

75 Servicing would be in a dedicated off-street area in the car park; however, as access will be gated, with an intercom, requiring delivery staff to contact residents directly, there is a risk that delivery vehicles will stop somewhere on-street instead. Furthermore, if a resident is not at home, the gate won’t be opened and therefore the driver would need to reverse back out onto the public highway, which would be a safety risk. Whilst it is accepted that no better physical arrangements can be made for servicing, the applicant should consider measures to mitigate these risks for inclusion within the Detailed DSP to be secured by condition.

Construction Logistics

76 The applicant has submitted a joint Construction Management Plan (CMP) for Recorder House and the related development of One Station Road. However, it does not sufficiently address the issues which are likely to arise and revisions and additional proposals are required. Given the proposed development’s size and location, it is essential that a Detailed Construction Logistics Plan is provided by the applicant, in line with the July 2017 TfL Construction Logistics Plan guidance, prior to commencement of construction, which should be secured via a planning condition.

Residential Travel Plan

77 The applicant has submitted a Residential Travel Plan, which is generally acceptable; however, a higher target increase in cycling mode share of at least 5 percentage points should be the sought. A Full Residential Travel Plan should be submitted six months after 50% occupation; this Full RTP should provide a surveyed baseline, amended targets and initial monitoring results for the residential element of the proposed development.

One Station Road

Trip Generation and Impact

78 Whilst the trip generation and impact assessment is generally acceptable, TfL does not agree that the retail element is likely to generate an insignificant number of trips, especially on foot, by bicycle and by bus. As such, the applicant should provide a revised assessment which takes into account these trips. Based on the revised assessment, it may be necessary to secure s106 contributions towards bus or pedestrian improvements. It is accepted that the development would not impact significantly on highway capacity.

Walking and Cycling

79 The Transport Assessment shows that the proposed development is expected to generate a significant number of walking trips, especially given that all public transport trips start and end on- foot. The proposed eastern vehicular access does not comply with draft London Plan Policy T2, as pedestrians would need to cross a 25-metre wide vehicle-dominated space used for (un)loading as well as negotiate vehicles which have to reverse into the servicing area from the public highway. This must be revised.

80 Whilst the long stay commercial cycle parking meets minimum draft London Plan standards, short stay provision and that for the housing does not and should be increased in line with the standards in draft Policy T5. Revisions to the layout and design of the cycle parking to comply with

page 13 the London Cycle Design Standards are also required including ensuring that 5% provision for larger bikes can actually be accessed.

Parking

81 The site is proposed to be car-free, which is welcomed in principle; however, as there is no provision for disabled parking the current proposals are not in line with draft London Plan Policy T6 and this must be addressed.

82 Future residents, other than Blue Badge holders, should be prevented from obtaining parking permits for neighbouring CPZs as part of the s106 agreement.

Deliveries and Servicing

83 The Delivery and Servicing Plan (DSP) states that servicing will be on site, which is supported by TfL; however, the apparent prioritisation of delivery vehicles over pedestrians and cyclists, as referred to above, does not comply with draft London Plan Policy T2. It is also proposed that delivery vehicles will reverse into the site, which also introduces conflicts with other road users as well as pedestrians and is, therefore, contrary to TfL’s ‘Vision Zero’.

84 The DSP does suggest several measures, including goods in managers for residents and the commercial element, which will help reduce failed deliveries; these are welcomed. A Detailed DSP should be submitted prior to occupation and secured by condition.

Construction Logistics

85 The applicant has submitted a joint Construction Management Plan (CMP) for Recorder House and the application site. The proposals for the Station Road site would result in blocking pedestrian access on the northern footway of Station Road for a period of 3 years, which is not acceptable. Furthermore, the CMP does not sufficiently address the construction logistics management for the site, which will involve up to 124 vehicles a day going in or out of the site. No swept path analysis or any detailed analysis on construction vehicle accessibility has been undertaken. These matters should be addressed.

86 An Outline Construction Logistics Plan (CLP) in line with the 2017 TfL CLP guidance should also be submitted by the applicant to show that the construction at the site will not have a detrimental impact on the local highway network. A Detailed CLP should be secured via a condition on any permission.

Travel Plan

87 The submitted Framework Travel Plan is generally acceptable. A Full Residential Travel Plan as well as full Workplace Travel Plans for each commercial element of the development should be submitted six months after occupation and secured within the s106. These full Travel Plans should provide a surveyed baseline, amended targets and, if appropriate, additional sustainable travel measures for the commercial and residential elements of the site.

Mayoral Community Infrastructure Levy (MCIL) and Crossrail S106

88 All new developments that create 100 sq.m or more of additional floor space are liable to pay the Mayoral CIL. The current levy is charged at £35 per square metre of additional floor space in Redbridge and from April 2019 it will increase to £60 per square metre. The site is also subject to

page 14 Crossrail S106 which should be secured in the s106 agreement but can be treated as a credit towards the MCIL payment. Local planning authority’s position

89 Redbridge Council Planning Officers are assessing the applicant and a committee date has not yet been established.

Legal considerations

90 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, 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. . 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. Conclusion

91 London Plan and draft London Plan policies on principle of development, housing, affordable housing, commercial and employment uses, urban design, energy and transport are relevant to this application. The application does not currently comply with the London Plan and draft London Plan, however, the following changes might lead to the application becoming compliant:

• Principle of development: Both sites benefit from good accessibility and are both locally allocated for residential-led, mixed use development, whilst One Station Road also lies within the Ilford Town Centre. As such, the principle of residential-led redevelopment on both sites is supported; however, given each respective sites’ allocation and designations, the balance of commercial uses on each site should considered and further justification is required for the loss of over 6,000 sq.m of commercial floorspace at One Station Road and the limited commercial provision at the Recorder House.

• Affordable housing: It is proposed that Recorder House, which will be 100% affordable, will provide the offsite affordable housing contribution for the entirely market Build to Rent scheme at One Station Road. When the sites are considered together, the affordable housing offer would be 33% by habitable room. The provision of offsite affordable housing is only acceptable in exceptional circumstances; as such, GLA officers will robustly assess the Financial Viability Assessments for each site to ascertain whether each scheme should provide affordable housing on site and, in turn, whether the viability provides exceptional circumstances for an offsite provision. Further information is also required on the London Shared Ownership units and London Affordable Rented units.

page 15 • Urban design: Further justification and work is required to reduce the perceived bulk of One Station Square, particularly when viewed from the north and south, and to ensure sufficient activity and good residential quality. For Recorder House, further work is also required to ensure good levels of activation and passive surveillance at ground floor.

• Energy: The energy strategies for both Recorder House and One Station Road have broadly followed the energy hierarchy, as set out in the London Plan and draft London Plan; however, further work is required, including selecting an alternative to the proposed CHP on each site and providing renewable energies on both sites.

• Transport: For Recorder House various items are required, including the provision of additional Blue Badge car parking spaces. For One Station Road, the applicant must re-run the trip generation assumptions, revise the servicing strategy and the provide Blue Badge spaces. For each scheme, various plans should be secured by condition or through s106 obligations.

for further information, contact GLA Planning Unit: Juliemma McLoughlin, Chief Planner 020 7983 4271 email [email protected] John Finlayson, Head of Development Management 020 7084 2632 email: [email protected] Katherine Wood, Team Leader 020 7983 5743 email: [email protected] Vanessa Harrison, Principal Strategic Planner (Case Officer) 020 7983 4467 email [email protected]

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